FCA: Guidance will help identify ‘implicit’ advice

He said: “All the customer needs to understand is the service they are getting and the limitations that go with that. So if a customer just wants to talk to the adviser about using up the Isa allowance for that year, this would be focused advice.

“The IFA might look at the whole of the market for the client, but because it is just one thing, an Isa, it is limited, focused advice. They are not exploring all the client’s other needs, such as their pension or protection.”

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The same applied to decision trees, Mr Geale added, pointing to section three of the paper which explained websites can deliver generic advice such as helping someone get a range of options to consider, while others can lead them to a single product or list of products, which would constitute a recommendation and therefore be regulated advice.

Mr Brown added: “It is reasonable for a firm to create a decision tree, and it could be created to provide advice, but it is up to the firm to decide where that is reasonably constituting specific advice that leads to a personal recommendation, or not.”