What about the competence of non-adviser staff?


My last article looked at the issues around evaluating a T&C scheme for advisers and came to the conclusion that the business plan has to be at the centre of the scheme. If the business knows what it is trying to achieve then personal development can focus on those objectives.

When I first became involved in financial services the organisation I worked for had half a dozen administrative staff and probably 50 ‘financial consultants’. Back in the 80’s before regulation kicked in much of the focus was on sales techniques – there was even a bell to ring if you came into the office with new business. That firm is no longer in business.

What I am finding now is that the balance between advisers and non-advisers in organisations has shifted considerably. The focus now is much more on building long-term relationships and providing an ongoing service that ‘adds value’. In order to do this firms have found that the role of administrative staff has become more important with clients talking to them at least as often as they do to their adviser.

The FCA requires all staff to be competent but often the focus of T&C schemes is on those in client facing roles. This is understandable as that can be perceived as one of the key risk areas for a business: giving the wrong advice can be very costly to put right. Qualifications and processes are in place, alongside CPD to try to help advisers maintain their knowledge. File checking is carried out on a regular basis to ensure that standards are being maintained. These are the things the FCA would check on a visit so it makes sense for firms to be clear.

it is likely that the relevant competences will be identified through considering what your firm’s clients expect from you

It is perhaps more difficult to create a scheme which applies to those carrying out administrative functions. In areas such as accounting there are examinations, refresher training and audits to check that the numbers have been run correctly. In marketing again there are qualifications as well as the rules around financial promotions that can help keep adverts relevant and compliant. Management information generated about campaigns can provide feedback about what works.

For new business support this may be a little more difficult but I believe it can be done. Again the focus starts with the business plan: what is the business trying to achieve and how do the various roles fit into those objectives? Being clear on these issues then means that job descriptions can be created to reflect the work required and this will drive the skills sought from staff.

Key performance indicators have for some time played a key role for advisory staff and some firms have similar arrangements for other staff, using different measures. With the FCA’s emphasis on firms having a client centric culture it is likely that the relevant competences will be identified through considering what your firm’s clients expect from you. I expect that prompt and accurate responses to requests will be relevant for all firms but the issue is how this can be trained and measured in terms of a competency framework.

Firms will make their own judgements about how much additional monitoring is appropriate for their business. Some feel that CPD is relevant for all staff and will have set up their system so that everyone has access to a range of training opportunities and encouragement to log how they are developing their skills and knowledge.

Exams are compulsory for advisers – the FSA/FCA saw to that – but many firms encourage other staff to attain qualifications to help them better understand how their work fits into the bigger picture of the business and what it does for clients. Refresher testing can be a measure of on-going competence for all staff, pitched at the appropriate level – this already happens for anti-money laundering. Many firms bolt questions on to this process to ascertain that general financial services knowledge is being maintained.

Other measures are: turnaround times for requests, volumes of applications/calls/correspondence dealt with, meeting of deadlines, timekeeping, absence, attitude, relations with colleagues. This shows a combination of indicators and the question for many firms will be is this to be driven by compliance or by HR via the appraisal process? If the latter, firms should consider if there are issues with a compliance impact.

One of the challenges with using the appraisal process is that for many firms this remains an annual event which at least in the early stages may not be enough to ensure that good habits are being established. Periodic reviews and other one to one meetings may be the solution.

Client feedback is another tool for assessing the competence of your team. The FCA encourages the use of open questions rather than tick boxes and in recent seminars has given examples around how the client describes the service or product they have bought.  Their focus is on whether clients understand but for non-advisory staff our attention could be on the overall experience of dealing with us. Questions such as how have you found dealing with our firm may help you to build a picture of what is working well for your clients. What could we improve on will help identify additional competences against which you should measure your staff.

Speaking to clients and explaining that you are trying to enhance the service they receive is encouraged by the FCA (some PI insurers may take a somewhat different view). Thoughtfully worded questions shouldn’t raise contentious issues or raise unrealistic expectations – it’s still your business and you can’t be all things to all people. As with your due diligence in product selection the key is identifying what is important – what will make the biggest impact in terms of staff performance and begin with that.


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Compliance Cubed Financial services is constantly changing - my passion is helping firms function effectively and in compliance with FCA regulation

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