'It's amazing a person like me can compete with FTSE 100 companies'

Wiltshire, who runs Bradford on Avon-based Wiltshire Wealth, retrained as a financial adviser after a 15-year stint as an actuary taught him he wanted to do something more dynamic and less technical with his life.

He joined the SJP academy five years ago but soon after his training finished he left SJP to set up his own independent firm under the Sense network.

He says he wanted to have a clean slate, not do things "by increments", not feel like there were any conflicts and compromises. "I wanted to do things, as I see it, in the right way."

Wiltshire says his actuarial background feeds into the way he does things. He is an advocate of low-cost passive systematic investing, saying this is sensible for the "vast, vast, vast majority of people".

And despite his firm's size, of about 50-60 clients currently, he spends money on an investment consultant to help him run his investment proposition.

I remember the first time I actually got an email through, it was like a miracle.

He says: "One thing that is absolutely amazing about the profession and the industry, is that a person like me, who has never advised before, can retrain, come into the industry, set up by myself, [and] use this investment consultant that some of the biggest independent advisers also use.

"I've effectively got the same proposition as them and I can compete with them; I can compete with these huge FTSE 100 companies, I take clients off the SJPs, the Chase de Veres, all of these. That's amazing to me, like what other profession can you do that in, that you can come in and you can compete straightaway."

Wiltshire says his actuarial background has helped him understand the more technical aspects of the job in greater detail and consequently has meant he does not feel "that intimidated by any of it".

"There's so much data, there are so many important-sounding people looking and sounding important that, you know, really could have held me back if I didn't have the confidence [to say] hang on a second, I've done all this training, I've worked in the profession before, I know that actually it's fine. You just got to sort of figure it out.

"So I think it's really helped my confidence moving into it. I guess the fact that I am still doing it after five years, it just goes to show that if people who do come from a technical background, and they fancy becoming a financial adviser, they can do it and you don't have to be a super extroverted relationship type person to do it."

Sustainability is 'not straightforward'

Despite his technical knowledge, when it comes to sustainability he says "it's not straightforward".

"The more you look into it the more morally ambiguous it becomes and the more difficult it becomes, and so I'm always really clear with people when we discuss, you know, investment options, that it is an option, it's there for them if they are interested in it.

"Many people are, but there are trade-offs."

Wiltshire says markets are broadly efficient, and the further an investor moves away from a diversified global portfolio, the more inefficient their investments become and the lower their resulting expected returns are going to be. 

He is also sceptical as to whether ESG investments necessarily always have the measurable real-world impact many investors are looking for.

"Selling shares, or not including shares in your portfolio, is not the same as not using a certain company's products. It's far more subtle and nuanced, and very hard to measure," he says.

"I think some people have this impression that by screening out certain companies from their investment portfolio, they will actually be having a real-world impact and I don't think it's always that clear cut."

He says active investment managers have not always been transparent enough about these issues and have potentially overpromised in some instances.

"So it is a really complex area. I do try and explain as best I can all my thoughts on it to clients. But yeah, typically, because I believe that markets are fully efficient, the starting point is a diversified global, systematic portfolio."

When clients do go ahead and invest in ESG, Wiltshire takes a "pragmatic approach where we reflect their value preferences within portfolios, but we just acknowledge it's not perfect."

He does believe the investment industry has a role to play in battling climate change however, but he sees the "real opportunity" in stewardship.

"Being engaged with these huge businesses through shareholders and that sort of thing, I think there's a huge opportunity to improve things.

"And actually the funds that have the most sway in that respect are the big passives – Blackrock, Vanguard – so I think that is undoubtedly one of the opportunities for investors that want to see a positive impact over the long term."

He says it is very difficult to get information on ESG currently so he welcomes the Financial Conduct Authority's plans for fund labels. "More clarity certainly would be really helpful."

Burden of responsibility

Wiltshire set up his business from scratch, with no clients or pre-existing relationships. 

He now has just shy of 60 clients, working with both lawyers and accountants on possible referrals, but he says his main source of clients when he started out was the internet.

"Having an online presence now is so important. The first thing people do is they google you, just to check you exist.

"And the standard of websites across the professional industry is so bad. It's just pages and pages of text about, you know, how clever they are, the wonderful system they have to beat the market with, and you know, it just doesn't speak to the people that are reading it."

He says he developed a very cheap and easy website with a local developer and started to get inquiries through.

"I remember the first time I actually got an email through, it was like a miracle. I couldn't believe that somebody had found it."

Wiltshire has ambitions to get to about 80 clients. He says being a small local firm gives him the edge over larger ones a lot of the time, as it allows him to keep it personal and focus on his relationships more.

He says service levels are what differentiate the good advisers from the mediocre.

He adds: "I heard the other day there's one adviser saying that he has 500 clients, I mean, I just don't know how that's possible. I think studies are saying the human mind can only handle 100 relationships or thereabout. So, for me, I think probably 80 would be my maximum."

I worry that some firms could potentially use [the consumer duty] in order to weaponise it and be obstructive and protect their books.

Most of Wiltshire Wealth's clients are local to the Bristol/Bath area. They range from 28-years-old all the way to 82, but have what Wiltshire calls "standard advice needs".

He runs his firm by himself and outsources administration and paraplanning as well as compliance, which Sense handles for him.

He says the thought of hiring someone terrifies him. "It's not just like adding another team member to a floor of hundreds or whatever, it's a really big decision.

"And for me at the moment my lifestyle is great. I walk into my little office, it's me, I'm not worried about anyone else. If I want to pop out for coffee I can, if I want to pop up to London I can, and it would definitely change that if I had someone else to worry about as well."

Wiltshire charges fixed fees for the financial planning, and a percentage for the assets invested, mainly in recognition that higher amounts do not only bring more work and carry greater liability, they also carry much greater responsibility, he says.

"The responsibility of managing someone's life savings is huge. I mean, personally, it weighs on me a lot. I find it very, very hard. I've got a young family, I find it very hard to shut off from work all the time. And the ones that keep me awake at night are typically the bigger amounts.

"That has to be recognised I think in the fees that you charge."

Consumer duty 'weaponised'

Wiltshire Wealth was only a couple of years into trading when the industry was hit with the next big regulatory change: the consumer duty.

Although his compliance is carried out by his network, and he has not had to deal with the regulator directly, he is nevertheless sceptical about the new rules, predominantly because they are "inexplicit".

"My worry is that everyone will just say, well, actually, we are providing value, isn't that wonderful. And nothing will change."

But his bigger concern is that the "consumer duty could be weaponised", for instance as "an excuse for not providing information or interfering in the adviser-client relationship."

He explains: "For example...one of the biggest problems that advisers face is just getting information from providers on their clients.

"And so we have to send off letters of authority and that sort of thing. And there are definitely instances that I've come across, I know other advisers do, where firms are obstructive, you know, it's almost part of their process to slow up the process for providing that information.

"Another thing on, say, business being transferred away from one provider to another provider, I've had instances before where before a provider would allow it, they send out a pretty comprehensive questionnaire to clients way over and above what the regulation requires.

"A questionnaire to the client saying 'are you sure this is right, can you explain to us exactly what the adviser is recommending, what are the charges, what are the funds', you know, and I just feel like that's overreach.

"While on the face of it consumer duty sounds like it has the potential to improve things, I worry, because it's unclear I think in places that, you know, some firms could potentially use that in order to weaponise it and be obstructive and protect their books."

carmen.reichman@ft.com