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Writing Consumer Duty Focused Suitability Reports

By
Team We Complement

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In this week’s newsletter, we’ll discuss how to write consumer duty-focused suitability letters that simplify complex information and support positive outcomes for your customers. We’ll also provide helpful tips and best practices from the We  Complement team. Sharing the knowledge you need to create consumer duty focused suitability letters that make a difference.

What are consumer focused letters?

Consumer focused letters are suitability letters that prioritise the client’s understanding and outcome over compliance requirements. These letters are designed to communicate complex financial advice in a way that is clear and concise to the client. Consumer focused letters should include a summary of the advice provided, the client’s goals and objectives, the risks and benefits associated with the recommended investments, and the reasoning behind the recommendation. Additionally, these letters should address any concerns or questions that the client may have and provide guidance on how to proceed with the recommended investments. Overall, consumer focused letters should prioritise client education and support outcomes that are in line with the client’s financial goals and objectives.

What are the benefits of writing consumer focused letters?

There are several benefits, with the main one being increased customer understanding. By using clear and concise language and linking recommendations back to the client’s objectives, customers will be able to easily understand why the recommended product or service is suitable for them. This will not only increase their confidence in your advice but also lead to better outcomes for the customer.

Another benefit is the reassurance that they will meet regulatory requirements. The Financial Conduct Authority (FCA) place a strong emphasis on ensuring that customers are treated fairly and receive advice that is suitable for their needs. By writing letters that are customer-focused and demonstrate a thorough understanding of the customer’s needs, firms can reduce the risk of regulatory action being taken against them.

Finally, by simplifying suitability letters and making them more engaging, firms can enhance their reputation and build trust with customers. A well-written letter that demonstrates a deep understanding of the customer’s needs and objectives can help to differentiate a firm from its competitors and foster long-term relationships with customers.

When crafting a suitability letter with a consumer duty focus, it’s important to ensure that it contains all the necessary elements to provide a clear and thorough understanding of the recommendation being made. Here’s what should be included:

  1. A clear statement of the client’s goals and priorities.
  2. A summary of their current situation, including existing investments.
  3. Explanation of the reasoning behind the recommendation and how it addresses the client’s needs and objectives, including associated risks.
  4. Advantages and disadvantages of the recommended product, to provide a balanced view.
  5. Explanation of the implications of any focused advice.
  6. If an existing plan is being replaced, a clear comparison of the new plan versus the old plan.
  7. A clear explanation of costs, charges, and potential penalties.
  8. Explanation of the tax implications for the client.
  9. A ‘further details’ section to include specific client information.

At We Complement we incorporate all the above into the templates we use day in day out, and the templates we create for our partner firms to use internally. If you would like us to design a suitability report template that can represent you and your firm and be engaging for your clients or update your existing templates to ensure they’re compliant, contact us online or by calling 01472 728 030.

You may have already read our previous blog explaining why it’s so important for advisers and planners to complete fact-finds in full and have an effective CIP.  As well as protecting your business from successful complaints and a loss of reputation, it could help your business grow by identifying opportunities you would have otherwise missed. You, should, however, adopt a Central Advice Framework. As a fully completed fact-find isn’t the only way to generate referrals and make your business more robust against complaints.

A Central Advice Framework works like a checklist to ensure you collect all the relevant hard and soft facts from the client and consider every option when making a recommendation. Read on to learn five powerful ways this could help enhance your business’s reputation if you’re a multi-adviser practice, and even make it prosper.

  1. Reduces business risk

A Central Advice Framework puts systems in place that verify that you have taken a holistic view of your client’s situation. It ensures you have considered every aspect of their circumstances in the rationale behind your recommendation.

It verifies that you’ve engaged in joined-up thinking and have considered all the options for your client. While this makes any solution you provide safer and less likely to be challenged, it also means your recommendation is more likely to be the right one.

This will mean happier clients, which in turn could mean referrals and new future business.

  1. Ensures you miss nothing

Because the Central Advice Framework is a checklist, you’ll have peace of mind that you have gathered and recorded every relevant hard and soft fact. For example, this might be the client’s capital needs as well as their income needs, or past investment experience and how this has shaped their views on risk.

This information is crucial when it’s passed on to a paraplanner, as they can use it to create a clear and accurate suitability letter that will stand up to inspection.

