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The FSA’s interim report on the retail distribution review has shed further light on the eventual outcome and the impact it is likely to have on advisers' businesses.
While many advisers will understandably be adopting a wait and see approach, the greater clarity we now have means there are steps that advisers can take to prepare themselves for the new post-RDR world.
The interim report suggested that there will be a standard equivalent to the Qualifications and Curriculum Authority Level 4, for those that provide 'advice'.
This is equivalent to the Chartered Insurance Institutes’s Diploma in Financial Planning - or in old money, not dissimilar to the old AFPC level although there might be a higher level set for those that specialise in certain fields.
However, there may be the opportunity for existing experienced advisers to demonstrate the requisite minimum levels of competence and knowledge through an 'on the job' assessment, as an alternative to examinations. This would not be an old-fashioned role-play or observation, so if this happens expect a rigorous assessment to be undertaken.
But let us return to the minimum standard being diploma level. Many are already on the road to gaining this standard; but what if you have not started yet, what should be your first steps?
Step one Obtain a copy of your learning statement from the CII. This will show you which CII examinations you have passed and the credits for each.
Step two Review your learning statement and ensure all the examinations you have passed are recorded. It will automatically contain CII examinations, but you may also hold qualifications of other bodies. The obvious example being those that hold an IFS examination, such as CeMAP, CeFA or CeLM.
Step three If your statement does not show all examinations, you will need to follow the accreditation of prior learning process. This ensures the CII recognises other exams you hold and apply an appropriate number of credits to your total. Details are available from the CII website.
Step four Once you have established the total number of credits you hold, you can determine how many credits are needed to attain the Diploma in Financial Planning - this is 140 credits with a minimum of 80 at Diploma level.
Step five You then need to decide which examinations will help you achieve the next designation level. However, there is no black and white answer to this question. You need to look at the examinations and their syllabus and do a mini-training analysis to determine what exams you need to take and what you need to do in the future. Remember that you will stand a greater chance of passing an examination where it is linked to an activity you are regularly involved in.
Whatever your route, you will need to consider the time commitment needed to give yourself the best chance of success. So planning how and when you will study over the next year or so will provide you with a solid base for achieving success.
The proposals around remuneration indicate the removal of the product provider determining the amount of remuneration an adviser gets for recommending a product. However, advisers will still be able to be paid through the product, and the interim paper states: "We are also not seeking to end the practice of 'factoring' whereby the provider advances payments to the adviser and recovers the cost from the customer out of regular charges over the duration of the product - a traditional front-end commission arrangement - so long as the product provider has played no part in determining how much remuneration will be paid."
So what might this mean? The start point is, do you currently determine the level of remuneration that you take? So if for example, you currently charge 3 per cent initial plus 0.5 per cent renewal then this can continue, with you informing the provider to account for this within the product charges. Or do you take whatever is available within the product recommended? If the latter, this option will disappear under what is being considered. You can still take your remuneration from the product – but you decide the level through discussion with your client, not the provider.
To prepare for this, you need to understand how much you might wish to be remunerated for the service you provide. To calculate this, you need to consider two factors. The first is to truly understand the cost of delivering the services you provide. The second is to consider what value your clients place on these services and, alongside this, how much they might be willing to be 'charged'.
The reason these will become important can be linked to another comment within the interim report: "In a market where shopping around by consumers is limited, there may need to be a mechanism for ensuring that charges set for advice are fair." Any charging structure that can be linked to such things as cost of delivery and customer value have a far greater chance of passing any potential 'are your charges fair' test.
The above scenarios have been based on the assumption that many existing advisers will continue to be categorised as 'advisers’' rather than 'sales' people. For many multi adviser firms, another key consideration is what your clients actually want from you - not just what it is you provide for them. A robust client segmentation exercise, whereby you determine those clients that truly value advice, will help business owners understand if the ‘advice’ model is the best overall base for their business.
Such an exercise might actually identify many clients where the 'sales' scenario - and this could be a 'guided sales service' - is the preferred relationship they want with your firm. The FSA’s RDR interim report recognises: "There may be many consumers who are currently already taking advice and who are saving, who may want to use sales services from time to time to make additional product purchases."
In addition, there may be some existing advisers who do not wish to move up to the proposed new minimum professional standards and/or go through any on the job assessment that might be created - but who want to stay doing what they enjoy doing.
So, an exercise to determine the best model for your business is also worthwhile, even at this early stage of the ongoing discussions around RDR.
Despite the fact that there are some areas where advisers will be calling for much more progress – such as the inclusion of a 15-year 'long-stop' time limit on complaints - the RDR interim report shows that the FSA has listened to the compelling arguments put forward by Aifa and Sesame, after years of lobbying on behalf of the advice profession. If the regulator maintains the direction that it currently appears to be adopting, then this new world could deliver greater clarity for consumers and, as a result, an environment in which professional financial advice can prosper.
But if we were to remove RDR from the landscape for a moment, many of the points discussed here are already being progressed by adviser practices. What is driving this is a desire to achieve higher professional standards; undertake client bank segmentation exercises; and a move to both understand what clients truly value and also what it costs to deliver the services. All of these elements are putting these adviser firms in a stronger, more profitable position to not only survive but also prosper - no matter what the future holds.
Paul Dawson is Head of Sesame Learning
Location: Nationwide
Salary: Remuneration: commission £120,000 + (uncapped).
Location: Milton Keynes
Salary: £40000 - £60000 per annum + Excellent benefits + Bonus