An interview with Santa? No he’s busy we asked our Editor instead!

 In this Q&A session, we dive into a topic that affects every financial services firm: Training & Competence (T&C). And since it’s that time of year, we’re asking the question: Is your T&C scheme on the ‘Naughty or Nice List’?

 To help us explore this, we have a true industry veteran, Jeff Abbott. With over 30 years of experience dealing with T&C regulations, Jeff is regarded as a ‘go-to’ expert for resolving interpretation and application issues. Jeff has published a helpful list of desirable and undesirable T&C practices on his T-CNews publication, and we thought it would be beneficial to discuss these with Jeff to support firms with their T&C progression in 2026.

Jeff’s background includes a successful tenure as a Senior Manager within mainstream financial services. Since 2009, he has led 2be Development Consultancy, which specialises in the ‘people aspects’ of regulation – specifically focusing on staff competence and behavioural standards across the UK financial services sector.

Jeff’s real passion is helping people become better at what they do, so who better to guide us through spotting those poor T&C practices and charting a course toward genuine competence and success?

Jeff, can you give us an overview of your T&C ‘Naughty & Nice List’ and why you put this together?

 

Jeff Abbott (JA): The background to those two lists is that at the bottom end, we’ve got what I would call the dismissive culture – the ‘Naughty List’. At the top end, we’ve got the advocacy culture, which obviously contains all the best practices.

The context to this is that in between those two extremes, there are three other lists that help you understand exactly where your firm is currently positioned. I compiled these lists based on all the work I’ve done over the years with companies, specifically working with T&C, and being able to identify and differentiate where companies sit.

The interesting thing is that when you put that full list in front of people and ask them where they would like to be, the level of agreement pointing towards the advocacy culture is incredibly strong There’s a common desire to reach that top level, but companies are spread right the way through this spectrum, with many of them still having practices in the bottom end – the ‘Naughty List’, or the dismissive culture.

As a matter of interest, the full spectrum runs through: Dismissive (the ‘Naughty List’), then Minimalistic, then Acceptance, and finally, we get to Advocacy (the ‘Nice List’). That’s the background to where it all came from.

PRACTICES THAT ARE USED THAT SHOULD BE STOPPED AND ACTIVELY DISCOURAGED:

 

1. T&C is regarded as an unhelpful layer of bureaucracy
2. We associate T&C with form filling
3. Our Compliance department is referred to as the business prevention unit
4. We try to get T&C activities completed to allow time to spend on our real jobs
5. We associate T&C with form filling
6. We exploit T&C procedures to get away with doing the minimum possible
7. We use a lot of ‘sheep dipping’ when training people
8. People only try to improve when they are told that they need to
9. Our supervisors give no real thought as to why records need to be kept
10. Training is perceived as an expense
11. Supervisors record the minimum possible details on any form they complete
12. The preferred budget to support T&C is zero
13. New entrants are ‘processed’ through training in the shortest possible timescale
14. Supervisors are there to check up as opposed to coach and develop people
15. Poor business results are often blamed on poor quality of training
16. Compliance is there to check and tell us what we have done wrong – we are guiltyuntil proven innocent

 

THE MOST COMMON DESIRED PRACTICES:

 

1. T&C is engrained throughout our business as best practice
2. Our focus is on competence and development throughout the business
3. People are treated as individuals and this is reflected in the approaches we take
4. Supervisors are required and called upon to use their judgement to resolve T&C issues
5. Users are regularly consulted in improvement initiatives undertaken
6. Senior Managers understand their responsibilities under T&C and accept them
7. Compliance is often consulted and their opinions are valued
8. Our supervisors are highly skilled coaches, trainers, assessors and motivators
9. The management information and training needs analyses help our business to operate effectively
10. We recognise mistakes are learning opportunities
11. We have no mandatory activities or events that must be completed on a regular basis
12. Training is regarded as a valuable investment

When people look at this list, Jeff, you’d hope that all firms have got a desire to be on the ‘Nice List’, but what would you say is the overarching reason as to why firms struggle to change some of their less desirable practices?

 

JA: I suppose in a way, it depends on the company set-up. If we go back to: where would you like to be? Then a lot of it is common sense. Are our people competent? Are our managers doing a great job? Have we got management information that’s telling us what’s going on? That’s what we want to be able to do.

But you often find a conflict that exists within the company which prevents them sometimes from getting to that point. I mean, one of the issues is within the company culture. There’s a cultural tool that’s been around for years. It was designed by two guys, Cameron and Quinn, and it’s called the Competing Values Cultural Assessment.

