Are you aware of ASR2?
not then you need to get with the FCA TLA’s!
Assessing Suitability Review 2.
This is the second stage of the FCA’s plan to assess suitability across the IFA market in investments and pensions. It will take place later this year – and your firm could be selected for the review. The review will ask for your new biz book. It will then pick files to check, and you’ll be sending in the FF and SR plus supporting documentation for FCA to check. If your firm are deemed below average then you will be asked to account for it.
In the 2017 review
58% of files in small independent firms were deemed to have submitted unacceptable disclosure (31% in networks) to their customers.(section 4.6)
You need to make sure you don’t land on that part of the next FCA Venn diagram. Get your files checked by IFAC.
DB contingent charging
DB contingent charging in the news this week– stole the headline in Financial Adviser this week.
Trustees of DB schemes are keen to recommend IFAs to their members, but less so when the firm does either not have the capacity to help (size) or they operate “contingent charging” – ie where advice is for free unless a transaction is executed.
It has always seemed quite reasonable to ask customers if they could cover basic expenses if, after all the work, it was decided not to proceed – and hey presto! You have crossed the floor from contingent charging to fee. But IFAC recognise that is also a challenge in the pockets of poverty in the UK – where the DB pension scheme represents virtually the entire estate of the owner.
FCA Brexit briefings for IFAs
On 15 February 2019, the FCA published a press release https://www.fca.org.uk/news/news-stories/brexit-briefings announcing that it is holding two briefings for regulated firms to give firms a clearer understanding of its approach to managing the impact of Brexit.
There are 1.2m British Citizens living in the EU - according to the PFS. presumably many of them need your advice!
The events will take place on 11 March (London) and 14 March (Edinburgh) (both will also have a live webcast). They are aimed at senior level staff in regulated firms who are involved in Brexit preparations. The FCA particularly encourages smaller firms to attend.
At the briefings, Nausicaa Delfas, FCA Executive Director of International, will explain how the FCA has been preparing for Brexit and its expectations of firms. The session will also include a panel Q&A session where firms can discuss any concerns they may have. Firms are asked to submit questions in advance when they register.
DUE DILIGENCE REVIEW
How to prepare your biz for sale
Your firm will one day get a letter like this. When a buyer looks at your business, they hire a compliance firm to complete a due diligence review.
Here is one we received recently on a client's behalf.
“It was good to speak earlier. As discussed, can you please provide us with the following documentation to help us conduct our review:
- Client brochure
- Client remuneration agreement
- Any regulatory correspondence from the past 6 years, including any FCA/ FSA assessment
- The last three reports from your compliance consultant (IFA Compliance)
- The result of any file checks (if any) that IFAC Ltd have completed in the past 12 months
- Any other TCF MI that the firm produces
- The firm’s Training and Competence scheme (or any other training and competence material)
- The firm’s new business register for the past 12 months
- A copy of the firm’s PII contract
- The firm’s complaints procedure
If you have any questions about any of these documents please give me a call or drop me an email.
We aim to start the review as soon as we have received the documents.
Trainee financial adviser courses
On the first Wednesday each month 10am to 1pm
6th March Wednesday 10am to 1pm
3rd April Wednesday 10am to 1pm
1st May Wednesday 10am to 1pm
5th June Wednesday 10am to 1pm
3rd July Wednesday 10am to 1pm
Delivered by experts with years of experience in financial services, this training course is specifically designed for Trainee Financial Advisers and Mortgage Advisers. This course is based around the following three key areas you will need to know in order to work as a Financial Adviser or Mortgage Adviser:
- Compliance Manual
- Training and Competence Manual
- Procedure Manual (relevant to your firm)
You will also be provided with copies of each manual for all three areas covered.
Each of the three sections takes one hour to cover, and includes over 60 slides, plus handouts.
Each manual will set out, in general terms, the regulatory reponsibilities and minimum standards required for authorised firms and individuals, and will give new entrants a clear idea of expectations for your firm.
Upon completion of the training course, each delegate will need to sit a test, and if they pass, receive a CPD certificate to acknowledge completion. The course qualifies as Structured CPD.
- Members- Free
- Non-Members- £100 + VAT per attendee
John Downs Head of Compliance at IFAC Ltd and director in charge of T&C Also with presentations by Charlie Palmer, Chairman of IFAC Ltd, on the compliance manual, and by Max Durrant, Head of Operations at IFAC. and by Chidi Kalu, IFAC specialist on new entrant training and qualified AML reporting officer. See all staff CV's here
Needs clarification? Chidi.firstname.lastname@example.org
find out more here