  1. Ensures you ask the right questions.

This dovetails into the previous point, as the Central Advice Framework checklist makes sure you do not miss important soft facts that would otherwise result in you making the wrong recommendation. This provides you with peace of mind that your recommendation is less likely to be challenged later on. Making it more likely to be approved by your compliance unit.

  1. Improves business efficiency

As the Central Advice Framework requires you to gather all the information needed by your paraplanners, they can produce a clear and compliant suitability letter more quickly. This is because the paraplanners will not need to chase you for missing information or clarification on certain points.

As a result, your compliance team are likely to approve your recommendation more quickly. Your client receives a more efficient service, and you could also have your presentation meeting and write the business sooner.

  1. Assists with compliance

A Central Advice Framework ensures your business meets the 11 FCA core business principles. In particular, makes sure that “customers’ interests” are put first. In addition, it also helps you meet the PROD guidelines, which require you demonstrate that your business has a robust, reliable, and repeatable processes.

Get in touch

In reality, there are 110 things you need to remember to ensure that every client outcome is compliant. By developing a simple checklist to guide you through your client outcome, you can ensure that nothing slips through the net, and it could also improve efficiency.

We believe a financial advice business should have its own bespoke process for the reasons outlined above. That’s why we have prepared many for clients over the years and have extensive experience that puts us ahead of the crowd.

If you would like to learn more about Central Advice Framework, read “A framework for delivering robust, repeatable and reliable financial planning”. A very informative white paper written by our Managing Director Tony Slimmings.

If you would like to discuss how we could use our expertise to help you create a Central Advice Frameworkand relevant documents, please contact us online or by calling 01472 728 030.

Running a financial planning practice can be a lot of fun. But it can also be a lot of late nights, hard work and stress. So, no matter how confident you are in running your business, at some point you will feel stuck, like some pieces of the puzzle just aren’t fitting right, you don’t know which piece is causing the issue, and you don’t have the time or the ability to take a step back and address the issues objectively.

Most people will hang in there and just accept that it’s all part of the job – especially now in a time with constant change and challenges. But, these feelings of being stuck can leave you feeling worried, anxious and irritable. In general, causing your stress levels to hit the roof.

If you’re running a financial planning practice, you probably know this feeling well. You’re running on all cylinders trying to build your business. You have a never ending mental to-do list that grows longer every day. 24 hours is not enough, sleep is for wimps right?

Sound familiar? Is your brain a mush with too many ideas, too many deadlines, and not enough time to fit it all in? You’re certainly not alone. Fortunately, there are steps you can take to ensure you’re caring for yourself and your business at the same time.

Write It Down

One reason you might be overwhelmed is that your brain feels overloaded with information. You might be mentally juggling a long list of tasks that breed to those negative thoughts I mentioned earlier.

Get a piece of paper and make a list of everything that you need to get done. Don’t try to evaluate or organize every task, you can do that later. For now, just get those tasks out of your head and onto paper.

This technique can help to reduce the feeling of overwhelm. Your brain doesn’t have to deal with all the competing tasks and deadlines. You’ve cleared your mental block and have a tangible representation of what’s required.

It’s about the journey not the destination

It’s great to the end goal in sight, maybe that’s increasing revenue, increasing your client base or simply writing more business. But problems arise when you let the goals get in the way. When it comes to sitting down and actually completing tasks, all the roadblocks that could hinder your progress raise their ugly heads and mark their territory. What should have been a simple task, is now weighing you down.

Instead, stop thinking about how your simple task is going to help you write thousands of pounds worth of business, you should focus on the process of the task itself.

Break down the projects and then schedule the time in

Breaking down massive projects is a great way to reduce the overwhelm that builds from massive projects and tight deadlines.

Let’s use your Consumer duty implementation plan and CIP document as examples. The FCA has said they do not view these plans as being set in stone, but rather expect firms to develop them between now and the implementation date.

First, identify milestones for the plan, this could be determining good outcomes, training and identifying relevant data and metrics. Then go one further and think about the steps involved in reaching these milestones. Then, just as you schedule meetings with clients, schedule specific times for these tasks. This will ensure you stay on track with completion and are not overwhelmed at the last minute.

Finally, let’s get real.