And it says that companies fit within these four quadrants that describe their culture. Two of those quadrants – one is to do with working together or the collaboration quadrant. The other one is the control quadrant, which is doing things right. Often, what you get within a firm is the conflict between working together and ensuring that everything is done and the I’s are dotted and the T’s are crossed. And so, sometimes, you find that where the business wants to own and take control of its T&C, for instance,

it’s constrained because T&C is actually designed outside the business through another department or Compliance that have different drivers. Therefore, the ownership of the T&C doesn’t take its purest form, which is a business enabler; T&C starts to be bolted onto the business.

I’ll give you a classic example of a sign of this: If we think about T&C and its relationship to a fit and proper assessment, so many companies still rely on HR to perform a fit and proper assessment, failing to use the T&C evidence that has been designed and created in the business, because they don’t regard it as part and parcel of the same thing. It’s just competing forces within a company that stop it happening.

 

Points one and three of your ‘Naughty List’ practices – ‘T&C is regarded as an unhelpful layer of bureaucracy’ and the ‘Compliance Department is seen as the business prevention unit’ – can you unpack what you mean by these, Jeff?

 

JA: Well, I think when you use the term ‘business prevention unit’, it gives a clue to the answer, because I’ve not come across a business that’s designed a T&C scheme for itself that’s regarded as: ‘this will help us prevent doing business’. It tends to mean that the T&C scheme has been designed somewhere by someone else and then introduced to the business that then has to operate with it.

When i’m designing or writing a T&C scheme, which I’ve done quite a few over the years the important thing to me is to engage the business and get them to work on it. To say: ‘Right, this is what we do. This is what we did without T&C, and this is what we’d like to do in the future. How would that work?’ Rather than coming in and telling them: ‘No, you can’t do it this way. You’ve got to do it this way to comply with this, that, and the other.’Whereas, in retrospect, you can look at it and say, well, you can actually use your existing processes and procedures to satisfy yourself that everything’s been done. When you try to get a business to change its tried-and-tested and trusted methodologies, it turns around and says: ‘This feels foreign. This feels strange. We don’t want to do it. What are you trying to do? Stop us doing business?’ That is where your ‘business prevention unit’ comes in.

 

Firms are really reliant on the competence of their people more than ever, aren’t they, Jeff? Especially when we take into account the FCA’s increasing focus on financial crime, Consumer Duty, and vulnerable customers. T&C is such an enabler of the business to deliver against these, but is it taken seriously by all firms and, if not, what needs to drive it – is it a top-level executive mindset change that’s required?

 JA: Actually, that’s a good question because it does bring to light some of the changes that happened a little while ago. Years ago, when T&C was first introduced – T&C within the sourcebook fitted within the business standards of the then FSA handbook – and basically, to try and change things and lift T&C up the agenda, there were a couple of changes that were introduced.

Essentially what happened is the former T&C rule book was changed; it removed the five T&C commitments, which were the aspirational statements.nYou know your employees are competent, they remain competent, they’re appropriately supervised, their competence is reviewed, and the level of competence is appropriate for the business.

What came in its place was what we now know as the competent employees’ rule, and that applies to everybody. But the other thing that happened and often gets overlooked is the T&C sourcebook was moved into the high-level standards of the rule book as a clear signal to senior management that T&C is important, and that you can’t underestimate the value of having competent people.

The important thing is that the company themselves has a huge amount of discretion to decide what competence looks like, and how they go about measuring it. And this is where we get differences of approaches, but at the end of the day, if you want to achieve these good consumer outcomes, it’s all about making sure your people are competent to do the job – and that’s going to help tremendously with getting those outcomes.

Is discretion and the different ways firms decide what competence looks like problematic, Jeff? Should the regulator be more prescriptive?

 

JA: That question raises some interesting points. Again, years ago the then regulator tried to be quite prescriptive – the PIA, in those days, almost described the inputs rather than the outputs that they wanted. They were very focused on telling people what they needed to do. Now, I accept the fact that giving people guidance to understand what the regulator’s requirements are is very helpful. And, again, in going through what’s happened over the years, what was then the Financial Services Skills Council got together a group of industry practitioners and put together quite an extensive document on good practice when it came to T&C. Now, whilst things have moved on, that document still adds valuable guidance as to what people could and should do for their T&C.

