Hot enough for you? See, you all moan about Scotland being dreich and cold, and then the first hint of 42 degree temperatures and you’re all like “oh wish we lived there Mark”. To which I say – you and everyone else. (Thanks to Craig Spittal on the twitters for that).
Anyway, the mercury did get up to the high twenties at one point, so the steady 14 degrees in the man-cave was welcome, and being installed down there gave me a bit of time to think about lots of things, at least some of which were Consumer Duty.
This is maybe the last Update of the pre-Consumer Duty era: the rules may be published as early as next week, so just in case m’colleague Mr Michael “I’m off for a bike ride” Barrett will duly helm the Update while I strategically disappear on holiday.
So let’s have a think about one aspect of Consumer Duty that we are sure will be included in the smorgasbord of new rules: the cross-cutting rule (which means it applies to all kinds of business) that providers must ‘avoid causing foreseeable harm to retail customers’. And another, aimed at ‘distributors’ (if you’re an adviser or planner you’re still a distributor, because the regulator enjoys winding you up) which states you must not distribute products or services unless you are satisfied that your distribution arrangements are consistent with the product or service providing fair value.
We’ve been down some of these roads before with PROD and even TCF – but these standards are higher in ways which we’ll tell you in weeks to come. But for now let’s think about how we might, were we a distributor, assess ‘fair value’ for something a little bit tricky. Let’s go past platforms, let’s go past funds and let’s go somewhere intangible, where the crickets sound, the warm air is perfumed, the cognac is plentiful and…ow!…a thousand biting little gits just decided I look tasty.
Sorry, I really, really need a holiday.
We won’t go there then; let’s go to DFM model portfolio services instead. Less bosky, but considerably more relevant. OK, Polson. Focus.
So how do we assess whether these services, which weren’t really caught by PROD but will be under Consumer Duty, are offering fair value? We can’t just go on raw performance – too many variables. Cost? That’s part of it, but something cheap and unsuitable is still unsuitable. Whether a client has complained? Well, that will depend on what the client understands – and Consumer Duty will have plenty to say about that. What does ‘fair value’ even mean?
The wonderful thing about doing what you do is that you get to decide a lot of this. The really hard thing about doing what you do is…you get to decide a lot of this. And what Consumer Duty will ask you to do is to evidence structured thinking around it all.
So, just for fun, and before anything’s published, let’s think about what we might ask ourselves about an MPS provider to work out if they offer fair value. Here’s how I think we could do it in three questions…
- Do the portfolios behave in the way I was led to believe they would?
- Does the provider keep me updated with the information I need?
- Are any communications they provide to the client clear and readily understandable?
Each of those is loaded with tonnes of nuance and meaning – once again, you get to decide what a lot of this means. But I think in those three questions we hit a lot of what Consumer Duty will aim to sort out. And if a client has an adviser or planner who is taking the time to consider and document these on their behalf…then they are fortunate indeed.
We’ll be working to give you lots of usable stuff on Consumer Duty, and if you’re a premium Analyser subscriber (sorry, bit of a punt here) then you’ll get even more, and it may not shock you to know that we’re working on updating Analyser in ways that will help you with the new rules.
Bet you can’t wait for next week. Excited? We are.
- Our quarterly service ratings are live and we need your assessment of platforms and lifecos please. So far it looks like a fair few providers have had a pretty bad Q2 service-wise. If that’s not what you’ve seen – and even it is – please take 2 mins to let us know here.
- I liked this piece in Money Marketing on entry-level roles. It’s my experience that admins often go on to make exceptional product marketing folk, because they know what they’re talking about. I bet many make great planners too in the fullness of time.
- You might like to show any of your clients who still bang on about crypto this article. Eye popping stuff.
- And your music choice…you know who we’ve never had on the Update? Peej, that’s who. And that’s a massive oversight. So many great songs to pick from her extensive collection of godlike genius, but this is the one that leapt to mind. So please pause your week and pay respects to PJ Harvey and A Place Called Hope.
Be nice to Mike and I’ll see you in a couple of weeks.