People – who knows any of those?


The old saying “there’s nowt so queer as folk”  is even more apt these days than it ever has been.

When we look around any conference room in financial services and you will see a lot of more mature around the room. Of course, I am talking about age rather than behaviours.  There are some scary statistics about the average age of advisers and the amount of advisers who are likely to stop operating over the next few years.

Succession planning is a growing problem. As advisers stop practicing, who is going to take over and look after the population of clients that want to continue to receive advice.  Somehow financial advice is not a profession that is mentioned often and only the children of advisers are likely to have any ambition to become one. And most of those are probably not entirely convinced when they hear about all the regulation that gets in the way of business.  And then there are the qualifications that are the ticket to the disco as well as the ongoing continued professional development.

In times gone by, only older people, over 75 years old, would trigger any kind of consideration of vulnerability

If the recruitment into advice Is a problem, recruitment into compliance is nigh on impossible. It is certainly not a career-path that is likely to receive much notice at careers fairs or in schools. It is possible to go directly into compliance and learn the role whilst completing qualifications.  But it is more likely to be a career step once someone has some experience of their working environment.  I used to be an adviser and feel that my experience makes me much more able to understand the advisers that I look after.

The Association of Professional Compliance Consultants is about to release some specialist compliance course that will lead to qualification in compliance practice. At the moment, we simply rely on being CII Diploma qualified or something equivalent. This is certainly a step in the right direction.

The introduction of Consumer Duty last was just the last project by the FCA to get advisers to behave ethically and not rip people off. To put the clients’ interest first and look to help good outcomes to be achieved.  To me, it is a sad indictment of our advice industry that so many sticks need to be used to get advisers to behave.

One of the pillars of the Consumer Duty is the emphasis on correct treatment of vulnerable clients. In times gone by, only older people, over 75 years old, would trigger any kind of consideration of vulnerability. I can remember dealing with an older lady talking about investments. If I had suggested for one moment that I thought she may be vulnerable,  I would have been offered the choice between a slap in the face or wearing the tea that she had made for me.

There are so many definitions of vulnerability to make advisers nervous that they may overlook something or tear themselves in knots to accommodate everybody. Again this should be just a minimum standard of behaviour for advisers to ensure that their clients understand their communications and the application of solutions to pursue their objectives.

I found myself being treated as a vulnerable client. I was trying to resurrect an old email account that had stopped working. After a while on the telephone, it became obvious that we were looking at different screens and getting nowhere. The operative could not simply link up and do it for me. After a while, he said “is there anybody that can help you with this” I said that I thought that was what he was supposed to be doing. A short while later, he said “is there somebody younger who can help you?”  It was one of those wonderful lessons in how not to do something.

With the election currently running, I guess that we could all be considered to be vulnerable.  Politicians are skilled in not answering the questions set. Providing answers that are easily proved to be incorrect/false. Making promises that are unlikely to be achieved. And then looking on in wonder at some remarkable behaviour that would lose most of us our business.

The only thing that I would want is to encourage everybody to actually vote. It does not matter which way you vote. But you are not in any reasonable position to complain if you do not get what you want, or thought that you wanted, if you have not been bothered to vote.


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Tony Catt from The Catt's Eye View Tony Catt is a freelance compliance consultant working with several firms of different sizes. "I have previously been an adviser, which gives me a good understanding of the advice process and dealing with customers and I enjoy a close relationship with my adviser clients"

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