But the regulator’s been very clever because when you actually look into the rules – and again, this is something that a T&C person needs to be aware of – when you look at the guidance within the Conduct Rules for a senior manager, and you also look in the Decision Procedure and Penalties manual (DEPP), which is another part of the handbook. The same paragraph appears, and basically to sum up, it’s to do with the fact the senior manager must have policies and procedures in place to review the performance and competence of every member of staff. They’re basically saying you’ve got to do this.

Now, the significance of the DEPP is that that’s the regulator’s interpretation of what are reasonable steps. So, they’re basically telling you that we as a regulator expect you as a senior manager to take reasonable steps and be able to demonstrate to us that you’ve taken reasonable steps to do what we’ve asked.

And we’re not telling you exactly what a T&C scheme should look like or how you go about training, but you need to be able to articulate how you’ve approached that in your business. But it all goes down to the same fundamentals that say: ‘what exactly is competence?’ Now I look at competence as performing to agreed standards on a regular and proven basis. So, we’ve got the standards, you do it because once is not enough, and we need your evidence. So, if you follow that same example throughout your business, because, don’t forget, the regulator says the competent employee rule applies to everybody, then they also say we think it’s quite a good idea that even if you have people that are not subject to T&C, you still have a T&C scheme for them. So, this is telling us what they expect, and to have a sort of ‘light-touch’ approach that starts to leave gaps, could lead to questions being asked about the approach that’s been taken – and it’s the senior manager that’s accountable at the end of the day.

 

In your ‘Naughty List’ section, you touch on the point about firms potentially doing the ‘minimum possible’. What do you mean by that?

 

JA: I think I need to preface that with the fact that some companies design a T&C scheme and they don’t intend to do the minimum possible, but they’ve created an environment where what I call activity managers can breed or succeed.

And what I mean by that is you might have defined a T&C scheme that has an expectation of an observation, say, every quarter, and you have a monthly one-to-one, and you have a certain percentage of cases that have to be reviewed. And everything seems absolutely fine. Well, it could be, but at the same time, when you actually look at the nature of the assessments that have been carried out by the supervisors, you find that instead of actually adding to the breadth and the depth of evidence of a person’s competence, it’s really just repeating what’s already been done. It’s the simplest cases.It’s the quickest calls.

The activity manager, as I call it, would look down the call list, choose the shortest call thinking, ‘well, that’s the activity completed,’ as opposed to being the competence manager that thinks carefully about how the evidence being gathered matches into the competence profile of the individual they’re assessing.

The other thing that you find is that when it comes to even defining what competence looks like, the ones that are trying to get away with the least possible tend to focus on the compliance aspects of processes, rather than the behaviours that are needed to support getting the good outcomes that we’re trying to achieve.

I’ll give you a real-life example. I was asked to look at an observation aid literally within the last month. One of them was a completed observation aid and there was no reference whatsoever to any of the behaviours that the adviser exhibited. There was no comment on the reactions or the questions made by the customer. It purely focused on whether the process had been followed. It focused on the “what” not the “how.” And these are the sorts of things that lead to the ‘tick-box’ mentality. It says you’re completing the activities, but you have to question what real value you are adding, and that’s what I mean by people trying to get away with the minimum – the activity manager and the tools.

 

When you look at something like Consumer Duty and the FCA’s continual reiteration about embracing the spirit, not just the letter, of regulation, would you agree that it’s these types of activities that speak to that?

 

JA: Yeah, indeed. I mean, when we go back to the Consumer Duty regulations as they came out, the regulator used a form of words that said, ‘we’re not wanting firms to purely follow the letter and the prescription of the rules; we want you to think about the bigger picture and take the steps necessary to ensure that you’re doing the right thing for the right reasons.’ So, yes, we’ve been told that, and it’s up to firms to decide how they’re going to interpret that.

 

And, again, staying with Consumer Duty, when we look at recent regulatory speeches, guidance and themeatic reviews, firms have been told that there is an expectation that it needs to be a continual learning and improvement exercise and that Consumer Duty training activities should ideally be personalised to role and function to help staff understand and embed desirable practices in their day-to-day activities. This feeds into the ‘sheep dip’ training mentality, doesn’t it? What do you mean by this, Jeff, and is it a risky approach in your opinion?

 

JA: In a training world, it’s essentially: you treat everybody the same irrespective of their past experiences, their level of competence, or their preferred learning style. So, it doesn’t matter what you bring to the table; you’re going to be treated exactly the same way. So when it comes to rolling a piece of training out, you don’t differentiate the fact that you’re a seasoned adviser, you’ve been working and meeting the competent standards, obviously, for a period of ten years, compared to a new recruit coming in that’s just passed their competence assessment. Everybody goes through the same thing. That is sheep dipping. It’s not really something that firms do nowadays as much as they did, but clearly that’s a ‘Naughty List’ practice. Some of the risks involved – apart from the resources it consumes – are that you can’t assume that all the training is going to stick. So, the job of the supervisor is trying to help embed that training.