The solutions above are all short term fixes that aren’t going to the root of the problem. If you’re feeling consumed by the overwhelm lets identify the issue at the source. It’s about working smarter not harder.

You’re an experienced adviser, but maybe you’ve never ran a financial planning practice. Or you’re running a business but it’s not going right, you’re not getting the clients you expected, your worried about finances, using the right suitability templates, or getting the propositions in place. It’s a struggle navigating the ever increasing complexities of running a financial planning firm, and maybe you need a little extra help, someone to offer paraplanning and coaching support, as well as reassurance and guidance. Maybe you need an outsider to take an objective view of the situation?

If this all sounds very interesting, email or call us on 01472 728 030. Let’s have a chat to see how we can get you back to loving what you do, and get a good night’s sleep to boot.

 

To many people, Six Sigma is ‘something done in manufacturing’. To me having spent six months obtaining my Black Belt and reviewing the processes within my own business, At We Complement we totally disagree.

Although Six Sigma has its roots in the 1980’s it has been applied successfully within the services sector for decades. Banks, Universities, Hospitals, and local governments are some of the diverse places that have benefitted from Six Sigma. There is even a book written in 2003 by Michael L George dedicated to the topic.

It is not only large companies, Six Sigma can be introduced into small businesses to improve processes. Including growing financial planning practices.

Six Sigma ranks among the foremost methodologies for making business processes more effective and efficient. In addition to establishing a culture dedicated to continuous process improvement, Six Sigma offers tools and techniques that reduce variance, eliminate defects and help identify the root causes of errors, allowing organizations to create better products and services for consumers.

People develop expertise in Six Sigma by earning belts at each level of accomplishment. These include White Belts, Yellow Belts, Green Belts, Black Belts, and Master Black Belts.

Does it work? Motorola reported in 2006 that the company had saved $17 billion using Six Sigma.

Experts credit Shewhart with first developing the idea that any part of the process that deviates three sigma from the mean requires improvement. One sigma is one standard deviation.

The Six Sigma methodology calls for bringing operations to a “Six Sigma” level, which essentially means 3.4 defects for every one million opportunities. The goal is to use continuous process improvement and refine processes until they produce stable and predictable results.

Six Sigma is a data-driven methodology that provides tools and techniques to define and evaluate each step of a process. It provides methods to improve efficiencies in a business structure, improve the quality of the process and increase the bottom-line profit.

A key component of a successful Six Sigma implementation is buy-in and support from executives. The methodology does not work as well when the entire organization has not bought in.

Six Sigma uses a DMAIC methodology for improving existing business processes. The letters stand for:

  • Define the problem and the project goals
  • Measure in detail the various aspects of the current process
  • Analyze data to, among other things, find the root defects in a process
  • Improve the process
  • Control how the process is done in the future

If you are creating new processes then the DMADV methodology is used:

  • Define the project goals
  • Measure critical components of the process and the product capabilities
  • Analyze the data and develop various designs for the process, eventually picking the best one
  • Design and test details of the process
  • Verify the design by running simulations and a pilot program, and then handing over the process to the client

The other big methodology is the Five Whys. This is a method that uses questions (typically five) to get to the root cause of a problem. The method is simple: simply state the final problem (the car wouldn’t start, I was late to work again today) and then ask the question “why,” breaking down the issue to its root cause. In these two cases, it might be: because I didn’t maintain the car properly and because I need to leave my house earlier to get to work on time.

Six Sigma in Financial Planning?

All the Six Sigma tools and methodologies serve one purpose: to streamline business processes to produce the best products and services possible with the smallest number of defects. Its adoption by corporations around the globe is an indicator of its remarkable success in today’s business environment.

Whether you are looking to improve your complete advice processes, your annual review process, your CIP, CRP or any element of your business speak to us about how we could use Six Sigma to improve the effectiveness of your financial planning business.

I now know this methodology can be applied into financial planning practices too. Read a case study here.

Tony Slimmings – MD

When you consider your daily activities, each one is a sequence of steps that make up a process. This can be anything from getting up in the morning, making that very first morning coffee, driving to work, or searching for car insurance. Most things involve a process in some form. Process mapping is a technique that allows you to visually represent these processes, tasks, and workflows. While it might not be appealing to map out your personal routines, in a team or work environment, a process map can bring clarity to everyone involved and is likely to enhance the process itself.

