2024 isn’t done with us yet and while I had every intention of keeping this week’s session as frothy as a frothy thing we do have one or two matters of substance to keep us busy. I appreciate you’re probably not here for Content this week – you may well be at your Christmas party, as indeed I will be soon after you read this. I’m distressed to read this about Christmas parties and I hope you are not plagued with this affliction. Activities are all very well but they can only take you so far.
This will be the second last Update of 2024; don’t know if you’ve noticed but Christmas is a Wednesday this year and much as I love you all I’m not doing one of those awful timed-to-send emails on the day itself. I do like seeing who forgets to cancel their timed posts and emails though; a good guide for which individuals and companies to ignore for the year to come.
It being the second last, I’m allowed a bit of a punt at the start (there’s another halfway down, not even sorry), and this is for our London event in early February. It’s called Divide And Conquer and I think it will be pretty good fun with a good mix of froth and, you know, not. You’re about to read a load of regulatory news, and so I’ll just mention that Sara Woodroffe from the FCA will be appearing, talking advice/guidance, consolidation and more. Book your (free for advisers, paraplanners, admins) tickets here. In person only; no streaming this time.
Right. Here we go. I suspect some Stratford residents had some objectives to tick off before the holidays and so we’ve seen a flurry of activity in recent days. “Look boss! I did all the stuff on my list! Please can I go to the bauble decorating and mocktail making party now? Please?”
Three things to put on your radar – the first is that we expect to hear the next steps in the advice/guidance boundary review tomorrow. On the one hand this feels like pre-Christmas postman’s knock, but on the other hand it’s good to see where things are going. Eyes peeled.
Second, it’s worth putting Tom Dunstan’s piece in FT Adviser into your eyes for a read of the tea-leaves in terms of where the fair value part of Consumer Duty is heading. It looks like we’ll get more on cash interest on platforms; you may have noticed along the way that some providers have been tidying up their stance.
More interesting even than interest, though, is this quote: “We want firms to use robust analysis to assure themselves, and us, that they are offering fair value, and identify and take action where they are not.”
That fair value assessment is going to be crucial. It’s not glamorous, but it’s not a waste of time either; if you do find, having used “robust analysis”, that you’re in a good place, then that’s a nice story to share with clients. The next question of course is: what makes for robust analysis? I expect we’ll see good and poor practice notes in time, but at the risk of talking my own book I think tools which allow for the demonstration of suitability, not just basic comparisons and which are completely independent of provider funding and control might be Well Worth It. Should you wish to see one in action, please head here, priced to own etc. Have a trial and a play over Christmas, good way to escape the family. But the broader point stands; this isn’t going away.
So there’s that. Finally, we need to mention a really big end-of-year story in Platform Land (insert time-honoured theme park joke here). The FCA’s leashing of FNZ’s new business activities is an unusual step and there is no nice way to put it; it spins itself. FNZ is massive and systemically important to our sector, but more crucially it’s vital to many, many clients who need it to do what it does to the highest standards. If doing a Pink Floydian “if you don’t eat your meat you can’t have any pudding…how can you have any pudding if you don’t eat your meat?” is part of ensuring that happens, then that’s how it has to be.
This illustrates a broader point. We read recently about platforms becoming co-manufacturers and stepping more into the regulated world (the nature of FNZ means it has been regulated for ages). If we are to really join up all the parts of the chain that control client outcomes, then it feels right to bring platforms and perhaps other forms of software into the body of the kirk as well. Will that increase costs or choke innovation? I’m not sure it will; the market generally takes care of this stuff, and if the drift downwards of platform pricing is very slightly slower then that’s hardly a deal-breaker. Most planning firms we speak to don’t want innovation anyway; they want the lights to go on and off when they flick the switch and no funny business, thank you very much.
So there we go; lots to think about as we lurch into the break. I promise next week will be frothy.
And your penultimate music choice of the year isn’t a Christmas song; you get that next week and it’s the only one which breaks the TCWU no-repeat rule. Instead what you need to cut through your sugary, alcoholic fug is some folk metal, and that means Eluveitie, not that I need to tell you that of course. Here’s Premonition, just out a couple of days ago, wherein Eluveitie are doing Eluveitie things except with more of a make-up budget and some pretend rocks for Fabienne to drape herself over. What’s not to like?