So you’ve got the risks of how much is actually sticking, how long it’s going to take for those changes to embed. You’ve got to think about the motivation levels in the firm as well, because how do people feel if they’re having to attend an event that they’re getting no value from or maybe ten per cent value compared to the rest? So, the key risks are: consuming more resources than you have to, the effectiveness of the training, the levels of motivation, and the speed of business changes. All these things say ‘no’ – it’s not a good idea.

 

When it comes to personalisation of training, Jeff, do we have any best practice examples from the regulator?

 

JA: I think the best example of that would be what the regulator’s published about the Code of Conduct training. They don’t want training to be rolled out across the masses, they want it tailored to the needs of the individual, so they understand not only what the code is but the relevance to their role and how they can live the code.

So, you know, be prepared to face the question that says, ‘Well, if you’re doing this for that aspect of the role, why don’t you do that for the rest?’ Again, it’s one of these examples that says, do we really have to tell you that you should do this? Or can you not actually build that from what we’ve already told you we’re looking for? Surely you recognise that by doing the right things for the right reasons, tailoring it to the individual, you’ll get the best results working with the individual which will lead to the best business results for customers and the business itself.

 

For firms looking at your list and thinking we’ve got a foot in both camps, what do you think is the most impactful first action they can take to start moving the dial towards better practices?

 

JA: I suppose the first thing to think about is, rather than assume where you are, take

action to find out exactly where you are. One of the best ways to do that is to compare yourself to your desired end state. Now, how do you define that desired end state? Well, there are a number of different things you can do. There’s a list that’s been put on T-CNews of eight principles of a good competence scheme, and it’s supported by about 100+ indicators. You can access it, and you can use that as a checklist to determine whether or not your T&C approach is meeting what you expect. There are other things that you can look for from external sources about what good looks like, but the key thing is you agree those standards of what you’re aiming for, and you carry out a review of where you are.

Having done the gap analysis, you can then discuss ideas for moving forward, prioritise those, and put together an action plan. But I would say that the whole exercise ideally should be sponsored by a senior manager, preferably one responsible for the competence of that particular business area.

 

One of the key ‘Nice List’ practices you’ve mentioned pertains to ensuring that supervisors are highly skilled coaches, trainers, assessors, and motivators of the business. Practically speaking, how do you train the trainer?

JA: OK, well, it’s a similar sort of approach: you need to understand what you’re looking for. What makes a good assessor? What makes a good coach? What makes a good supervisor? You can’t assume that the person has all those skills and abilities. At the same time, what you can do is put together a programme that is capable of adapting to their preferred method of taking on board the learning so that you can develop them to be what you’re after.

Many firms put in supervisory training and that’s an excellent start. But I know from working with supervisors over the years that either they haven’t covered the ground, or they forget things, or they haven’t necessarily had that interaction. This is because one of the things you find is, as you work up the ladder, often it is assumed you have the skill sets needed to be able to perform what’s asked of you, and that’s not always the case. So, we need to make sure that we’ve got some sort of process to ensure that the competence of the managers is in place.

Now, it may be a little bit old, because we’re going back a few years now, when the regulator first came out and looked at the success of the banks and building societies to deal with the certification regime and requirements, one of the things they picked up – and it’s referred to as the Stocktake report – they actually told people, “Don’t forget you need to make sure that people that are performing those assessments are competent themselves to be able to do so.”

If you don’t do that, you’ll build a house of cards because you turn around and say, “Yeah, we’ve completed all the assessments. Everything’s been done,” and then somebody says, “Well, who confirmed the assessors were competent to perform that?” “Well, that’s a good question. We didn’t quite cover that.” Suddenly, it undermines all the assessments that have been taken place. Supervisors are no different to anybody new. You just have to have the structured approach to cover off what you’re looking for. So, make sure you know what good looks like.

When I run supervisory programmes, people smile when we say T&C is a motivational tool. But I share with them how we actually look at motivational models and how we can say, through our actions, we can either support, encourage, develop and progress, or we just scratch our heads wondering why we’re not getting the results that we want because we haven’t addressed some of the underlying causes. So, it goes beyond the coaching and assessment skills. It goes back to this, you know, do we have to tell you literally about what you have to cover off as a supervisor? We’re telling you, you must have good coaching and assessment skills, but there are a few other things that you also need to be pretty adept at to be competent to do a good job.

