It is probably fair to assume a good number of our TCWU readers attended the Professional Adviser awards last night. I hope you all had a great evening and are feeling bright and energetic. Mark has been “in meetings” all morning, so for this week I’m on update duty. Fear not – there will be no loud thrash metal on my watch….

Shortly before we all went on our Easter breaks, the FCA published their business plan for 2022/23. As the name suggests, this sets out their intentions for the next 12 months. For our world of advice, platforms, asset management etc, aside from the increasing threat of violence aimed at the DB pension transfer market, the next year can be summed up in two words. Consumer, and Duty.

Current timescale has the final policy statement dropping in July, almost certainly a few days after Mark goes on holiday, with the rules due to be implemented this time next year. There have been some calls for this implementation period to be extended, most notably from PIMFA. I don’t think a delay would be the right solution, but it does highlight the big problem the regulator will face as they roll out Consumer Duty.

Each of the four outcomes is a beast in its own right. Any one of these would require a lot of work to implement, especially if they are enforced to the letter of the law. Collectively it leads to the concerns PIMFA are rightly raising, and on t’other side of the fence you have to wonder if the FCA are biting off more than they can chew.

I wrote about the detail of the customer support outcome in Money Marketing this week. The value for money and customer communications outcomes are equally challenging. Whilst the products and services outcome might be the least troublesome, it does have a whiff of “you should be doing this already via PROD”, and it will underpin a large part of the overall work. Add it all together, and there will be a lot to work through over the next 12 months.

As we await the final rules it is interesting to note that Nikhil Rathi believes Consumer Duty will result in “fewer future rule changes”. A delayed implementation might make it easier to do the bare minimum, but I don’t think it will help firms get to the standards the FCA are expecting. In order to achieve this the FCA will need to ensure the final rules are supported with clear good (and poor) practice examples, setting out examples of how they expect the Consumer Duty to be implemented. As with the “fewer future rule changes” comment, this should not only cover merely being compliant, but also the spin off benefits this will deliver. The new rules create a nice stick if needed. We now need the carrot…


  • First (and probably last) appearance for the Isle of Wight County Press in the links section. An awful interview with one of the victims of a pension scam, showing the impact this crime had on his life. Fortunately, the scumbags involved were jailed last week, but that’s probably small comfort to this chap…
  • I enjoyed Michael Klimes’ piece in Money Marketing last weekend. Lots of good points to consider as digital propositions become more ubiquitous.
  • Closer to home, if you are an adviser or work in an advice firm, we’d LOVE IT if you could complete our latest provider ratings survey. Click here and let us know who you heart or hate.
  • If you’re an Analyser subscriber and want to know all about our shiny new MPS capabilities, why not join us on our next demo on 5 May? We have lots of cool functionality to show you – book your free place here.
  • GENTLE MUSIC PLEASE. Soothe your tired head with a track from one of my favourite albums of last year… Sunshine by Cleo Sol.

See you next time.