As we move further from Beltane and towards Samhain – not only a fine festival but also one of Glenn Danzig’s best projects – and a pattern of daylight which really only suits farmers, our collective chins may start to head towards our collective chests. There is not much cheer to be found out there, but I for one am taking some pleasure in the fact that this year for once we will not be playing host to spotty youths turning up and expecting loot for nothing in particular.

Unexpected outcomes have been on my mind this week as I’ve been prepping for HomeGames, which this week features Stirling-based uber-planner Garry Hale, who also happened to be PFS President in 2012, when RDR knocked at the door, ready to egg the windows of the advisory sector.

(If you want to hear Garry’s session you can join us live at 12.30pm today here, or catch up later here.)

Part of what we’ll talk about during our session is whether RDR really changed anything all that much. Without giving the game away, we’re just beginning to crunch the numbers on our State of the Adviser Nation 2020/21 census (568 of you responded; we think that’s the single biggest sample of the advisory sector since lockdown – thank you!) and when we look at the way the sector has changed over the last eight years, it’s maybe not as profound as we like to say it is. Yes, there was a lot of flapping about moving to facilitated adviser charging and away from commission, and much irritation with share class conversions, but firms like Garry’s were fee-based 18 years ago and still are now.

This was underlined for me this week with this really interesting story on SM&CR. Bovill, the regulatory consultancy, popped a little FOI request around a set of exploding caps and chucked it at the door of the regulator, and what it found was that there has only been one enforcement action under the senior managers’ regime in the last five years. Now, SM&CR is still newish for adviser firms, if not for providers, but it has been positioned as the ultimate regulatory bogeyman – proper go to jail stuff if you are found to be taking more than your fair share of the Heroes or Haribo from the hat. I’m starting to think that actually the advisory profession will find it much, much less burdensome than almost everyone has predicted.

More generally, the more I think about it, the more it seems to me that the accepted wisdom that the advisory profession is buffeted and bruised by regulation is wrong, or at least is if you take the long view. The marketing approach of so many providers – start using This Thing or do things This Way or you’ll come a regulatory cropper – is wrong too.

The profession (or whatever we want to call it) stays at the centre and regulation orbits it. That regulation warps the gravitational field; the provider moons, fund management planets and discretionary asteroids all feel its effects much more sharply. There are effects, of course – the odd lights flicker in the sky and sometimes there are electrical storms – but the profession is flexible and self-healing enough to deal with that.

Anyway, just idle thoughts on a dark Tuesday night. Stay safe and maybe just leave a wee offering outside for the Sidhs. They sometimes manifest as spotty youths.


  • We’re still looking for your platform reviews for Q3. I think platforms have done well in the last three months, but what do you think? Takes 4 minutes to do, makes you feel good and 37.2% more attractive to whoever you want to be attractive to. Tell us everything here.
  • I’d thought I might do this week’s TCWU on Farage, but Lee Robertson of Octo has done it in a more restrained and refined way than I ever could, so I was outclassed and outgunned. Great piece here.
  • This is a remarkable piece of writing from Ben Goss. Well worth 10 minutes of your time.
  • And your music choice – well, it has to be the Evil Elvis himself. Rather than Samhain, here’s Danzig with the highly relevant Soul on Fire. A prize if you can decipher the lyrics without looking them up.

See you next week