“Did you have a nice…?”

“Yes, it was very…”

“Seems a long time…”

“Certainly does, ready for the next…”

So that’s sorted that out, good to catch up. Now put your behind in the chair and do some work.

You’ve got a lunchtime, I’ve got an Update and we might as well sit the two of them together and see if one of them doesn’t offer to buy the other one a drink. Who knows where we might end up? Maybe with lots of baby Updates.

Let us open our hymnals, then, at the FCA’s 2019/20 business plan, wherein we may divine what the regulator has planned for all of us in the next year or so. You don’t read the FCA’s business plan, and I’m keen to keep it that way, because it’s by cheating and reading stuff like this that folk like me can sit on panels at conferences and sound knowledgeable, maybe even savant-like, about what the regulator has in store. “How does he get this privileged information?” you think. “Is he some kind of seer? What access he must have! Is this DARK MAGIC? Should we FEAR HIM or FOLLOW HIM?”

It is. It is dark magic. And reading the business plan.

Anyway, much of it matters to mortgage guys and credit guys and peer-to-peer guys and all that, and we don’t need to worry about that here. But you may wish to have a wee look at chapter 6, pages 36 & 37. This is the ‘retail investments’ sector focus, and it’s where the interesting stuff is for most folk reading this.

Before we do though, let me just say for the record that I really do feel for the person who has to pick the stock imagery for the front of FCA publications. The business plan is a boring document – it has to be – but the art department has eschewed the recent trend of happy looking people in urban environments and gone straight for an architectural shot from what Bill Bryson calls the “F*** You School Of Architecture”. This is a photo so brilliantly dull and ugly that whoever picked it should immediately be allowed to read the news at teatime.

Back to it. Here are two key quotes:

“Our main concerns in this sector are unsuitable and/or low-quality advice and products, and high charges.”

“Our 2017 Assessing Suitability Review identified areas where firms could do more to ensure they provide customers with suitable advice and clear communications. We will carry out a second review in 2019 and aim to publish our findings in 2020. This second review will again examine advice and disclosure firms give to different consumers, across different product types and by different types and sizes of firms. It will allow us to assess how firms have implemented the requirements introduced by the Markets in Financial Instruments Directive, the Packaged Retail and Insurance-based Investment Products and the Insurance Distribution Directive. It will also provide an updated baseline against which we can assess ongoing issues within the advice market.”

So a big theme for the year-and-a-bit coming up is exactly what us at the lang cat and many others like us have been saying for a while: after the Asset Management Market Study and the Investment Platforms Market Study, the eye of Sauron was inevitably going to swing back to the advice sector.

I’ve said this before, but I don’t know any adviser worth their salt who gives even borderline poor advice. I do know plenty who, if asked to prove how their assessment of suitability matched the requirements of the major legislative and regulatory instruments they labour under, would suddenly have a nasty coughing fit and have to leave the room for a glass of water.

One little interesting bit in that: “…across different product types and by different types and sizes of firms.” I’m hoping we can expect a good look at the consolidators and vertical integrators to try and settle once and for all if the advice they give is up to scratch.

There’s lots of other good stuff in there – the focus we saw trailed in the IPMS on transfer times (there’s a pension version of this too), a good look at scams including discretionary managers using very high-risk products, and a longer-range study of the impacts of RDR and FAMR.

So a lot to look forward to, then.


  • First up, we’re still shilling our event on 30 May – the lang cat Home Game. It’ll be braw as a craw, and if you’re based in Scotland or would like to visit, we’d love to see you. Full details here.
  • Still on events, you should keep your eyes peeled for the results of Citywire’s Retreat in Chepstow, wherever that is. I thought this was an event where the Citywire team walk backwards looking scared, but apparently it’s a proper conference. Anyway, there’s a big bit in it on mental health in asset management, and that’s not something you often see brought up at a conference like this. Kudos to Ollie Smith of Citywire, our own Steve Nelson and Rosanna Williams-Wood of The Secret Coach who are standing up and doing the do. #EndTheStigma
  • I’d say consolidation of adviser firms is set to continue.
  • And for the music slot this week, let’s keep the holiday vibe going. With Holiday In Cambodia by The Dead Kennedys. You are very much welcome.

See you next week