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FSA advises advisers on advising

A recent piece of Financial Services Authority work on the quality of advice was designed to help firms improve their practice and is relevant to the all-pervading topic of Treating Customers Fairly. The FSA describes this as one of the largest pieces of thematic work it has undertaken, with the objective of providing firms advising consumers on financial products with help on how to improve their advice processes and cut the risk of mis-selling.

The findings concern advice on investment products but are also relevant to mortgage firms, reinforcing earlier work in the mortgage sector combined with a major shift in the stress that is given to TCF as the driving force behind ensuring quality of advice is consistently high. In fact, the Quality advice cluster report, which gives detailed findings, case studies and recommendations, is sub-titled ‘Considerations for treating customers fairly’.

Another publication arising from this investigation is the factsheet, Improving the quality of your financial advice process, and it contains useful information that together with findings of the 2005 mortgage-specific investigation, provides an excellent basis from which firms can look at their quality of advice systems and implement improvements.

The information is given under five headings – the quality of advisers, assessing customer needs, recommendations and research, communication and suitability letters and systems and controls. Firms are reminded that their recruitment processes should be searching enough to ensure they recruit the right staff. Training and competence regimes must identify and address gaps in advisers’ knowledge and skill, and their ability to apply these in the workplace.

Follow-up and review are essential and the good practice example suggests the completion of a training needs analysis every year for every adviser, with regular meetings including reviews of advice given.

On the subject of assessing customers’ needs, we are reminded that customers must understand the areas on which they are receiving advice and that their individual needs and objectives must be sought. Risk, affordability and the effect of future changes in their financial circumstances must also be discussed.

Regarding the recording of recommendations and research and presenting this to clients, no suitability letter is stipulated as there is with investment products. But there can be few mortgage firms that still believe such a document is unnecessary.

A comprehensive letter setting out the client’s circumstances and needs and the adviser’s recommendations is key to proving quality advice is being given. It can provide the basis for internal case monitoring, generate valuable management information and act as proof of advice quality.

The factsheet suggests that clear and plain language is used, with the use of bold text to emphasise key risks and changes associated with recommendations. Letters should be individually tailored to customers and there should be a clear explanation of how recommendations meet the customer’s circumstances and needs.

The factsheet goes on to remind firms about having adequate systems and controls in place with regard to the collating and use of management information to ensure advisers follow a good quality advice process. Systems should include regular file reviews and meetings with advisers, monitoring their progress and the quality of their advice to customers.

The Quality advice cluster report goes into greater depth on these points and senior personnel in mortgage firms who have TCF and compliance responsibilities would do well to understand and apply the examples of good practice cited at the end of the report, grouped under five headings – TCF, quality of advisers, assessment of customer needs, communication and corporate culture.

TCF has a high profile in this FSA work and we must sit up and take notice. High quality advice to clients is a major factor in delivering the FSA’s statutory objective of consumer protection – that’s why mortgage advice and sales are regulated. Following good practice on the recruitment and ongoing training and competence of advisers, making, communicating and recording suitable product recommendations and keeping control of the advice process safeguards a firm’s core relationship with its clients and should ensure their fair treatment.


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