Threesixty Services.Ppt


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  • There was some confusion over the question of whether an IFA choosing to operate, for example, solely as a pension adviser could be described as ‘independent’ this seems to have been caused by the FSA using some poor wording of its own and it is clear that such an adviser would be independent provided they used the whole of the market relevant to that specialist field. They would, however, have to make this restriction clear from the outset.Panel – must be drawn from the whole of market and reviewed regularly – whatever that may mean, we review quarterly and I cant see any greater frequency being required
  • The FSA sees commission as wrong. Commission moves from the provider so advisers (and clients) may be confused as to whose interests they represent.Commissions are set by providers – the client is not involved in the negotiation – and may be varied in order to compete for the adviser’s business. The FSA is not against competition but wants to see that competition focused on the client rather than the adviserSo, commission will be abolished for all advice channels except basic advice.Since there is no commission, there can be no initial commission – or factoring as the FSA is now correctly describing it. Nor is it going to be possible for providers to set up factoring arrangements in respect of adviser charge payments they may be facilitating. Logic here is that factoring is another form of competition aimed at the adviser not the clientDisclose…..Disclose…..Note – doesn’t seem to be any minimum service level or maximum ongoing charge being propsed
  • While there is no obligation on a provider to facilitate adviser charging and an adviser cannot use this as the basis for product selection, in practice providers who do not offer it will be disadvantaged, even existing fee based advisers are more likely to use commission offset than true fees so advisers finding their feet in the post-RDR world will certainly look for this facility.Negative charges means, mainly, high initial allocation rates – the FSA is against them because advisers may use them to hide their fees so that they again become a means for providers to compete for the adviser’s business rather than for the benefit of the clientCan’t vary – should be unreasonablyReview re internal bias, FSA is questioning whether internal remuneration structures pressurise advisers into selling rather thansimply providing advice
  • Whatever the extent of the catastrophe for some firms, there will of course be some survivors. There will be some speedy evolution – also known as mutation – and old model firms will change their appearance.
  • Threesixty Services.Ppt

    1. 1. New Model Adviser Conference 2010<br />
    2. 2. differentiation<br />RDR - key issues<br />RDR – where next for OMAs?<br />Spot the difference<br />Look after the Ps<br />Spot the differences again<br />Q&A<br />
    3. 3. implementing the RDR<br />Clarity<br />Remuneration<br />Professionalism<br />Miscellaneous issues<br />
    4. 4. implementing the RDR<br />Clarity<br />?<br />Independent Advice<br />Vs<br />Restricted Advice<br />
    5. 5. implementing the RDR<br />Clarity?<br />Written disclosure – Not mandated<br />AND<br />Oral disclosure – Mandated<br />
    6. 6. implementing the RDR<br />Clarity<br />Packaged Investments<br />Retail Investment Products<br />
    7. 7. implementing the RDR<br />Clarity<br />Retail Investment Products<br />To be ‘Independent’ WOM advisers must:<br /> Consider all RIPs<br /> Understand how they work <br /> Not restrict advice to own OEICS/DIFs<br />
    8. 8. implementing the RDR<br />Clarity<br />Retail Investment Products<br />To be ‘Independent’ WOM advisers:<br /> Can operate in a limited field <br /> Can use a Panel<br /> Can be financed/owned by a provider<br />
    9. 9. implementing the RDR<br />Remuneration<br />No commission for Advice channels (except BA)<br />No ‘factoring’ – new members to existing GPP/protection under ICOB (CP 09/31)<br />Disclose before providing service<br />Disclose after providing service<br />Ongoing charges require ongoing service (except RP and existing)<br />
    10. 10. implementing the RDR<br />Remuneration<br />No obligation on provider to facilitate<br />Can’t select product on basis that provider does offer AC support<br />No negative charges<br />Applies to all advice channels (except BA)<br />Can’t vary between individual clients<br />Review re internal bias<br />
    11. 11. implementing the RDR<br />Professionalism<br />Independent PSB – Now to be FSA (CP 09/31)<br />QCF 4 or equivalent<br />No regrets guarantee – June 2009 (CP 09/31)<br />FSSC Review started August 2009<br />Structured CPD – Learning outcomes (CP 09/31)<br />31st December 2012<br />New advisers<br />
    12. 12. implementing the RDR<br />Timetable<br />Consultation throughout 2010 (16th March CP 09/31) <br />FSA Feedback Statement, incorporating final rules, quarter 1 2010. <br />The final timetable for implementation is likely to require firms to implement changes by 31 December 2012. And now some ‘ifs’ (CP 09/31)<br />
    13. 13. RDR – the impact<br />Proposal<br />Potential market impact- OMAs<br />Increased capital adequacy <br />to £20,000<br />No Impact<br />Three Months fixed expenditure<br />Drive away from new model,<br />Slow down in investment <br />Possible move to network?.<br /> Driver for consolidation<br />Qualification threshold <br />raised to QCF 4<br />Some advisers will not reach this level. <br />Retirement or move to basic advice or introducer<br />New definition of <br />“whole of market”<br />Negligible but may lead<br /> to shift to “restricted advice”<br />Possible reduction in move to wrap.<br />Adviser charging<br />Some move to basic advice/ introducer<br />Encourage move to more secure business models<br />Less movement of products<br />Stronger relationship between firm and client<br />Move away from ‘transactional’ models<br />Abolition of provider Factoring<br />Some move to basic advice and IFA <br />sale of protection contracts under ICOBs.<br />Networks and support providers may offer replacement. <br />Banks may enter market<br />NATIONAL ACCOUNTS BRIEFING 2009<br />
    14. 14.
    15. 15. Profile of the survivors<br />New Old Model Firm<br />Fee based<br />Qualified<br />Advising on wide range of investment vehicles<br />Clear client proposition around initial and ongoing service<br />Using technology<br />Well capitalised<br />New Model Adviser<br />Fee based<br />Qualified<br />Advising on wide range of investment vehicles<br />Clear client proposition around initial and ongoing service<br />Using technology<br />Well capitalised<br />
    16. 16. Similar but not the same<br />
    17. 17. Brand or consumer research<br />
    18. 18. NMAs – Reading the manual!<br />Fee based<br />Genuinely, ‘Service is the product’ – income not dependent on transaction.<br />Qualified<br />Probably beyond ‘Level 4’<br />Advising on wide range of investment vehicles<br />Still operating beyond WOM and providing holistic advice<br />
    19. 19. NMAs – Reading the manual!<br />Clear client proposition around initial and ongoing service<br />Properly segmented and scalable <br />Using technology<br />As appropriate to the proposition for specific clients<br />Well capitalised<br />And well resourced<br />Outsourcing services where appropriate<br />
    20. 20. NMAs – Reading the manual!<br />Working with Professional Firms<br />Professionals recognise professionals<br />Have clear Propositions <br />Internal<br />External <br />Service – deliver to expectations<br />Investment philosophy<br />Robust<br />Consistent amongst advisers<br />
    21. 21. What’s your strapline?<br />Skoda<br />Audi<br />Vorsprung durch Technik<br />“It’s a Skoda, Honest”<br />
    22. 22. Questions?<br />