By mapping out a process in detail, organisations can identify inefficiencies and bottlenecks that can then be addressed and improved using Six Sigma and other tools. It also shows that organisations can demonstrate robust internal procedures and processes and better define roles and responsibilities Additionally, process mapping can help reduce costs and improve the quality of a service or the advice provided by a firm.


The benefits are numerous. Firstly, process mapping can help organisations identify areas of waste or inefficiency. This can lead to the reallocation or redistribution of resources to areas of greater potential, thus saving time and perhaps reducing costs. Additionally, process mapping can help organisations identify areas of overlap and communication points between teams or departments and highlighting opportunities for improvement or development. By doing so, processes become more efficient and effective.


By mapping, firms can identify areas of greatest risk and then address them accordingly. This can help the reduce the risk of errors or costly mistakes of various kinds. Additionally, process mapping helps internal practices stay up-to-date with regulatory changes and industry trends. This can support maintaining a competitive advantage.

Finally, mapping can help organisations grow and increase customer satisfaction by ensuring that their processes are efficient and effective. By mapping out the process and testing it on staff that don’t work in that area, or with test clients, firms can identify areas of confusion or difficulty for customers and address them accordingly. This can help firms increase customer satisfaction and loyalty, as customers will be more likely to stay loyal to an organisation that is responsive and proactive about their needs. (I didn’t want to make this yet another consumer duty blog but it always creeps in somewhere!)


Making organisational processes more efficient and eliminating unnecessary steps is a no brainer. However, before taking any action, it’s essential to ensure that all team members are in agreement. Process maps are an excellent tool for depicting a process within a team and promoting collaboration and input from team members. By visually displaying all the steps and decision points involved in a process (including who executes them), completing a map provides a clear organisational snapshot. This snapshot can serve as a starting point for the way forward.

Our team is on hand ready to help map your way forward, giving We Complement a call is a great starting point.

 

Thanks to Consumer Duty, our need for efficient and streamlined operations has never been more critical. Financial advisers are constantly seeking tools that not only simplify their workflow but also enhance their overall productivity. One such tool that has gained significant traction in recent years is Intelliflo Office. A comprehensive practice management system designed to meet the unique needs of financial professionals. So it would seem that for many financial advisers, this is the preferred back office product. Perhaps this is no surprise as according to the market statement, Intellifo’s services are used by around 30% of the advi.ce profession.

We are not connected to Intelliflo office in any way and will always select a back office system that is the right one for our clients. We just understand that so many firms are not getting the best out of their Intelliflo office licences. The question that often arises is, “Are you truly leveraging your Intelliflo Office licence to its full potential?”

Unlocking the Features:

Intelliflo Office comes equipped with a plethora of features aimed at simplifying the day-to-day operations of financial advisers. From client management and document storage to task automation and compliance tracking. The platform offers a wide array of tools designed to enhance productivity and efficiency. The key lies in understanding and unlocking these features to their full potential.

Client Management Excellence:

The heart of any successful financial practice is client management. Intelliflo Office provides robust client relationship management (CRM) capabilities, allowing advisers to track interactions. It can also  manage communication, and gain valuable insights into client needs. Exploring the depths of these CRM features can significantly enhance your client relationships and help you provide a personalised experience.

Document Storage and Organisation:

In a world drowning in paperwork, having a secure and organised document management system is invaluable. Intelliflo Office offers document storage and organisation tools that not only help in reducing paperwork but also ensure that important documents are easily accessible. Understanding how to efficiently manage and retrieve documents can save you time and enhance your overall workflow.

Task Automation:

Time is money, especially in the financial services industry. Intelliflo Office allows for task automation, enabling you to streamline repetitive processes and focus on more strategic aspects of your business. By exploring and implementing task automation features, you can free up valuable time, allowing you to concentrate on high-priority tasks and client relationships.

Compliance Tracking and Reporting:

Staying compliant with ever-changing regulations is a non-negotiable aspect of our industry. Intelliflo Office includes tools for compliance tracking and reporting, helping you stay on top of regulatory requirements. Understanding and utilising these features can save you from compliance headaches.

