So some wag must have read last week’s Update where I boasted that us Scots can go off on holiday earlier and for less money than our English confreres, worked out that I’m going to France, leant on Macron and now there’s going to be another election just after this interminable one. You wouldn’t think that all of Europe could have lurched to the right just to mess with my holiday, but there it is.
Talking of messing with things, I was struck by this piece from the reliably effervescent Justin Cash over at Financial News on the latest emission from Stratford. This one is a big survey that has to do with vulnerability and supposedly is going far and wide, so may be coming to an inbox near you soon if it hasn’t already.
Given the focus on vulnerability in Consumer Duty I doubt many of you are shocked and stunned that there’s a data request. But what’s inside it is instructive and potentially awkward.
As Justin points out, even some ostensibly straightforward questions might be hard to answer. Question 3 – the first real one after “how are you?” and “what did you have for breakfast?” – is “how many individual retail customers do you have?” I know plenty of firms who will find that a tricky needle to thread. And if you don’t have the number to hand, it’s not an easy one to magic out of nowhere.
Q3 disposed with, let’s (beep beep) board the Awkward Questions Bus to Q5, wherein we are asked “what proportion of your retail customer base have you identified as vulnerable?” If you’ve done the work and given each client a vulnerable / non-vulnerable flag in your CRM or practice management system (see last week’s Update on why you need to think about data integrity) then you’re good for Q5. If not…well, strap in because we’re just getting started.
(Don’t worry, I’m not going to do the whole thing, there are 29 pages)
So we’ve already established that having a tight hold on your data is pretty important. This is true no matter what kind of firm you are; this Trojan horse of a survey doesn’t discriminate. But what if you’re more than one kind of firm at the same time? What if you’ve fully leaned into the new world and are your own DFM and maybe even your own platform too?
Well, don’t worry. The survey has you covered. You have plenty of space to detail all the different services you offer and then go through how you deal with vulnerability for each of them. Bear in mind your answer will likely be different for your DFM service from your financial planning service and so on.
Watch out for question 8, by the way. You get to say how much action you’ve taken in a range of areas, and the temptation will be to tick the furthest right “good boy” box for all of them. If you do so, the triumphalist ‘gotcha’ of questions 9, 10 and 14 will definitely stretch your creativity skills – here’s the text of Q9: “In Question 8, you confirmed you have taken action to understand the nature and scale of vulnerability in our target market and what this means for consumers’ needs. Which of the following actions have you taken in order to execute this?”
Training, comms, all sorts; it’s all here. And the reason I’ve dragged you through all this isn’t to go on about vulnerability, though that’s obviously important. It’s to demonstrate the standard to which you’re being held accountable in terms of not only thematic areas of interest, but also basic data, controls and business MI. When the sector has talked about professionalism in the past, we’ve always assumed it meant giving good advice. Now it means this too.
I’ve said it before, but advice businesses, in your privileged position closest to the client, are absolutely in the driving seat. You can do anything you want within the law. You’re in control, and the emerging advicetech industry is making it more and more possible for you to do more and more. The question is: can you do everything? It’s absolutely cool for you to be your own DFM, platform, SIPP operator; whatever. But you’ll be held to the same standard as a business that only does that.
And that’s where my four words come in; this is my summation of everything the regulatory regime has been building towards through TCF, PROD, MiFID II and now Consumer Duty, and they are these: “you’d better mean it”.
Do what you want. You’re in control. You have all the power. But…you’d better mean it. And surveys like this are just part of how it’ll be monitored.
And your music choice this week is a real treat. It’s been a long time since The The put out new music, and I couldn’t be any more excited. The second the bassline starts you know exactly where you are. Do enjoy Cognitive Dissident.
