Compliance Q&A part 5: How can firms keep their ongoing advice services compliant?
Following the FCA’s release of its findings into its recent ongoing advice review, TCC and Recordsure’s Chief Product and Commercial Officer Garry Evans catches up with TCC’s regulatory expert and Technical Director David Boyhan – who specialises in wealth management to unpack all the detail.
In the final instalment of the five-part mini-series, Garry asks David how can firms keep their ongoing advice services compliant. Watch part five now to learn more or read the transcript below.
Watch part five:
Garry
Okay so finally then David, what should firms be doing now to ensure that their ongoing advice processes are compliant?
David
Okay so Garry, there’s two things’ firms need to be doing. The first is a go-forward piece: that’s potentially the easier of the two that firms need to be doing. The go-forward piece is looking at your current policies and processes and making sure they’re geared towards delivering a good ongoing service for clients. Circa 90% of clients receive an ongoing service and it’s essential that those clients are receiving good outcomes. So, firms really need to start by looking at their client agreements to see what’s being promised to their clients, they need to look at their fair value assessments and they’ve got to look at their processes such as disengagement where clients are not engaging with the process. So that’s a go-forward piece – look at your current policies and procedures and make sure they’re compliant. I think it’s fair to say the FCA findings are positive, but there’ll be no excuses going forward now the FCA has released its findings from the thematic review, it would expect policies and procedures to be compliant going forward.
The second thing that firms need to do is a backward-looking piece, and that is going back to 2018 and getting all the MI you need in relation to clients who haven’t been engaging with the process and clients who may not have been invited to engage with the process as well. And then taking appropriate action in relation to potentially providing redress to the relevant clients and also potentially disengaging them.
So, there’s two things’ firms should be considering: that’s a go-forward piece but not forgetting the backward-looking piece, ensuring that all clients historically have been receiving good outcomes.
Garry
That’s great. Thanks very much David.
Watch the full Compliance Q&A video:
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