Cash Flow Modelling

Intelliflo has just revealed that their award-winning cashflow modeling and planning capabilities will be seamlessly integrated into their core Intelliflo Office system, eliminating the requirement for additional licensing. This enhancement empowers customers to enhance client service and showcase the potency of their financial advice through real-time, visual cashflow charts and data.

Our Complementary Support:

The Intelliflo Office back office system, utilised by over 30,000 advisers worldwide, empowers clients to manage income reconciliation with providers. It also features a brilliant compliance module designed for those who are directly authorised.

From taking the initial inquiry, through business tracking and then to completion, the software promises to save you time, money and stress.

Our experience at We Complement is that not only are advisers and administrators lacking in confidence in using intelliflo office, but very few advisers use it to its full potential.

Some of the specific issues we’ve come across are,

  • Getting the client review process on the system
  • Setting up the fee models
  • Integrating other systems
  • Creating and adding templates
  • Getting the electronic document function working

At We Complement, we take pride in providing dedicated support to financial advisers. Therefore, ensuring they harness the full potential of Intelliflo. Our experienced team is well-versed in the intricacies of Intelliflo. We stand ready to assist advisers in navigating and optimising their usage. From personalised training sessions to ongoing guidance. We are committed to helping advisers streamline their operations, enhance client relationships, and stay ahead.

In Conclusion

In conclusion, Intelliflo Office is a powerful ally for financial advisers, offering a range of features to streamline operations and boost productivity. However, the true value of this tool lies in your ability to explore, understand, and leverage its features to their full potential. Take the time to delve into the intricacies of Intelliflo Office, attend training sessions, and stay updated on new features.

With We Complement by your side, you can confidently maximise your use of Intelliflo. Thus, empowering you to focus on what matters most – delivering exceptional financial services to your clients. Get in touch today. 

Yes keeping in touch with your clients on a regular basis is a great thing to do, however, as you will no doubt know, the Financial Conduct Authority (FCA) also requires advisers who supply investment advice to do annual planning reviews in a formal way. Specifically, you should “agree with a client whether a periodic assessment of suitability will be performed. If periodic assessment is to be performed it must be at least annually and the continued suitability confirmed in writing”.

These annual planning reviews (which we can help with, more of which anon), are a valuable opportunity to have a really in-depth check-in with your client – and the best ones focus on the person, as well as the products.

So, while it is possible to include everything on one page, at We Complement we believe APRs should become a document of your client’s annual financial planning journey – not just a snapshot.

For example, while obviously you need to include details of all current investments, their performance and any recommendations you would make, a good APR will also appraise your customer’s circumstances – what are they investing for, how they are planning on making it work and any worries they may have.

Clearly, this is considerably more time consuming for an IFA – which is where the We Complement team come in.

We will work with you to develop a document which is personal to each client, while also ensuring it truly represents your brand. We will undertake all necessary research to emphasise the value you have provided during the previous 12 months – and how you will continue to do so in the future.

We can also access all the necessary information on your system, such as products, planning and risk profile, and add these to the APR document, giving an overall review that provides a truly detailed view of your client’s financial year.

We Complement believes that your annual planning reviews are a great opportunity to engage fully with the financial planning needs of your clients. Sending a one page summary just seems to be such a wasted opportunity not to take the chance to engage positively with them.

Once we have all the details we need, we go ahead and prepare the review, and typically produce reports in five to seven working days.

For more information about our annual review offering and complementary offerings, and how they can benefit you and your clients, please get in touch.

So, as we come to the last quarter of 2023, you might be thinking about the next 12 months and what working with outsourced paraplanners might mean for you and your business.

With this in mind we have highlighted five important points regarding how we believe we are the go to support to help Financial Planners deliver high quality bespoke financial planning outcomes for their clients in 2024.

Learn to collaborate with our experts and see them as a partner

While in the past paraplanners, or technical analysts as we call them, have largely been hidden from the client spotlight, they are, in the main, every bit as qualified and experienced as advisers to deliver a great client outcome. Involving a paraplanner in meetings also allows you to concentrate on your rapport while we take notes and are on hand to answer any tricky technical questions the client may have.

Having a paraplanner attend the meeting is all good in theory, but if your meetings are all conducted face to face this could be a logistical nightmare. Many advisers now do the next best thing and record meetings or include our paraplanners virtually by video link, as it can be so beneficial to hear the client in their own words. This gives us a clear mental picture of your client that we can use to develop a detailed summary of their circumstances and why a recommendation is right for them.

