It’s been a week since we launched our first ever white/yellow and grey paper, It’s all about you: Tackling your PS13/1 due diligence requirements’ and it’s fair to say that we’ve been bowled over by the response.
There’s been a lot of tweeting and some press activity which is great but the thing that really cheers us is the positivity around the paper, not to mention the fact that people are actually talking about it. Having actual conversations! We’re assuming that the rather cool cat cartoons were enough of a distraction that everyone momentarily forgot that the whole thing was about regulation. Something for the FCA to think about. That aside, there is a feeling that this is a step forward; helping to simplify at least one aspect of the ever increasing due diligence demands.
We’ve been clear from the off that this is a dialogue and we’re seeking the involvement of platform providers and advisers. We’ve already been in touch with platform providers to ask for their responses to the first set of questions raised in the paper. If you’ve not read it yet (and why not?) the link is conveniently placed for your linking pleasure. Again, we’ve been delighted by the response and a big thanks goes to all those who have taken the time to complete the survey. For those who have not quite got around to it yet, there is still time. It’s very quick and largely pain free, we promise!
While we can’t make generalisations about the provider position without a full set of responses, we do have some sense from the replies we have received so far. And that is that platform service providers are comfortable and confident that they are not at risk of contravening the letter or spirit of the PS13/1 amendments to COBS. While this is positive, it provokes a challenge; a hypothetical putting of money where mouth is! would the platform providers who state this confidence indemnify advisers against any regulatory costs incurred on the basis of recommending their platform? We’ll leave that one with you.
And now to advisers; if you’ve read the paper (and if not then really, the link is right there, see? there, that’s it) you’ll be familiar with the questions that we propose for advisers to ask themselves about their interactions with platform service providers.
Follow the link to the adviser survey and have your say. The more responses we get the greater the validity of the output, and that will benefit all. We’ll be passing a summary of the (anonymised) feedback to the FCA and we’ll post on the site too. Ideally we’d like to revisit this over time, with the same advisers, to see how experience and perceptions change. That’s why we’re asking for an email address. We won’t attribute responses and we promise not to use details for anything naughty; you’re quite capable of deciding for yourself whether or not you might be due a refund of PPI.
In a sense this all comes back to the core of the paper, which is whether you the adviser are satisfied that the platforms with whom you place business or advise on are playing by the FCA’s COBS rules.
PS: 13/1/14 (do you see we did there?) is when we plan to submit feedback to the FCA so we’d love to capture as many of your thoughts as possible by then. Over to you.