Newsletter David Potton - Compliance Manager Email: David.potton@therightequityrelease.co.uk Mobile: 07980 212950 Tel: 01245 422509
Introducers - Clarfication Following on from last months newsletter, there has been some debate over the current Introducer Agreement in that it implies the relationship is between TRER and the Introducer and not the Adviser and Introducer. TRER recognise the hard work our advisers have gone to establish valuable relationships with their Introducers and we would never seek to interfere with this.However, we do have a regulatory responsibility to ensure that all parties are aware of their responsibilities and we do need to maintain a register of all Introducers and ensure agreements are in place. With this in mind, we are changing the wording on the current Introducer Agreement to make the relationship clearer. This will be available from the usual place.
GPDR Following on from the GDPR presentation and the “self-review”, we are now in the final throws of implementing the GDPR procedures. You will shortly be receiving a declaration to confirm that you have undertaken the necessary precautions. You will need to sign and return this to me as soon as possible. Please however also bear the following in mind:1. 2. 3.
You must not store your passwords for CRM on your laptop. Be sure to ensure it doesn’t If you lose your laptop or it is stolen, you must report this to either myself, Rob, Sarah or Jo as soon as you become aware and we will ensure that your access to CRM is suspended. CRM itself has end to end encryption using SSL therefore entering or retrieving data should be safe.
GDPR will have a regular slot in these updates as this will provide a forum to discuss issues that arise.
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Tracesmart There appears to be some confusion over the use of Tracesmart. Just to clarify, this is now compulsory on all clients as detailed in Rob Brennan’s email dated 16th November 2017. A compulsory field will soon be placed on CRM which could delay input if you have not obtained one.
Complaints Fortunately, as a firm, we do not receive a high volume of complaints. However, we thought it might be useful to share broad details of complaints we do receive to help advisers understand the main areas of concern. All the complaints received recently have all related to Gilt Linked ERC’s. All cases were the same i.e. where the client has been able to repay the loan and the Gilt Rate has changed invoking a high ERC.I am not sure we can cover this in any more depth that we do already, but advisers should continue to ensure that clients are fully aware of this at the point of sale. Some of the suggestions I have received from advisers have included getting the client to sign the relevant part of the illustration. At this moment in time I can report that the Financial Ombudsman has not upheld any of these complaints.
Financial Promotions Please note that the turn around time for all Financial Promotions is 7 days although we aim to do this a lot quicker. Please ensure that you always submit the authorisation request form (available on drop box) with each Financial Promotion.
Changes to compliance procedures Following discussions between the Management and the Compliance and Training and Competence Departments, the following procedural changes have been agreed.
CRM The 7 day rule for sending out suitability letters has been relaxed. The rule is now that a fully compliant file must be uploaded to CRM within 14 days. Please note that these timescales have been designed to ensure that we stick to the FCA rules, they are not flexible.
We look forward to seeing you all at the next Sales Meeting: Thursday 21st June The Village Solihull The Green Business Park, Dog Kennel LN, Solihull B90 4JG
The Right Equity Release 21D Croft House Knowle Solihull b93 0JE 0800 612 6755 www.therightequityrelease.co.uk