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PIMFA Fortnightly News Bulletin - 22nd August 2019 Welcome to the PIMFA Bulletin, our fortnightly e-newsletter delivering a snapshot of the latest news and current affairs from within PIMFA and the industry.
What is PIMFA working on? PIMFA Brexit Update - Ten weeks to go The UK is ten weeks away from leaving the EU. As things stand, the country is heading towards a ‘no deal’ Brexit on 31st October. Both sides remain entrenched in the same positions – the UK insists that the Withdrawal Agreement should be reopened and the Irish backstop removed and the EU maintains that only the Political Declaration, a non-binding document attached to the Agreement, can be changed. This week Prime Minister Boris Johnson is due to meet German Chancellor Angela Merkel and French President Emmanuel Macron but in the current political climate, expectations regarding the outcome of the talks are not high. Meanwhile, The Labour Party has indicated it plans to call for a vote of noconfidence in the government as soon as Parliament returns from summer recess. If a majority in Parliament votes in favour of declaration of no confidence, Jeremy Corbyn, Labour leader, would seek to form a temporary government of national
unity in order to stop the UK exiting the EU without a deal. This temporary government would ask for an extension of Article 50 in order to call a general election. Corbyn promised he would take Labour into the election committed to a public vote on the terms of leaving the EU, including an option to Remain. It is not clear, however, if other party leaders and MPs working on stopping a ‘no deal’ Brexit, will be able to reach a consensus on such a plan. It is critical that PIMFA members are prepared for the ‘no deal’ scenario on 31st October to ensure the minimum possible disruption to their business. They should ensure that their clients are aware that a ‘no deal’ scenario is a real possibility and that they understand what this means for their business operations and contracts. Our advice to PIMFA firms remains the same – after Brexit, passporting will cease to exist and firms wishing to access clients in the EU Member States will need to consider options including: -
Setting up an entity in each Member State where there are clients
-
Setting up a passporting subsidiary in one EU Member State for all EU clients
-
Merging or affiliating with an existing EU based firm
-
Seeking an alternative provider to the EU clients and withdrawing from the EU
private client market -
Only using mitigating factors such as a reverse solicitation in situations where
they have checked that it will work.
PIMFA's New Sustainable Finance Working Group PIMFA is setting up a Sustainable Finance Working Group in September. It will focus upon monitoring the wide ranging initiatives currently taking place to address Sustainable Finance issues and identifying the potential impact on firms and clients. We will also focus on compliance and regulatory obligations arising from the work on sustainable finance, such as the obligation to consider clients’ ESG preferences in the context of assessing suitability. If you’d like to join the Group or get more information, please contact Des FitzGerald.
MiFID II Transaction Reporting Working Group meeting – ‘The implications of Brexit on MiFID transaction reporting’ – Monday 9 September 10:30 – 12:00 at PIMFA As a 31 October Brexit is starting to look increasingly likely, we thought it would be a good idea to look again at the implications of Brexit on MiFID II transaction reporting. David Nowell from Kaizen Reporting has kindly agreed to give an ‘impact of Brexit’ presentation on Monday 9th September 10:30 – 12:00 here at PIMFA’s office, 22 City Road. Please email Kevin Sloane if you would be interested in attending the meeting either in person, or joining via the conference call.
FCA Guidance for firms on the fair treatment of vulnerable customers On the 23rd July, the FCA published a consultation on its proposed guidance for firms on the fair treatment of vulnerable customers. The guidance document sets out practical steps that firms can take in translating the FCA’s expectations into action and includes examples of good practice as well as case studies. The consultation on this guidance will take place in two stages with feedback on the first stage by 4th October 2019. At this point, the FCA is seeking feedback on three areas: •
Whether the proposed guidance covers the right issues and provides sufficient
clarity for firms; •
The cost-benefit breakdown of the proposals;
•
Whether the guidance goes far enough to ensure firms take appropriate action
or whether additional rules are required.
You can read the consultation in full here. PIMFA will be responding to this consultation and welcomes views and comments to be sent to Alexandra Roberts.
PIMFA Financial Adviser Survey 2019
If you are a Financial Advice firm PIMFA are very keen to hear from you. We’d like to gather your input for our Financial Adviser Survey 2019, which can be accessed here. We are looking to gain some insight in to what the main concerns are for Financial Advisers this year, in terms of time and cost. This will provide us with greater clarity concerning the constraints and growth opportunities within the industry, both now & in the future. The survey can be completed in under five minutes and your participation is greatly appreciated. All data provided will remain anonymous and we will be distributing the resulting Financial Advice Market Report (FAMR) later this year. If you have any queries or comments please email PIMFA’s Head of Research, Gary Sunderland.
Tips on getting the most out of your membership We thought that it may be useful to remind members of some top tips to ensure they are getting the maximum benefits from their PIMFA membership: •
Membership is on a firm level and as such an unlimited number of your staff
can sign up for access to the PIMFA members only web area, register for events and free webinars and receive our research and publications free of charge. •
We create numerous useful guides for member only use on important technical
and compliance issues such as the Senior Managers and Certification Regime (SM&CR) CyberCrime, Defined Benefit Pension Transfers , The Insurance Distribution Directive, Vulnerable Customers, FOS, Inter-broker client transfers, etc. •
Remember you can use the PIMFA membership portal to update your details.
If you have a large number of staff contacts registered with us, contact us at enquiries@pimfa.co.uk and we will help you keep them up to date.
If you have any questions, please email us at enquiries@pimfa.co.uk and we will be happy to help.
