Advisers will remember a time when the Compliance Officer was probably the person you would least want to meet in the corridor, let alone in their office. The Compliance officer was often also responsible for T&C, and any summons for the adviser’s presence was unlikely to be good news. The sudden appearance of the Compliance Officer over an adviser’s shoulder whilst they were sat at their desk was probably the most unwelcome conversation anyone would want, even on a good day. Depending on the severity of the case, the conversation could be likened to that of a vampire about to sink his teeth into the victim’s neck, in that the life could be crushed out of the adviser’s bonus for that period, and the list of remedial actions required appeared to have much synergy with the doomsday book, at least on a item by item basis. Back then the T&C Scheme role appeared to be a more of a barrier to business being conducted, rather than an asset.
Hopefully today it’s a different story. Implemented well, the T&C scheme has a massive opportunity to be a friend to both the firm, and to the scheme members. Implemented badly or just sat there in the background, it can be a foe. The deciding factor is whether or not the scheme has the right focus. More importantly is how it is received by the scheme members.
The Passive Scheme
The passive scheme skulks along on the fringe of day to day operations and only comes to life when its diarised activities force it into action. The level of engagement with the scheme members is usually minimal, often providing little or no education and just ticking the boxes to meet its requirements. Using a T&C scheme in this way does little to help the firm or the scheme’s members, and can become a burden rather than an asset.
The Proactive Scheme
The proactive scheme is one that interacts with but does not interfere with the firm. It actively engages with the members at all levels, establishes a healthy working relationship whilst creating and delivering an educational environment that benefits both the firm and the individuals working within the firm.
One size does not fit all and, whilst it may be acceptable to use a generic template as a starting point, the way the scheme is actually used has to fit the firm itself and adapted accordingly
No firm should want a passive T&C scheme. There is little or no value in something just “being in place”. So consideration should be given as to how the scheme can be used to best advantage, whether when setting up a new scheme or revising an existing one. The value of the scheme should be measured by what it delivers to its members against what the members deliver to the firm overall.
Every T&C scheme should be bespoke to the firm it works with. One size does not fit all and, whilst it may be acceptable to use a generic template as a starting point, the way the scheme is actually used has to fit the firm itself and adapted accordingly.
Improving quality improves sales
Assessments are one way in which the scheme can help the firm improve its’ income flow. The better the adviser performs with a client, the greater the opportunity they have of the client acting on the recommendation. The way the assessments are carried out and the forms used may need adapting to ensure that, like the way an adviser adapts to a client’s personality and receptive traits, they are relevant to the type of business being conducted. For example if the scheme is working with advisers who spend a large proportion of their time with their existing clients, the assessment must be tailored so that the output and therefore any developments meet the needs of the type of meeting being undertaken. The language employed in the output is also a very important part in getting a message across: “Points to consider” will be much better received than “What went wrong”.
Education
The scheme may use education as a means of driving up the quality of record-keeping, rather than “waiving the big stick”. Mistakes do happen and documents do get omitted from client files. Advisers, whilst having the great ability to verbally display their knowledge about the client and a particular transaction during a discussion may not have the same skills when documenting the same information. The proactive scheme will look beyond what it sees and try to establish why something happened before using an educational method to prevent a reoccurrence.
Active, not passive, monitoring
Scheme members are often left to “just get on with it” when it comes to mandatory requirements such as undertaking and recording CPD. The scheme should be actively monitoring each member to ensure that the right levels are being recorded and to avoid potential issues such as having to rush the CPD input at the last minute. Engaging with each member helps them plan and focus on what particular area of knowledge the member wishes to improve using CPD.
There are other ways the scheme can get actively involved. Setting up a diary to prompt renewal of SPS’s, following progress towards examinations, and providing MI in advance of supervisory meetings help promote the scheme’s relationship with its members and other stakeholders.
Effective communications
How information is communicated is essential to helping the scheme members. Communicating the outcomes of assessments and file checks helps the individuals concerned, but regularly sharing that information other than just at team meetings, and in a generic format with the other members of the scheme, helps to educate everybody.
Encouraging members to also hare information that they personally acquire, such as seminars, training events, and industry news through a medium that everybody can access actively promotes learning and relationship building within the scheme.
Paperless records
Hardcopy files should be changes to electronic ones. This facilitates a more effective administration of the scheme, accurate gathering of MI and the overall monitoring, and allows the scheme to promote the ease of the delivery and filing of documents such as examination certificates, CPD evidence, annual declarations, benchmarking results etc.
The T&C Scheme can be a highly effective tool. It should be an integral part of any firm and should be embraced as a friend, not a foe. To use it in any other way is a waste of a highly valuable resource.
