The missing link between advice suitability and appropriateness of product in meeting client needs was delivered for retail investment advice firms with the introduction of Product Governance and distribution rules i.e. PROD 3.3 in particular.
One of the biggest risks we see Retail Intermediary Advisers (RIAs) make is confusing compliance and business risk. For example, recommending a product that is deemed suitable to meet current client needs doesn’t make it a good risk when viewed from a business legacy viewpoint i.e. client circumstances change, their perceptions change thus their trust and informed consent is at risk if they are not serviced correctly and thus lost trust and complaints become a business risk via fines and damaged reputation or worse.
The FCA’s latest Platform ‘probe’ paper left many wondering if it really was worth the wait. No imminent platform price war is evident, yet this is another steppingstone in this new age of high regulatory accountability the industry now finds itself.