With all this creativity in play, when we were asked into the FCA to ‘kick the tires’ around the sandbox, we thought that the regulator should walk its talk and create a digital diagnostic platform that allows firms to see if they are hitting the regulatory bases and also assess how they are competing in a highly competitive market. ‘Good idea’ said the FCA, ‘But’ (there’s always a but) ‘we can’t be seen to be prescriptive’.
So with Model Office - MO already in production as a business development diagnostic and the fact that managing regulatory risk is a bit like hurdling in the dark, we decided to calibrate the FCA COBs suitability rules, KYC, TCF and MiFID appropriateness tests into MO’s platform, not forgetting key risks such as BREXIT.
Not only this, we also decided to review all the relevant FCA suitability focused final guidance, discussion, occasional and market studies and their good outcomes into MO’s algorithm for its steers to help improve scores.
So we now have a platform that uses Engage Insights 5 year market research on benchmarking professional firm performance against our 5 keys and the FCA suitability directives and relevant papers they produce factored into MO’s algorithm.
All this creates prescriptive outputs using gamification as an enabler tool with performance dials, radar charts and strategic plans to help firms make sense of their professional development journey against a continued backdrop of regulatory risk, consumer mistrust and increasing competition.
Some of the papers we have assessed and incorporated are below:
|
Regulatory Paper |
|
FCA Business plan 2016/17 |
|
FS 16/10 Smart Consumer Communications |
|
FR 16/3 HMT & FCA Financial Advice Market Review |
|
MS 15/2.2 Asset Management Market Study |
|
TR16/1 Assessing suitability, research & due diligence of products & services |
|
TR 15/12 Wealth Manager firms & private banks suitability of investment portfolios |
|
TR14/21 Retail investment Advice, Adviser charging & services |
|
TR14/10 Distribution of Retail Investments: purchasing investments without personal recommendation or with simplified advice |
|
CP 16/19 Markets in Financial Instruments Directive II Implementation |
|
FG 16/5 Guidance for firms outsourcing to the ‘cloud’ & other third party IT resources |
|
FG 15/4 Social media & customer communications |
|
FG 15/10 Risks to customers from performance management at firms |
|
FG 12/16 Assessing suitability: Replacement business and Centralised Investment propositions |
|
FG 11/05 Assessing suitability: Establishing the risk a customer is willing and able to take and making a suitable investment selection |
Please click the below logo link to the platform and learn more about MO today..
