In challenging times dealing with retail client enquiries and concerns can be all consuming. But we have to remember we are still obligated to be compliant and treat all our customers fairly. The FCA are also trying to be as flexible as possible, as they know firms are facing uncharted waters and in the main are fully aware of their obligations. The latest Dear CEO letter is obviously designed to respond to the calls they have had and follows discussions with trade bodies to introduce some temporary measures which will allow firms to be responsive to clients, whom they are quite rightly focusing their attention upon.
The four key measures
- Client Identity verification – introduces more flexibility about how this can be achieved at this time of limited/no physical travel allowed
- Best Execution – extension to the permitted publishing time for RTS 27 and RTS 28 reports from 1 April 2020 to 30 June 2020
- 10% depreciation notification – until 1 October firms can now issue just one notification in the current reporting period and subsequently issue updates and via other media including website and other public channels AND can cease 10% depreciation reports for any professional clients
- Financial resilience – firms can use Government schemes to help with debts as they fall due, but any loans cannot be used to meet capital adequacy requirements
The letter also includes some clarity on policy implementation on “investment pathways” and “platform switching provisions” and confirmation that their statement on pension transfer advice and contingent charging will be delayed as well as follow up work on the suitability of advice on retirement income.
All designed, we believe, to allow you more time with clients.
Letter in full LINK HERE