Equally, it might be useful to think about grouping clients into segments in a more robust and commercial manner. For example, grouping clients together based on their responsible investment preference can be used as an input into this process. It can help you identify and map where the responsible investment opportunity lies across your clients whilst also helping assess the value provided across different offerings. The key is clearly defining and differentiating your different products and services.
The new and the old
So there are new requirements to think about as well as strengthening existing rules and guidance. With the FCA shifting their approach to regulation, the litmus test for advisers is proving that you treat your clients ‘well’.
As we build momentum to the final rules and guidance, it’d make sense implementing procedures to regularly review and document your different processes, if you haven’t already - starting from the way you communicate with your clients, to your investment proposition and everything else in between.
April 2023 may seem like a long way off but if the last decade is anything to go by, the regulatory clock will continue to tick faster and faster.
Read the research to get closer to what advisers are saying about the new Consumer Duty.
