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.
Terminology is everything we hear, as the financial services industry seems to enjoy loading up on acronyms and jargon for simple processes. Just think of AER, CREST, Dematerialisation, Dirty price, FRNS, HICP – I could go on, so since the RDR (another one) we have been called to the transparency table. So where pricing and charges are concerned, for example, we have a need for clear and unambiguous charging delivered in simple terms.
‘The luddites destroy the robots’ may make an attention grabbing headline, yet with all the hype around job losses caused by machine learning and Artificial Intelligence (AI) we need to gain some perspective on where we’re at and where we’re heading.
When Starbucks closes 8000 stores across the USA, you know there’s a problem. It was reported that due to staff’s unconscious racial bias two men were asked to leave and then arrested for ‘loitering’ in a Starbucks café when all they wanted was to buy a cup.
During our tour of the UK last year promoting our RegTech platform Model Office, we made it clear that those firms employing the poorly named Robo-Advice solutions really needed to employ research and due diligence on the technology before employing it within their business proposition.
‘We strongly encourage firms and senior management to continue to focus on their conduct and culture and to ensure that good practice becomes embedded throughout their firm' The FCA 5 Conduct Questions April 2018.
The FCA complaints data can read like the opening credits of a disaster movie: LIBOR rate rigging, Long term Care, Payment Protection Insurance miss-selling, product and fund churning, (are you already switching off yet), this results in an industry tarred with a brush that has seemingly painted graffiti all over the Treating Customer Fairly (TCF) principles.
MO® represents an industry first in many ways. Not only is MO® a standalone Artificial Intelligence driven compliance chat bot, but she also offers 24/7 service and her knowledge base is programmed with the very latest from the FCA handbook, their papers plus other directives such as MiFID II, AML 4, SM&CR and the GDPR. Essentially, MO® is now empowered to perform a regulatory audit.