Jun 21 2017

Firing Line: Caroline Bradley

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Firing Line: Caroline Bradley

Ms Bradley is the group finance and risk director of Tenet Group, but has now taken on the role of group risk and regulatory director at the company. She also runs the company's own professional indemnity insurer, Paragon Insurance, so knows the kind of complaints that come in and has finely tuned instincts over where advisers go wrong.

She said: "It can be a genuine mistake. A lot of funds sound the same. There may be a fund that sounds very similar, and it's been a genuine mistake by a member; sometimes it might be a new member who's not too familiar with the panels and rules, and we're happy to put them on the right track."

Unfortunately, Tenet, along with every other successful firm, has to pick up the pieces of much more serious mistakes made by other adviser firms when they offer bad advice and the investments go wrong, forcing the Financial Services Compensation Scheme – and the rest of the financial advice industry – to pick up the bill.

Ms Bradley said: "We pay more in our FSCS levy than PI premium for the network."

The reason FSCS levies have gone up is because some advisers are trying to game the system, but the FSCS is onto them, according to Ms Bradley.

She said: "A regulated adviser gives advice to set up the Sipp, and they make an introduction to the unregulated company who then sells an unregulated product. The regulated adviser thinks he's off the hook, but he's not off the hook."

This is because, she said, the whole purpose of the regulated advice was to buy the investment.

She said: "The regulated adviser has tried to be cute with the rules and the FSCS has seen beyond that, and that's why they're paying out the claims and that's why the levies have gone up; a lot of unscrupulous people have sold these products and they're paying high commission."

The investments have subsequently turned out to have gone bad. But, she added, the investor is not entirely blameless because the regulated adviser introduced them to the unregulated adviser, so they ask: "what could possibly go wrong", and are dazzled by the promised spectacular returns.

The FCA is currently exploring new ways of funding the FSCS. Ms Bradley said: "There does seem to be a willingness on the FCA's part to share some of the burden with product providers, because the argument is, why should the good advisers pay for the sins of poor advisers who have gone into liquidation?

"We have been suggesting that a product levy is the way to go and that we should charge more for a high-risk product, and if you're buying an unregulated product you wouldn't pay a levy, and that would help the client realise that they don't have FSCS cover, and they might be more wary of an unregulated product."

Sipps are not the only product on the FSCS radar – mortgages are also being used to raise cash. Again, the client goes through a regulated mortgage adviser to raise money through a mortgage, gets introduced by the adviser to an unregulated individual, who organises an unregulated investment for the client. The FSCS is onto this scam too.

For Ms Bradley, her role is to keep an eye on the advisers at Tenet Group, who belong to the network part of the business and therefore whose advice Tenet is responsible for – certainly something to keep the head of risk awake at night if Sesame Bankhall's experience is anything to go by.

She said: "We're trying to drive the right behaviour through our PI policy, so that if they've gone outside the rules, the network says they don't have PI cover. We now get information from all the product providers and check that each month against the panel. If someone goes off panel, we try to catch it and do a post-sale review to see if it's suitable.

"Even though I've been finance director at Tenet, I have been involved in the finance side and I've seen what happens when things go wrong."

One of the big icebergs on the horizon is defined benefit transfers. This is an area of advice that many advisers have become wary of, but has suddenly become more complicated following the impact of the Brexit vote on sterling.

Ms Bradley said: "Our procedures are very, very clear. We always do a pre-sale review, because once you've transferred out of a pension you can never go back into it again. Often it can be the right decision for the client. Pension freedoms made transferring the assets out means they can pass them on to their dependents. 

"It's less likely to be suitable if it's a small pension pot unless they're in debt and they have got high debt refurbishing costs."

Tenet advisers get very few insistent clients and often there are good reasons for a client wanting to transfer. However, for any adviser that really wants to give high risk advice, Ms Bradley said: "We would say they would want to be outside the network."

Melanie Tringham is features editor of Financial Adviser

Caroline Bradley's career highlights

2012 – present

Group finance and risk director and (from July 2017) risk and regulatory director, Tenet Group

2012

Interim director of corporate finance, Lowell Group

1999 – 2012

Finance and risk director, TD Direct Investing

1998  – 1999

Finance director, YorkShare

1996 – 1998

Corporate planning accountant, Yorkshire Building Society