PFS's Matt Connell: Regulatory risks
In this exclusive column, Matthew Connell, director of policy and public affairs for the Personal Finance Society, looks at why the Consumer Duty is not the 'be-all and end-all' for Financial Planners this year. This edited article first appeared in Financial Planning Today magazine (July-Aug issue).
It’s understandable that alongside the historic implementation of the Consumer Duty on 31 July, press column inches have been swallowed up by seemingly endless commentary and advice about how to achieve the FCA’s four stated outcomes.
However, while focus is rightly in the moment, we can’t afford to lose sight of another FCA initiative that was launched quietly in January.
The thematic review of retirement income advice is due to be completed in the last quarter and is an important second arm to the regulator’s work on retail financial investments. Understanding how the two initiatives might fit together is key to understanding regulatory risks in the sector.
As we know, the Consumer Duty identifies four outcomes for firms to work towards:
• Products and services
• Price and value
• Consumer Understanding
• Consumer Support
The retirement income review will use these outcomes as a lens to bring common market practices into focus. The FCA has already said that, "The results will…be an important indicator of how firms are implementing the Consumer Duty."
So, what areas will the thematic review be looking at?
We already have a pretty good idea of some of the potential themes from comments made by FCA leaders, including the clustering of adviser charges at a small number of price points.
Although it’s natural for the regulator to be thinking about price, I think it’s vital to start with the potential benefits that advice brings to clients, which go beyond the selection of a suitable investment or insurance product, or the ongoing rebalancing of portfolios. They include setting clear and relevant financial goals, providing increased confidence and security and reassurance during periods of short-term market turbulence.
Firms can match these benefits to the needs of different target markets, which can then inform pricing strategies – if a firm can demonstrate a clear link between the needs of different groups of clients, the cost of providing the services to meet those needs and a range of charges based on that analysis, it will be in a very strong position to defend its proposition.
The introduction of the Consumer Duty is not the end of the road but a milestone on the journey.
• Matthew's column appears in each issue of Financial Planning Today magazine. You can subscribe to the magazine by registering for this website and then checking subscription options in 'My Account.'
Matthew Connell is director of policy and public affairs for the Personal Finance Society.