PIMFA Weekly News Bulletin - 10 October 2022

Significant win for PIMFA on Simplified Advice

Emily Shepperd (Chief Operating Officer and Executive Director, Authorisations FCA) delivered a speech at the “Financial Planning Conference 2022” in Liverpool on Thursday 6th October.

The speech highlighted vulnerabilities and risks generated from current market conditions, and FCA’s ongoing and planned support to firms and consumers in the authorisation processes. FCA is encouraging financial services firms to monitor consumer behaviours and to offer help at the first signs of vulnerability, and to ensure investors get appropriate and professional advice before taking big decisions.

As part of the FCA’s Consumer investments strategy, FCA is keen to establish a simplified advice regime for mainstream stocks and shares ISAs where the risks to consumers are relatively low. Simplified advice will remove some regulatory burdens which currently apply across the board to all advisors. It will also enable firms to reduce their charges and make advice on mainstream investments more accessible to mass market consumers.

This is a significant win for PIMFA who have been advocating for a simplified advice regime for some time. We look forward to engaging with the detail of the FCA’s proposals when they become clearer.

PIMFA Consumer Duty Implementation plan outline

Following our recent Consumer Duty Working Group sessions, which focused on the implementation plan, PIMFA have produced a high level outline to help members meet the 31 October deadline for board approval.

Members can download the outline here

FCA provides further explanation on the Consumer Duty based on firm FAQs + new FCA Consumer Duty webpage to support firms

The FCA have added an information for firms page to their Consumer Duty webpages to help firms implement the Duty. This provides more explanation on the areas of the Duty that firms have queried:

FCA expects firms to develop plans, by the October deadline, assuring their Boards (or equivalent management body) and the FCA that the expectations set out in the Duty have been carefully considered and will be implemented for new and existing products by 31 July 2023. The FCA has clarified its expectation in that it does not expect firms to have fully scoped all work required to embed the Duty, but it does expect firms to set out how they will do so in the time provided by the remaining implementation period.

FCA expects firms to have a champion at Board level (or equivalent governing body), ensuring that the Duty is being raised regularly in all relevant discussions, and that the Board is challenging the firm’s governing body/management on how it is embedding the Duty and focusing on consumer outcomes. Firms should note that this is not a prescribed responsibility under SM&CR and firms can set it up in a way that fits with existing roles and responsibilities. More broadly, firms should note that the Board Champion will not be singularly responsible for the firm’s implementation of the Duty, merely responsible for ensuring it is discussed at the Board.

FCA has clarified the definition of closed products; Closed products are products that are no longer marketed or distributed to retail customers or open to renewal. Existing customers can continue to make payments under the existing product terms as long as the product or service is not open to new customers.

The FCA intend to keep this updated and have also published the speech Sheldon Mills gave last week on "What firms and customers can expect from the Consumer Duty and other regulatory reforms"

Read PIMFA summary on the FCA’s Sheldon Mills provided advice on implementing the Consumer Duty now.

FCA consults on replacing FCA Financial Resilience Survey

The FCA have published a Consultation Paper with proposals to replace the FCA Financial Resilience Survey with a new regulatory return during 2023. In doing so, they aim to reduce the administrative and financial burden that an ad hoc survey places on firms & increase the quality and consistency of financial resilience data.

We invite firms to respond to the questions in the Consultation Paper by Friday 2 December 2022

However, they still require firms to complete the Financial Resilience Survey when requested to do so by us, until such a time that the new return comes into force.

They’re planning to send this survey to the relevant firms in Tranche 2 on one of the following dates:

• Batch 1: to be sent on 18 October 2022 response due by 8 November 2022

• Batch 2: to be sent on 19 October 2022 response due by 9 November 2022

• Batch 3: to be sent on 20 October 2022 response due by 10 November 2022

• Batch 4: to be sent on 21 October 2022 response due by 11 November 2022

Firms in the Temporary Permissions Regime and Supervisory Run off Regime can expect to receive this same survey, based on the same timeline above.

They will send a warm up/introduction e mail to all the firms at least one week prior to them receiving the survey.

Completion of the survey is mandatory under section 165 of the Financial Services & Markets Act (FSMA) 2000. We may exercise our powers under FSMA for firms who do not respond. We have designed this survey so that it is quick and simple to complete. However, if due to exceptional circumstances a firm cannot access its financial information, they will need to ensure that they complete the questions where the relevant information is available.

The 2022 Q4 PIMFA Asset Allocation Survey is now open

Complete this quarter's survey, and you can:

• Receive a complimentary, 40 page report, showing you how the strategic asset allocations of your firms model portfolios compare to others

• Enable the index weight methodology for the MSCI PIMFA Private Investor and Equity Risk Index Series’ to ensure they remain relevant benchmarks for the UK wealth management sector Click here to submit

Cyber Security Awareness Month

It’s Cyber Security Awareness Month, and our PIMFA Plus partner Mitigo are sharing helpful advice and guidance.

This week they are focussing on passwords. Perhaps it goes without saying, but the stronger your passwords, the better protected your system will be.

The graphic shows five ways you can make yours better. It is good practice to change your passwords regularly either when prompted by the system, or if you’re even a slightly unsure if the account has been compromised.

If you can’t remember when you last changed your password, it’s probably time for a new one why not change a couple of them now while you’re thinking about it?

For more helpful cybersecurity advice, follow Mitigo on LinkedIn, or head to their blog

Latest PIMFA Press Releases

PIMFA Press Coverage

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Read our latest magazine here

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PIMFA announces shortlist for second Diversity & Inclusion Awards

PIMFA updates Future of Supervision paper and calls for more improvements from the FCA

Read more press releases here

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Citywire New Model Adviser: Take consumer duty seriously, FCA director warns

Money Marketing: Liz Field: Working for a diverse and inclusive future

The WealthNet: PIMFA adds IFA managing director to its board

CapaData: CA Summit 2022: New advice regime could be on the cards

Financial Planning Today: PIMFA helps members get ready for FCA Consumer Duty

The New York Daily Paper: Fears over public servants who quit their gold plated pensions

See more of PIMFA in the press

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Improving diversity and inclusion across the industry

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Read them all here

THE PIMFA ESG ACADEMY FOR WEALTH MANAGERS

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Change is happening. Governments are legislating for mandatory climate disclosures, new rules and regulations are constantly being announced while impacts on firms are still being evaluated.

The Conference 2022 aims to provide attendees with the latest information firms will require to ensure they are ready for what is coming and the opportunities these changes will create for their clients and the sector.

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PIMFA LIVE ONLINE TRAINING: OUTSOURCING, THIRD PARTY RISK AND RESILIENCE

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