Top Tip: Recordings can sometimes be long and time consuming for the listener, so why not just record the last 30 mins of a meeting where you round up the meeting and briefly go back over the key points that have been discussed?

Our team use a wide and varied selection of back-office systems

By taking an impartial view of your administration and processes, we can identify ways to make your back-office systems more efficient and robust against an FCA check. Having a streamlined back-office system could also mean happier clients and potential recommendations that lead to new business.

Outsourced Paraplanners can provide specialist technical advice

Whether it’s for defined benefit (DB) pension transfers or long-term care, outsourced paraplanners typically provide specialist technical advice. If you have an in-house paraplanning team, choosing to also work with an outsourced provider enables you to swiftly access specialist information.

An outsourced paraplanner can also provide specialists who could join complex client meetings. This could improve your chances of securing the business, ensure the suitability report is as robust as possible, and ensure work is produced promptly.

Having a centralised system is essential

As we head into 2024, being able to demonstrate robust, repeatable and reliable processes is more important than ever thanks to consumer duty. It’s as important as being able to show your business is consistently providing excellent outcomes for clients and treating them fairly at all times.

Adopting a centralised retirement proposition (CRP), a centralised investment proposition (CIP) and a centralised advice framework (CAF) could help you do this. Our Managing Director Tony Slimmings has written white papers detailing all of the above.

Outsourcing support reduces staffing issues

As paraplanning is often seen as an entry point into financial advice, your business could struggle with a high turnover of in-house staff moving on to become financial advisers. An outsourced team means you won’t have the stress of recruiting new team members, nor will you need to worry about cases being dealt with when members of the team are off ill or on holiday.

Furthermore, you can always be assured that you will have access to high quality and professional outsourced paraplanners.

For us, report writers are individuals who’re fed client information by the adviser that is subsequently transposed into a standard template. This requires little input from the report writer and does little to influence the outcome. Paraplanners like us at We Complement are technical analysts, and as you can see, using a paraplanner for more than report writing could help you generate more business.

Ok, we are a little biased, but we do believe outsourced paraplanners can add a whole new dimension to your business and your client outcomes. If you would like to discuss any of the above points, or how we might help your business in 2023, contact us here or call on 01472 728 030

Centralised propositions allow you to demonstrate robust, repeatable, and reliable processes. With Consumer Duty fully upon us it is more important than ever that you can evidence consumer value and consistency of service. It’s as vital as being able to show your business is consistently providing good outcomes for clients and treating them fairly at all times.

Adopting a centralised retirement proposition (CRP), a centralised investment proposition (CIP) and a centralised advice framework (CAF) could be key to achieving this.

Read on to discover five ways these centralised systems could provide greater protection against complaints and potentially boost business.

Ensures your business can stand up to scrutiny

Centralised systems allow you to demonstrate to the FCA that you and your company has a robust, reliable, and repeatable process. This could be critical in meeting PROD guidelines and COBS 9.3.3, which requires you to consider all relevant client information before making a recommendation.

A CAF ensures your business meets the 11 FCA core business principles and, in particular, makes sure that you put “customers’ interests” first.

Ensures your recommendations are always appropriate

The FCA knows that clients’ situations differ, and so will check to ensure they have not been “shoehorned” into the same solution – especially where retirement is concerned.

Having centralised systems, such as a CRP, means you can demonstrate

that you’ve collected all the relevant hard and soft facts, recorded them, and considered the client’s individual situation.

With a CIP, any investment or product you recommend will be from a centralised selection that has been assessed and found to be suitable for your clients. This is more likely to result in a good outcome for the client, reducing the chances of complaints or an FCA investigation.

Reduces risk for the business

A centralised and consistent advice framework, such as a CIP, helps eliminate the chance of errors and omissions. This dramatically reduces the risk of a recommendation turning out to be wrong, or not be in the client’s best interests.

As such, complaints against you and your business are far less likely. Furthermore, it will mean happier clients, which could mean referrals and future new business.

Improves business efficiency

Each of the centralised systems require you to gather all the information needed by your paraplanners, allowing them to produce a clear and compliant suitability letter more quickly. This is because they will not need to chase you for missing information or clarification on key points.

