I mean we’ve all done it, right? You’re filling out your tax return, you’ve got your pension contributions sorted, your charity donations, your child benefit payments which you should have cancelled some years ago and then the Deliveroo guy comes to the door with your bao order and you miss out your £27 million offshore trust because of course you do and I mean how could anyone be upset about that?
Advisers aren’t accountants – much too much fun at parties for that – but when you’re talking about tax affairs with your clients it must be good to know that this sort of thing is basically OK and nothing to worry about, right, and you can always have a chat about it later with the nice chaps at HMRC – as long as they’re working for you – and it’ll all work out.
Anyway, too much to Update on this week to dwell on mendacity, though a different strain may crop up in the links; who can tell?
EVENTS, DEAR BOY, EVENTS
Very quick bit on this. Our 9 February #langcatlive Home Truths event is fully sold out for in-person attendees and there is a burgeoning waitlist. It’s relatively unlikely now that if you don’t have a ticket you’ll get one. However, you can stream all or part of the session for free and that ain’t bad. Two cameras, professional sound, amateur presenters, brilliant guests, all of whom bar one are advice professionals, not providers. If you do want to stream it, you need to register in advance so we can send you access details, and if you want to do that please do so as soon as you can because I’ve already lost enough hair.
I’m pleased to say we have an awesome charity partner for the day in Refugee Support Europe. We were introduced to them by Phil Billingham and David Crozier, who as many of you will know have made superhuman efforts to bring help directly to suffering Ukrainians in the last year. Fair warning: whether in person or remote we will be bopping everyone over the head to open your moneybags and extract some bawbees.
Other event news: also benefitting Refugee Support Europe will be another gig from “industry supergroup” (whaaat?) Consumer Duty; surely the worst-named band since A*** C*** – although your mum might agree to wash your Consumer Duty t-shirt. Anyway, Phil and David have organised this and we’re playing at Stationers’ Hall in London on 23 February. The band is Chris Budd of the IFW, Ian Beestin of Money Alive, Jenny Smyth of Verve, Nigel Ross-Scott of PIMFA and me. You can get tickets here – just £20 – and donate here if you can’t make it. It’ll be a laugh.
We also need sponsors for this. The venue and the PA hire and all the rest of it don’t care that it’s for a good cause, and so if you’re a business with some discretionary spend available and you want to do some tangible good then come and talk to me so we can cover costs and get some proper money flowing to people who desperately need it. I can offer sponsorship of:
- The bar
- The venue
- The PA
- The gents (willing to sub-divide the package per pissoir)
- The ladies
- Ian’s left drumstick
- Ian’s right drumstick
- Chris’s overcomplicated guitar multi-effects thingy
- Nigel’s shirt (sunglasses recommended)
- My burning desire for more distortion
- 20% of the sequins on Jenny’s outfit (5 packages available)
And so on. You know where I am; we need your money, let’s make it happen.
BACK TO WORK
Let’s get more serious now with regulatory affairs, which always make me think of Ugandan affairs but then most things do these days. I don’t get out much. Two things to bring up like a particularly fine furball…
First up, in a stunning display of doing what it is it said it was going to do, FCA has launched a retirement income advice thematic review. Details are scant but at least some of you will be tapped on the shoulder with an attractive invitation, ‘Atchet ‘Arry style, to contribute. If and when that happens, I think we can expect the kinds of questions you’re asked to be a reasonable hint as to the kinds of questions that will crop up in Consumer Duty work. I’d expect these to include such hits as “how do you know what you’re doing is good value?”, “how do you know the tools you’re using to model out retirement are robust?” and “how do you know your investment strategy is appropriate for retirement income if it’s the same one as you use for pre-retirement?”. I mean, there will probably be others but I’ll bet my tax budget of £5m that these will crop up.
By the time you read this, FCA will also have published a multi-firm review on Consumer Duty prep. The firms reviewed tended to be bigger and with their own close-and-continuous relationship; a bit like Big Chris had with Harry I suppose. You should read the MFR yourself; it’s only nine pages long, and gives some very useful areas of good and poor practice. There are too many to summarise here, but here are the things that stuck with me when I read it last night:
- Aligning your CD work to the four outcomes seems about right
- If you’re big enough, appointing a CD champion who’s senior enough to punch their weight at your management table is essential
- Don’t assume that what you are doing just now is OK, or that the data / business information you get just now is adequate
- Don’t forget to look at third parties involved in delivering or helping you deliver your proposition
- Where improvements are needed – perhaps to look more closely at clients in closed-book products – then that’s OK and shouldn’t be glossed over.
In terms of warning shots, this sentence seems the best summary: “…we saw some plans that suggested firms may have considered the requirements superficially or are over-confident that their existing policies and processes will be adequate.”
Your response is your own, but I’m not convinced that I-am-not-listening-to-Jeffrey-but-he-is-still-talking is the right approach here, whether you’re a small planning firm working all the hours, a bigger firm trying not to think about the complexity of all the back book business you’ve got or even a DFM considering due diligence on the platforms that you allow to host your portfolios.
CAREFUL, DELIBERATE LINKS
- Big week last week – we launched the fifth wave of our annual adviser survey, State of the Adviser Nation. If you missed the launch webinar you can catch it here. Iss good.
- Imagine putting an advert like this out and then doubling down and defending it when you’re quite rightly pulled up. Absolute mendacity, knavery and a masterclass in what not to do even if you’re trying to be an “edgy brand” (yuck).
- Transact has got the salami slicer out again, this time to what I’m going to refer to as its “vintage” buy commission charge.
- Your music choice this week is not from Consumer Duty, but is a belter of a tune from Swedish sadbois Katatonia, just one of many fine Scandiwegian metal bands that we won’t be covering. Here’s Opaline. No more boundaries to cross…
See you next week. Try not to be careless.