 

For firms that have a desire for their T&C scheme to be a motivator and key enabler of the business, how do they go about securing budget and demonstrating value?

 

JA: We have to realise that we’re not necessarily regarded as an investment; we’re regarded as a cost that says, you know, how much can we afford? We don’t want to spend too much money. But we’ve got some things in our favour nowadays. I’ve already mentioned this requirement placed upon senior managers to make sure that your people are competent. So, if you have got problems resourcing either through manpower or financial budget, you know, a clear business case that you need to address, and you haven’t got the budget, then go to the person whose head is on the block; they might be able to unlock something for you. But clearly, what you’ve got to be able to do is demonstrate the value that you add. If you can actually demonstrate, through having people who are competent to the appropriate standards, the knock-on effects or benefits to the business – you know, the level of business volumes, the lack of complaints, the customer experience that’s coming through that’s reflecting that they’re a pleasure to deal with – clearly those things are in your favour if you can pinpoint precisely the areas that you’re trying to fix.

If you’re not quite in that camp, your business leaders are going to sort of push back if you say, “Yeah, we can resolve all this, all we need to do is send everybody on a three-day course.” Whilst they factor in days off for training and CPD purposes, that’s a huge ask for a business to try and do it.So, we’ve got to be mindful that it’s not so much our money that we’re spending; it’s the business’s income that we’re having to address and how can we demonstrate a return on investment based on what we’re proposing to do? And if you can deal with those aspects, as well as address the other old favourite, which is senior managers often assuming that somebody goes off on a training course and comes back competent to implement the changes. That’s not the case. What we’ve got to think about is that’s the initial acquisition of the knowledge or skill. We’ve then got the supervisors to help coach, develop, and implement that on the job. So again, that’s part and parcel of the factor of how do we actually make sure people understand.

What would you say are the best observable behaviours of a ‘Nice List’ firm?

JA: If I break it down, at the end of the day, it’s for companies to decide what’s going to make the real difference. The ones that scream out in a Consumer Duty world are all about customer focus and communication. So, from that viewpoint, those are absolutes in terms of what goes on. And what I mean about communication: it’s when you look into any aspect of it and you find a sentiment that says, ‘Well, I sent them an e-mail. Surely they know, they understand?’ And you think, ‘Woah, yeah, this is a complete lack of understanding of what communication is all about.’ With the regulator placing so much focus on that, we need to be very, very sharp on our communication skills: effective listening, summarising, and making sure that we’ve gone beyond checking the customer’s understanding by simply asking them, ‘Do you understand?’ I’m in favour of asking a couple of questions that demonstrates that they’ve picked up some of the key elements.

I’ve got a few others: What’s more important? Is integrity more important than personal development? To me, integrity is key. Where does integrity fit in? How many times do people say, ‘I’ll get back to you by the end of the week,’ and they don’t? They break a promise. You know, these are fundamental issues that say, ‘Yeah, if you’ve made a mistake, own up to it.’

These are important aspects of a very successful company. But if we go back to what I said earlier about collaboration, you know that working together because you’re all working for the same company, teamwork is important. I’d probably put personal development in there too. How people approach their personal development, how they invest in themselves, how they approach their CPD, and how they demonstrate that CPD builds them, but also fits into their portfolio of competence.

The other thing that firms need is examples of what good looks like. So, it’s all very well to say, ‘Well, we want good communication skills,’ but give me examples of behaviours that you’re looking for to essentially show that we’re meeting what you’re expecting. So, it’s having those sorts of standards.

Now, rather than sort of say you’ve got to go away and commission experts to define what those behaviours are, there are some tools out there that you can access. There’s something called the Universal Competency Framework that gives you examples of behaviours. It’s not something that you have to invest thousands of pounds in; it’s what you do with that once you’ve defined what you’re looking for.

With the expectation for more personalised approaches to T&C, how can firms – especially those with a larger number of employees – approach this without the administration becoming too overwhelming or burdensome?

JA: It goes back to the supervisors having the necessary skills, being adept at training and coaching. You assume that the spans of control – if I refer to that terminology – are appropriate so that you’ve got a supervisor that can work with their team and help provide the assistance that’s needed. When it comes to the designing of any sort of development or training, if you apply some of the design tools up front, that allows the supervisor, perhaps, to go to a menu of ten things, for argument’s sake. They can then identify, working with the individual, that items two, five, and seven will really help that particular employee.So, what you’ve got is a more tailored approach that could arguably create a better, quicker, and cheaper response than doing that “sheep dipping” thing that we talked about earlier. If we’re looking at what
advocacy is and what the best way of doing it is, it is tailoring to that individual’s need.