Because a CIP removes the need to undertake investment and platform research for every case, your business will be more efficient, providing quicker outcomes for your clients. This could mean you can arrange that all-important presentation meeting sooner.

Allows you to spend more time with clients

This dovetails into the above point of having a more efficient business. Documented centralised propositions allow you to concentrate on delivering what clients really want: good financial planning and a first-class service.

This is likely to result in happier clients who then provide referrals, allowing you to build your business while reducing the potential of complaints.

Get in touch

We have been helping businesses develop and integrate centralised systems for many years, and have tested many for robustness, reliability, and repetition. If you would like to learn more about how we can offer support in establishing centralised systems please visit our website or contact us. You can get in touch online or by calling 01472 728 030.

What is a central investment proposition?

A central investment proposition is a standardised investment approach that allows independent advisers to offer a comprehensive, consistent, and value adding investment solution to all their investment clients. They are a key part of an holistic advice process for all financial planning firms.

It means that instead of conducting whole of market investigations advisers can focus on a range of providers and products within a well-researched Centralised investment proposition (CIP) which is reviewed on a regular basis by an investment committee.

4 out of 5 independent financial advisory firms already have a central investment proposition of some kind. However, probably all of these need to be reviewed in the next few months in line with the impending Consumer Duty requirements.

 

Who benefits from a CIP?

A crucial aspect of a CIP is that it must not just be a good fit for the advisory firm but more importantly for its clients. A good CIP should reflect client segmentation. A good understanding of knowing which client fits into which segment means clients are dealt with efficiently and from a regulatory viewpoint, compliantly.

Flexibility for clients is also a vital consideration, life events can dramatically change a client’s investment requirements. It should also meet the needs of various attitudes to risk and investment time frame windows. An offering of passive and active investments, ethical offerings and different tax options also make a robust client friendly proposition.
Any costs should be transparent.

 

How does a CIP work for an advisory firm?

Some firms have an investment committee that meet regularly to gauge whether their picks are providing what they set out to do. They chose which providers and products to place within their CIP. They also set the parameters of when advisers can go outside of the CIP. An experienced paraplanner, in-house or external, is an ideal person to sit on this committee.

Establishing and running a centralised investment proposition has always been a challenge for smaller to medium independent advisory firms. The introduction of Consumer Duty makes the challenge slightly harder and more accountable.

There should be no blurring of lines between efficiency for a business and what is good for the consumer.

Firms that have investment committees that consistently appraise investment selection, performance and value for money for their clients have real responsibility.

Inhouse research is expensive from a time perspective. It is also pressurised because the aim of achieving positive performance on a value for money basis can be hugely impacted by markets. Any member of an investment committee working in the summer of last year can relate to this.

 

Third party offerings

Investment selection can be delegated to a third party but is important advisers know their responsibilities to the third party and their own clients.

A range of players have entered the market with the aim of providing outsourced investment solutions for advisers and to take away some of the challenges of running a centralised investment proposition.

Managed Portfolio Service (MPS) providers, Discretionary Fund Managers (DFM) and platform providers have all realised the IFA community is a good place to expand their own businesses.

The challenge for businesses moving away from their current self-picking system or to another third-party provider is to ensure any migration does not have a negative impact on their clients. They will also need to ensure that any proposed solution will fit in with the customer journey, segmentation and be flexible enough to adapt.

Due diligence should be comprehensive. There is a real challenge for an adviser to explain why their firm is moving from one third party to another in a short space of time.

Consumer Duty means that most firms are reviewing all aspects of client interaction.

Recently five different third party providers were recently interviewed by an adviser business. Only one of them had a clear plan for how it would operate under Consumer Duty. So, it really is important to look at governance when considering working with any third party provider.

Whether having an in-house selection approach or that of using a third party, the consideration of providers Consumer Duty plans should be a key consideration.

 

Back-office systems

Another consideration when establishing an effective Central Investment Proposition is ensuring the chosen risk profiling tool works in conjunction with CIP offerings. Compatibility of a client’s attitude to risk with a selected product or fund should be in place.

Complacency

Which CIP option an advisory firm takes the main thing to consider is accountability. CIPs should be reviewed on a regular basis, and good record keeping of discussions on the topic made.

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