Latest PIMFA Press Releases
PIMFA Condemns New 50:50 Funding Proposal in Consultation Response to FOS Funding
PIMFA letter to new Prime Minister Boris Johnson
Leading Cash Savings Platform Insignis Cash Solutions and PIMFA Announce Strategic Partnership
PIMFA: Industry must Safeguard Public Trust in Sector
Read all of the PIMFA press releases here
Latest PIMFA Consultation Responses
PIMFA’s response to the BSI draft technical advice (PAS 7340) framework for embedding sustainable finance principles in financial services organizations
PIMFA’s response to FOS Our future funding - A consultation
PIMFA’s response to the feedback on the draft technical advice on minimum requirements for the EU climate-transition benchmarks and the EU Paris-aligned benchmarks and benchmarks’ ESG disclosures
PIMFA’s response to the Decarbonisation of the UK Economy and Green Finance inquiry
Read all of PIMFA's Consultation Papers here
What's coming up in PIMFA? PIMFA's Autumn Webinar Schedule
We kick off our autumn schedule of FREE webinars with four offerings to support members in making their final preparations for SM&CR, including the effective handling of complaints and the development of a robust CASS framework. ‘SM&CR: The Hidden Challenges for HR’ 11.00am, Tuesday 10th September ‘CASS in the new world of personal accountability: Are you ready?’ 3pm, Monday 16th September ‘SM&CR Conduct Rules: Best Practice Implementation’ 10am, Tuesday 17th September ‘Effective Complaint Management’ 11.00am, Wednesday 18 September
For more details on these webinars, and for registration, please email learning@pimfa.co.uk
Women in Wealth Forum 8th October 2019 Fidelity International CPD: 3 hrs Our final PIMFA ‘Women in Wealth’ event for 2019 brings together colleagues from across the industry for peer-to-peer debate, networking and inspiration.
Speakers will include top female professionals from our industry and its key stakeholders to share insights and experience, as well as a practical element of takeaways suitable for both men and women on individuality within your organisation.
Speakers: •
Stuart Cummins, Managing Director and Executive Head, Nedbank Private Wealth •
Liz Field, Chief Executive, PIMFA
•
Mark Freed, Chief Executive, E2W •
•
Anita Rolls, Consultant
Tracey Reddings, Managing Director, Reddings Wealth Management
*Please note that, as of 1st June, PIMFA events can only be booked using a credit card*
Sign Up
PIMFA Annual Summit 2019 16th October 2019 etc. venues County Hall Riverside Building, Belvedere Rd, Lambeth London SE1 7PB CPD: 6 hrs The PIMFA Annual Summit 2019 will be taking place in London on Wednesday 16th October.
Our flagship conference provides delegates with the opportunity to investigate and gain a comprehensive understanding of the issues that impact upon the investment management and financial advice sector, providing an exceptional opportunity to debate, gain insight and network.
Speakers: •
Katy Balls, Political Correspondent, The Spectator • •
• •
Torsten Bell, CEO, Resolution Foundation Stephen Bush, Political Editor, New Statesman
Julia Dreblow, Founding Director, Fund EcoMarket
Debbie Gupta, Director - Life Insurance & Financial Advice, Financial Conduct Authority (FCA) •
Dr. Rebecca Harding, Chief Executive, Coriolis Technologies •
•
Holly Mackay, Founder & CEO, Boring Money
Daisy McAndrew. Former Economics Editor and Chief Political Correspondent, ITV News •
Rt Hon. Jim Murphy, Managing Director, Arden Strategies
*Please note that, as of 1st June, PIMFA events can only be booked using a credit card*
Sign Up
What's happening in our industry CSDR Settlement Discipline regime – new live date This is still subject to confirmation from the EU Commission, but Euroclear have indicated that the new Settlement Discipline regime will not be going live as planned on 14 September 2020. The live date will be moved back to 23 November 2020, to coincide with a SWIFT messaging update. If you have any queries, please email Kevin Sloane.
Latest news from the Financial Conduct Authority FCA podcast: Culture and SM&CR The FCA have published their Inside FCA podcast: Culture and the Senior Managers & Certification Regime. This interview with Executive Director Jonathan Davidson and guest Dame Jayne-Anne Gadhia, former Chief Executive of Virgin Money, discusses the impact of SM&CR and its role in creating a healthy financial services culture, including Conduct Rules and Certification.
Fair Pricing in Financial Services In July, the FCA published a feedback statement on their work on fair pricing in financial services. The judgement of when pricing practices are unfair is not always straightforward. So, in line with FCA's Mission, they developed a fair pricing framework to be transparent about how they think about this issue. This summarises the main themes from the submissions they received and provides further clarification on how they will apply their framework in practice.
They will now begin the work to formally embed this into their regulatory approach and they will report further in Q4 2019/20.
FCA and Practitioner Panel Survey Results The FCA and the Practitioner Panel have published the findings from their 2019 joint survey of FCA-regulated firms regarding their views across the financial services sector of the FCA's performance as a regulator, specifically on how well they are achieving their operational objectives: •
securing an appropriate degree of protection for consumers
•
protecting and enhancing the integrity of the UK’s financial system
•
promoting effective competition in the interests of customers
This year, scores against the first two of these objectives have risen slightly. For competition, the confidence of fixed firms increased. But the overall score for all firms showing confidence in FCA's ability to achieve this objective decreased from 72% to 70%.
The survey revealed some specific areas for improvement: •
The FCA need to ensure the costs imposed on firms of providing information are
proportionate to the benefits. There was a substantial increase in the proportion of fixed firms who said the number of information requests are greater than seems necessary. •
Flexible firms have overall higher satisfaction scores than fixed firms, but are
less likely to agree that our staff have sufficient experience and are appropriately qualified.
Since conducting the survey, they have clarified their approach to supervisionFCA will evaluate the impact of this work and any changes to firm views in the next survey.
Latest Industry Events
View all the latest industry events on our website here If your firm has an event which you would like to post on this area, please click here to submit it.
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