One time, when on holiday with the lang kittens in a part of England that I can’t remember, we went to a forest park place called Bewilderwood. The back-story for this place was something to do with creatures who looked like people who were called Twiggles, and creatures who didn’t look so much like people who were called Marsh Boggles.

Anyway, the Marsh Boggles didn’t like the Twiggles very much, if memory serves, or possibly the Twiggles didn’t like the Marsh Boggles. High jinks ensued. The whole thing had the potential to get very dark indeed, especially when the teenagers working at the park had to do Boggle and Twiggle dances. We all went home having learned, I suppose, valuable lessons about man’s natural fear of the Other, and quite a lot about capitalism.

Not sure what made me think of that. I think perhaps we are all in Bewilderwood now.


Let’s focus. We may not have much time. I’ve really only got one big thing to talk about.

The FCA took back some sort of control this week with a Dear CEO letter to pension providers about DB transfer business. You can read the letter itself on the FCA website here.

It’s a remarkable piece of writing. In it, the regulator seems to tell providers that they are responsible for checking the advice of IFAs, and of hollering loudly if they don’t like what they see. Here’s a quote:

“We expect you to have appropriate measures in place to ensure that products are being recommended responsibly and appropriately, in accordance with the Treating Customers Fairly Principle.”

Woah, woah, slow down there Fernando Alonso, can this be right? Have we crossed to the other side, a side where advisers recommend things and providers say “sorry Susan, you’ve no’ done that right” and refuse to take the business? Is this just about DB transfers? What is its applicability to other types of business? Is Intelligent Money right to pull out the market? What, to cut a long story short, in Bewilderwood is going on?

It’s actually all very simple, and no, providers aren’t going to have to check advice, or at least I don’t think they will. The answer is that this all comes down to PROD again. I’ve written on it before here and in other places – that’s sort of the nature of locations, I guess – and in fact the quote above comes from a paragraph called “The information you give to distributors” which is all about ensuring that manufacturers (providers) give distributors (advisers, hahahahaha, that still cracks me up) the correct information to make sure advisers planners trusted financial coaches distributors can give the kind of advice you can eat your dinner off.


PROD is something advisers are waking up to, though your friend and mine Rory Percival reckons only 1% of firms have got themselves sorted out for it – that could be 50 times better and would still be poor. What’s interesting in this letter is that we’re seeing PROD really impacting the lives of manufacturers as well as advisers.

Anyway, the key thing is that the industry’s usual method of nodding sagely at regulation before going back to doing exactly what it was doing before, may not hold with this one. It all flows from MiFID II, and has a way of worming into everything – once there it’s very hard to shift, much like certain diseases in Victorian London. I’m not sure about the diseases of the Marsh Boggles, but someone else can probably tell me.

Have a read of the letter, look at the key terms such as ‘target market’ and ‘consumer’s best interest’ and then take a look at PROD, section 3.3 in particular. There is much to go at there, and not all of it is intuitive. This one isn’t optional. Oh, and be ready for providers to get very risk averse with DB transfers and to start asking all sorts of questions.


  • First up, 7IM has cut its price for the very poshest of its posh customers. You can find out the detail here, but it’s actually quite a saving given the size of the portfolios under consideration. Also cool is that it works for family groupings. It’s hard to get the energy up to head to the barricades about something which makes rich people very slightly richer, but it’s all good.
  • I thought this article on multi-asset investing in its different guises was really interesting from Morningstar. This comes as a few providers are working on their multi-asset ranges, including Premier who launched three new funds yesterday and GAM who have been tinkering with pricing on theirs.
  • If you missed lang cat consulting director Steve Nelson’s remarkable podcast on mental health with Ollie Smith of Citywire, there’s a full transcript available now. It’s well worth a look.
  • And there’s no contest for the musical spot this week. Scott Walker was an incredible singer and total oddball, and the world is a little less interesting now. Here’s my favourite Walker Brothers tune. We will be gods on nite flights indeed. And if you want to see a great cover, this one from the Fatima Mansions is legendary.