You know what? I can’t even. So here’s a joke instead. Why are ants always getting sick? Because they only have tiny antibodies. Thank you. I’m not here all week. Might take to my bed for the next two years.
Quite tempted to leave the Update there.
But I won’t. Instead, let’s have a think about something practical you can do for Consumer Duty. We’ll be doing the Duty comprehensively at our Edinburgh event in a few weeks – see below – and giving you Stuff that you can actually do rather than vague warnings about how you’ll be forced to assume the position by the regulator if you don’t is what we’re aiming for.
I was talking to a big provider yesterday – that is to say, a person who works for a large company that provides platforms and stuff, rather than a huge dude who provides non-specific things – who had, I thought, a pretty enlightened view. It sort of breaks down like this:
- All the compliancey, ticky-boxy stuff will be taken care of by compliancey, ticky-boxy people and that’s fine for keeping out of jail and whatnot.
- But there’s the capacity to do some development to help adviser firms meet your responsibilities (and as the bunch closest to the client you certainly do have some).
- But other than for very big firms who can afford to hire consultants (hi!) and project teams, few firms he’s spoken to could articulate what would help, so he can’t really build it.
This is just one provider, of course. But isn’t that the right sort of attitude? I thought it was.
So. How can we help said bod to spend her money wisely? And by ‘we’ I mean, of course, ‘you’.
The thing with Consumer Duty is that it’s about outcomes to be sure, but also the journey towards the outcome. It’s at least partially on you to define what ‘good’ looks like, and also to protect your clients from ‘foreseeable harm’, and it’s equally up to you to define what ‘foreseeable’ and ‘harm’ means. With me so far? Good.
There’s no point in being all hello-trees-hello-sky about this. The key to getting all of this right is data. Data on your clients’ expected outcomes vs their actual results. Data on the experience they’ve had along the way. Data on what has gone wrong and what was done to put it right. And so on.
A key thing you can do to help yourself, your clients, and the providers you work with (who I promise you are bricking it about Consumer Duty as much as anyone, though they won’t admit it) is to work out what you think would be a good data dashboard for you to monitor on behalf of your clients. Imagine you’re sat in front of a big mixing desk with loads of channels and you want all the wee lights to be green lest you blow the hearing aids off the audience. You’re monitoring it all and swooping in on anything that’s too low or too high. Unless it’s Motorhead, obviously.
For example, you might decide that speed of paying out PCLS is a good measure for your clients at the point of crystallisation. That’s reasonable. But when you ask most providers for data on speed of PCLS payment, they’ll quote a service standard, what percentage of cases met that standard, and possibly the average time taken to pay out. But averages aren’t our friends often, and a 98.3% adherence to service standard with an average time of 7 days isn’t any good to you if all your clients have had to wait three months. So it’s on our friend from the big provider to work out how to supply you firm-specific information – but you need to be ready to tell her what you need.
This – to me at least – is what Consumer Duty does. Yes, it makes firms defensive and no doubt we’ll see lots of stuff about on average how good things are. But it also requires the industry to work together; to draw together counterparties so that the experience of your clients is monitored; not in the abstract but in reality.
So think about getting to work defining a dashboard that allows you to monitor the ins and outs, ups and downs for your clients specifically. Then share that with those you need to supply the data – and expect it. The ability to deliver will be one of the defining characteristics of a good supplier in this new era. And remember that their necks are on the line for this too, so they will be asking for your data in return.
EVENTS, DEAR BOYS AND GIRLS, EVENTS
I said last week I’d be punting our Edinburgh event on 5 October relentlessly, and look Ma! That’s exactly what I’m doing. Since we last spoke we’ve been able to confirm a speaker from the FCA to talk about Consumer Duty, and a bunch of great paraplanners and planners to share their experiences of technology, regulation and lots more. We’re also looking forward to our fintech showcase, where some of the most exciting fintechs aiming Stuff at You come and show their wares. Full details and how to get free in-person tickets (if you’re an advice professional) are here.
During the event we’ll also be going through some of the findings from our new report on the fragmentation of the adviser technology market, covering platforms, CRMs, tools, APIs, hubs and lots besides, all through the medium of cat jokes. It’s a follow up to 2019’s A Disconnected World, but this time is cleverly called A Fragmented World. We’ll launch it at a separate do on 20 September. If you fancy coming along to the breakfast briefing in Fashionable London drop me a note on email@example.com and I’ll see what I can do. All free.
- At this time of great upheaval you might enjoy listening to a senior politician having at it freely with no real expectation of keeping his job in the coming weeks (let the record show he is still in post). Such a one is Guy Opperman, pensions minister of note, and you can hear him having, as we say, at it with Tom McPhail on Tom’s podcat here. Already our 2nd most downloaded episode.
- We continue to add new MPS providers to Analyser – Rockhold (Sense Network’s portfolios) and Wealthselect from Quilter are now live. Never been a better time to get your subscription, priced to own etc, apart from all the other times. #marketing
- Parmenion buys EBI, just in time to make it into the Update.
- IFA consolidator slags IFAs. We’re through the looking glass here…
- And as I write this on the train down to London on Wednesday morning, I find that it’s a Nick Cave sort of day, but not in a Release The Bats sort of way. So here’s a live version of Grinderman’s Palaces of Montezuma, and you could do a lot worse than lie back, close your eyes and take a few minutes out to enjoy it.
See you next week