I think the other thing is that if you have technology behind it, what you’ve got is the opportunity to say, “Well, actually, rather than just do those three modules by yourself, we’ve got twenty people here that are looking for the same.” So, you could start to create cohorts of people working together with the same sort of preferences or the same needs.

You say that the best firms learn from their mistakes – what do you mean by this?

JA: Arguably, no one is perfect, and firms will make mistakes. So, what are the consequences of those mistakes? Rather than constantly having an approach that says, “Well, you’ll need to do that again,” or “You’re restricted in this area,” we have to think about: “What have you learnt from that experience, and how can we actually prevent that from happening again?” or “Have you identified something and taken action todeal with it?” Probably the best result or example I can think of is a firm that used to conduct compliance monitoring visits,like every other firm. They had a policy that said if they conducted a review and found something that needed to be addressed, that was one outcome. But if they found the issue and there was also evidence to suggest the supervisor had already realised it and had started to correct it – taking the honest and open approach – then the mistake was treated as a positive. It was saying, “Well, you’ve identified it, and you’re working on it.”

So, this is the sort of thing that encourages people to admit to perhaps falling short of the mark, or encourages them to use their initiative to correct it – not to cover it up and hide it, but to be open and transparent and fix those areas. These are the sorts of behaviours you’d encourage people to adopt.

 

I think that’s a great point, Jeff. The regulator consistently reiterates that self-improvement piece, don’t they? Do you think that it’s not a case that the FCA wants firms to be perfect, but that it’s about honesty, transparency, and not sweeping things under the carpet?

 

JA: Yes, I mean, absolutely. There is also a danger that if you’re looking at a balanced scorecard and it’s all green, you’ve got to be able to challenge it. You’ve got to be able to lift the surface and ask questions. If I go back to things like activity management: “We’ve done all the assessments, everyone’s passed, no problems at all.” And then you start to look at it, and you think, “Well, that’s not right.”

If someone had then said, “Well, actually, we recognise that when we analysed the data, we missed out on certain areas of the business. We’ve currently got a remedial plan in place to address that. So, we’re going to turn that green indicator amber because we feel that we should do things slightly differently.” Those are important things that say: “Let’s be transparent; let’s be honest and open.” And the regulator would review us and think of us in a much more positive light than if we were keeping things hidden from sight.

 

Finally, Jeff, T&C is ultimately a ‘people business’, but what’s your opinion on technology for T&C? Can it help and, if so, how?

 

JA: If we look at it and say: let’s see what we’ve got without technology, then T&C will potentially just be a mass of paper records. Yes, you might have all the evidence of a person’s competence, but what we then want to ask is, “How is that information, how is that data, able to produce management information that is capable of informing the business?” And that is when you think, “Well, perhaps we need technology of some description.”

I would speak to the senior manager responsible for competence and performance and say, “What information do you need to know to satisfy yourself that everything’s working and on track?” So, we need technology to help us do that. One of the things that makes eyebrows raise in one of the T&C workshops I run is when we talk about the objectives of your T&C scheme. We then go on to say, having defined the objectives, “What are the indicators that you monitor to ensure your T&C scheme is performing against those objectives?” In simple terms, you could create a traffic light system that goes to senior management. If course, they’re going to focus on the one that says amber. “Why is it amber?” So, we’ve got that sort of thing to consider. But then the other thing we need to do is connect things like products and services, competency levels, and consumer outcomes. What we don’t want is the T&C scheme necessarily to say, “Everything’s wonderful. It’s in fantastic shape” – and yet the consumer outcomes are telling us, “You must be joking.” You know that there are all sorts of issues that haven’t been addressed. So, we’ve got to connect those in some way, and we’ve got to think about how we interrogate. How do we identify competency hotspots that tell us where we need to apply resource to fix things that will change some of those issues that we’re experiencing further down the line?

So, yes, there is a place most definitely for technology. I think with the right technology, you could probably free up time, and therefore advisers will be able to cope better in terms of having to deal with things.Without it, I think you’ve got a bit of a challenge. If the technology is the appropriate one, it will help most definitely, but at the end of the day, I think it’s important that the business drives the technology, not the technology drives the business. It goes back to this element of control, and if it’s the right solution, it will work very well.