"We have moved to an era of outcome-based regulation and as such providers and advisers need to take what they believe are the necessary steps to evidence good customer outcomes and fair value. This means doing a thorough gap analysis of the products and services you offer, assessing your client communications and creating a customer centric culture within your business."
Stuart Wilson, chair of later life advice network Air Club, said his company had already found that some later life advisers were unprepared for the incoming step change.
"As the FCA’s review of progress suggests, this is also true for the broader industry as a whole," he noted.
"The deadline for firms to make the necessary changes is fast approaching, so they must act now to ensure they are providing the best consumer outcomes under the new rules.
“Prioritising, making the changes needed and working with other firms should be the focus."
No firm will ever ‘be there’
While many advice firms are now confident they have done enough to meet the FCA’s requirements, some have suggested the guidance - being so open for interpretation - means it could be impossible for any firm to truly meet all that’s expected of them.
Philip Milton, who heads up a Devon-based IFA, told FTAdviser: “We are confident that we are ‘there’ already though with such subjective commentary within the guidance, one conclusion is that no firm will ever ‘be there’.
“The variations in regard to the quality of service delivery will be massive between one firm and another and their interpretation – or perhaps ultimately it will be the regulator’s disciplinary intervention.”
Milton’s fear is that the worst firms in the advice sector will continue to operate, whereas the “law-abiding and soft targets” will, he said, no doubt be the ones worrying about not quite meeting the expectations.
Transactional vs relationship-based businesses
The FCA is yet to take a closer look at smaller firms and their plans to implement the consumer duty, but today the FCA did say it will soon be sending out surveys and targeting smaller firms.
Perspective Planning co-founder, Phil Billingham’s main concern is that small firms with well-established client banks are going to struggle implementing the duty due to the fluidity of their client relationships.
“It’s going to be another challenge to adapt something designed for big firms into a smaller environment,” said Billingham.
