Another week in, and it seems forever ago that I was able to be a hermit because I wanted to be rather than being forced. Days of thunder, I tell you. My only wish is that, when all this is over, video conferencing by people hunched over laptops in dimly lit rooms becomes a thing of the past. I have seen up more nostrils in the last few weeks than most ENT surgeons manage in a lifetime.

Fun fact: certain big-brand laptops have their webcams below the screen rather than above it, to ensure you get the full nasal hair / cornflake effect. I have some innovative ideas about what to do with the designer who thought that little wheeze up.

Two things to talk about this week. First up, let’s have a wee think about digital business. We’ll be discussing this at today’s #HomeGames webinar, which you can join here at 12.30. If you can’t make it then a recording will be available at the same link. Tim Page of Page Russell will be joining me to have a good old moan.


It’s remarkable that so many providers insist on wet signatures in this day and age. As Tim will (probably) point out later on, there are tried and tested digital ID products freely available and have been for a long time. Offering scan-and-send options is better than requiring self-isolating advisers to physically drop into your office, but not much. A form still needs printed, enveloped, sent to the client, who needs to sign it and send it back to the adviser, who needs to scan it, save it somewhere and upload it. Worse, the client scans it and emails it insecurely to the adviser.

Happily, today the FCA has had some words to say on client identification verification – you can find that here. Page 2 has the details.

As providers find that they actually can amend their processes quite quickly when forced to, we should see more and more on the path of righteousness, and understanding that lines of colloidal systems of fine pigment particles dispersed in a solvent and applied to compressed moist fibres of celluloid pulp are not, in fact, sacred.


News reaches us – and everyone else who reads the Dear CEO letter – that the FCA has relaxed the 10% drop rule until the end of September. This is good news, but it is fervently to be wished that the rule would go away forever, and that right quickly.

The truth is that the 10% rule was always aimed at wealth managers, and specifically vertically integrated European wealth managers who haven’t quite scaled the giddy heights of Transparency Mountain that their UK cousins have been forced to. Good luck finding out what’s going on in your portfolio if you are with one of those guys – so a 10% drop rule makes some kind of sense, if you half-close your eyes and squint.

It makes no sense here, and particularly now. An arbitrary limit, over an arbitrary period, with no recommended action off the back of it, is wrong-headed at best and damaging at worst. Here’s hoping it doesn’t come back.


  • More platforms have sent us details about their coronavirus responses and what they’ve been doing on MiFID II 10% reporting – obviously that will all change again now. You can find those responses on the free section of Platform Analyser here.
  • Our Edinburgh neighbour Multrees has done away with wet signatures entirely – read all about it here. 587 house points and an extra grog ration to Multrees.
  • If you’re feeling investmenty, this is a good piece from David Stevenson in FTfm (paywall) – “there isn’t any compelling evidence ESG strategies can deliver outperformance.”
  • And your music choice this week is a good belt of swamp rock with exactly the right sentiment for those keeping on and particularly working to keep the health service going in these troubled times. Have Still Unbroken by Lynyrd Skynyrd, whether you like it or not.

See you at 12.30 – or next week.