What a summer so far and what a week; World Cup, Wimbledon and… Consultation Papers 🫠
Yep, in case you haven’t seen, the FCA are doing that thing where they try and ruin your upcoming break (they usually do this at Christmas time, but this time it’s all about inserting themselves in our summer holidays) and hammering us (as compliance consultants) with consultation papers galore. In the last week alone, we have had:
📝 CP26/22: Simplifying the insurance rules📝 CP26/23: Consumer Duty - scope and proportionality 📝 CP26/24: Simplifying Consumer Investment DisclosuresNow, you can see from the titles, that this is all intended to be good news stuff for advisers. It’s all focused on proportionality and simplicity which are the kind of things advice firms have been crying out for, for a long time.
Looking at CP26/24 as an example. The overall aim from the FCA is for “more consumers to feel confident investing by getting clearer information in plain English on products and charges”.
That’s clearly a great aim. Previously some of the disclosure documents were heavily templated by the FCA and therefore could be considered unreadable and one of the consultations is on removing these limitations and allowing more creative licence in how charges are disclosed.
This reminds me of the work we did previously at Verve to bring suitability reports to life, creating
interactive ones that clients could click around in. Cost disclosure maybe doesn’t need to be
that fancy, but having a bit more freedom to test out a few options and do some user testing to see in which format people actually understand what they’re being charged, can only be a good thing.
They are also going to simplify and streamline rules for MiFID, IDD and non-MiFID business as they, quite dryly, note that “the co-existence of three similar but distinct regimes increases complexity”.
Of course, there’s complexity in unpicking complexity, but, it is at least a step in the right direction. Another interesting area is a focus on embedding their expectations that consumers are clearly told about "… any fees they pay on cash held in investment accounts". They are also “codifying” the end of “double dipping” which happens by getting interest from cash and also charging a fee on it.
Overall, they’re not drastically sweeping changes, but more of the theme I wrote about previously of the small, but many, tweaks designed to make the future of advice businesses that bit easier to run. With CP26/23 also effectively removing TCF, there’ll be a lot of short-term changes needed and the hope is that they translate into long-term efficiency gains, for both clients and advisers.
There’ll inevitably be devil in the detail, and so I guess I know what I’ll be reading over a pi
ña colada by the pool. What could possibly go wrong?!
Another jam-packed edition here for you. Our latest NewIn podcast episode, featuring an Australian friend, our first AI release to our Verve members and a round up of the Verve awards (with a few Transformation tickets remaining!)
Everything below is guaranteed to be more interesting reading than 3 x Consultation Papers if I’m honest - you’re welcome 😉
Drink of choice was inspired the
Foundation summer party earlier this week where
Lewis Byford got me
into this, which he enjoys so much he has given it the affectionate nickname of LP Pink 🥂