PIMFA CONSUMER DUTY WEALTHTECH
Update on PRIIPS and MIFID Costs - Investment Trust Forbearance
As you’ll be aware, HM Treasury (HMT) has announced that it will exempt investment companies from the PRIIPS regime and, in particular, associated cost disclosures. As we await this legislation to be published and progress, FCA have announced that they will not enforce its rules on this issue with immediate effect.
Following this announcement, we have received further clarification from the FCA with respect to its expectations for Distributors of investment companies shares to clients. In which it has encouraged firms in the distribution chain for securities issued by investment trusts, to look to work together to determine and share what information is required to enable the continued distribution of these products. This is in compliance with their more general obligations towards retail investors, including in particular under the Consumer Duty.
PIMFA is currently working with the Association of Investment Companies (AIC) on an agreed approach for the distribution of Investment Trusts. At present we are minded to agree on an approach which relies on the provision of a modified KID for each share. This would follow the KID format but could include changes to specific sections.
Preparers would:
• Include a prominent disclaimer in the KID stating that the document does not follow the KID requirements.
• State prominently that a KID is no longer required following a decision by the UK government and regulator.
• For any section which is materially amended (e.g. costs) state that the information does not follow the KID methodology.
• Revise cost disclosures. These could be left blank or labelled “N/A” or alternative figures (such as the ongoing charge figure) could be provided. Where a different methodology is provided, the basis for these would be explained. This specifically enables flexibility and removes the misleading and ‘one size fits all’ issues of previous KID disclosures. The information drawn to investors’ attention is likely to differ from one fund to another depending on the information the preparer believes best helps the investor make an informed decision.
• Include ‘signposts’ to further information, for example, including the factsheet, website and/or to the annual report and accounts.
We would welcome further input from firms before agreeing an approach. Please contact Simon Harrington with your views.
PIMFA Plus partner Mitigo introduce new game - The Cyber Heist!
To end Cyber Security Awareness Month, our cyber risk management PIMFA Plus partner Mitigo Group introduce their educational game that immerses players in the world of cyber threats: The Cyber Heist!
In this simulation, you step into the shoes of a cyber-criminal gang leader, strategizing your next attack in a high-stakes environment. The objective? Maximise your profits while avoiding capture.
Why Play?
• Understand cyber crime - Learn how organised cyber criminals operate.
• Develop critical skills - Enhance your awareness of cyber threats and defences.
• Stay updated - Learn about the latest trends in cybercrime.
Join Mitigo’s mission to raise awareness and knowledge about cyber threats.
PIMFA members can read MITIGO's new Cyber Security Matters guide here.
REMINDER: DEADLINE NOW EXTENDED TO TUESDAY 15TH OCTOBER
PIMFA WealthTech: New Tech Sprint on Strengthening Cyber Security Defences
PIMFA WealthTech has launched it latest Tech Sprint focusing on strengthening the industry's cyber security defences. With the launch of this Tech Sprint comes an invitation for FinTech firms to participate in this latest challenge by identifying and evaluating a range of effective technology solutions which can be deployed to strengthen firms’ cyber security defences.
Interested FinTechs can participate by registering online and due to demand the deadline has now been extended to Tuesday 15th October 2024 at 5pm.
Read the full press release here.
Accelerated Settlement Taskforce Technical Group - Draft Recommendations Report and Consultation
The Accelerated Settlement Taskforce Technical Group has today published its draft recommendations report and consultation, for consideration by all participants in the UK investment market.
PIMFA will be reviewing the report and responding to the consultation questions. The consultation closes at the end of October. If you would like to contribute to PIMFA's response, please contact Kevin Sloane.
Read the full report here.
The JMLSG revisions to Sector 18 in Part II of its Guidance
On 30 September 2024, the Joint Money Laundering Steering Group (JMLSG) published revisions to Sector 18 (Wholesale markets) in Part II of its Guidance, read the full details here.
HM Treasury publishes final draft of the Payment Services (Amendment) Regulations 2024
On 3 October 2024, HM Treasury published a final draft of the Payment Services (Amendment) Regulations 2024, which are intended to allow Payment Service Providers to slow down the processing of outbound payments when there are reasonable grounds to suspect fraud or dishonesty.
The maximum time that payments can be delayed will be extended by 72 hours where there are reasonable grounds to suspect a payment is fraudulent.
Payment Systems Regulator: Policy Statement
On 3 October 2024, the Payment Systems Regulator published a policy statement, PS24/7, confirming the maximum level of reimbursement under its Faster Payments Authorised Push Payment scams reimbursement requirement would be set at £85,000.
The start date for the reimbursement policy is 7 October 2024.
Investment Week: 'The million dollar question' for wealth and asset managers as Consumer Duty enters next phase
PIMFA sets out 5-year agenda for government to create a UK Culture of Thriving Financial Health
PIMFA calls on next Government to create a more attractive environment for investors after General Election
Private Banker International: UK private bank Hampden & Co welcomes new CEO arrival
FT Adviser: Majority of advisers say consumer duty has been positive PIMFA LEARNING AND EVENTS
PIMFA Live Online Learning: Mastering Your Ongoing Compliance with Consumer Duty
The FCA urges firms to show 'how' they are improving customer outcomes. Unsure where to start? Join our masterclass, 'Mastering Your Ongoing Compliance with Consumer Duty' and ensure your firm's compliance with the Duty evolves with changing customer needs, good market practice, and regulatory expectations.
By attending this masterclass you’ll be able to:
• Rectify and remediate the gaps in your MI and data.
• Enhance your processes and controls to monitor customer outcomes.
• Overcome common challenges, weaknesses and failings in your approach to outcomes monitoring and testing.
• Ensure that your firm is able to effectively identify and proactively remediate and crystallised or potential consumer harm.
• Assess and prioritise the tasks your firm’s needs to undertake to ensure alignment with FCA’s ongoing Consumer Duty expectations.
Take advantage of our early-bird offer. Reserve your place today and bring a colleague for free.
PIMFA GUIDE ON UNDERSTADING CUSTOMER VULNERABILITY FOR FIRMS LAUNCH EVENT
PIMFA has been working closely with the regulator and member firms this year to understand better the extent and range of vulnerabilities that customers may face and to ensure that firms can correctly identify and support those customers.
As part of our work, we will be launching a PIMFA Guide on Understanding Customer Vulnerability which will be a valuable reference aid and will assist firms with creating vulnerability strategies and implementing processes and procedures that will not only help to meet regulatory obligations but also identify opportunities to enhance how firms serve all their customers.
To mark the publication of the Guide, we will be holding a Understanding Customer Vulnerability Guide Launch Event on the 24th of October 2024, where we will hear from the FCA and a range of industry CEOs and practitioners to discuss the importance of this topic and to share views and best practices.
You can find out more and view the agenda here.
Please note this is a virtual event which will be live-streamed, or for further information please contact events@pimfa.co.uk
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