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Our last 'Your Voice' took place on 2nd October 2008. To read the archive of our last web chat on the RDR, please click on the following link:
We have just launched a new report about the retirement market which is causing quite a stir. Entitled "Financial Planning Through Retirement" the report looks at the issues of decumulation.
At the end of last year, I spoke to a number of member firms about how they were handling the decumulation challenge facing their clients. What shone through the responses was how difficult delivering advice in this area actually is, how complex the subject matter, how ever-shifting the political and regulatory backdrop, and how the marketing of products only adds to the noise and confusion.
It seemed to me that clarity was needed and so we set about the task of better understanding the issues. We were joined in our work by the Prudential who brought their expertise and commitment to the table and helped to fund the substantial research that was needed.
The report seeks to join together the threads of: emerging public policy thinking, regulatory structures, provider marketing, advisory practice, the demands of consumer groups, and the needs of real consumers. We interviewed over 1,000 consumers in compiling the report, interviewed firms from across the spectrum of providers and advisers, and met with consumer groups, politicians and those who help influence public policy.
The work was overseen by a high profile Editorial Board: Rt Hon John Gummer MP; Lord Lipsey; Prof. David Blake; Tom Boardman, Barry O'Dwyer and Russell Warwick (of Prudential); Allan Rosengren (Lighthouse); Mark Lund (Money Portal) and myself.
However, the report is more than just an interesting market analysis. It contains recommendations for how the decumulation market can be fostered and consumers' real needs addressed. It has now been launched with a reception attended by leading figures in politics, public policy, regulators, members and the media. The report was officially welcomed by Nigel Waterson MP, Shadow Pensions Minister.
A copy of the report can be found in the publications section of the website. Rather than do it the diservice of trying to precis the key points to a paragraph, can I instead, commend it to you as worth the time spent reading it.
We will shortly be producing some Good Practice Notes to help firms better understand the practicalities of advising in this fast growing, and increasingly important, area. One speaker at the launch suggested that, because of the changes in society and demographic forces at work, the job of an IFA will, in the coming years, be focused less on accumulation and rather more on decumulation. This does of course remind us all of the truism that it is impossible to decumulate what you haven't accumulated!
It's the time of year again when leading members of the IFA profession head for PIMS. As one of the highlights of the networking calendar, PIMS has been through a transformation, as the needs of those attending it have changed.
For me, the opportunity to catch-up with so many members over the course of the event is simply too good an opportunity to miss. So, apart from my time on stage and in working parties, I've a full diary of one-to-one meetings.
I am a stickler for accountability and transparency; so PIMS is a golden opportunity for me to let members know how we are meeting our objectives - and to agree what the challenges are for the year ahead. This year, of course, the AIFA "score card" reads very well indeed! It's not every organisation that can proudly say that it has just saved its members £11.7m in regulatory fees! Given the difficult market conditions, rising costs, and the challenges faced in the RDR, a "windfall" like this is welcome news - as many members have already told us!
We are finalising the details of our Business Transition Academy, one of the most important and exciting projects we have ever offered members. This new service will enable members to benchmark their firm against the requirements of the RDR and leading business practice and, having undertaken a "self diagnostic", work through a tailored business plan for change. Free to members, this will save firms considerable financial expenditure - and give them a clear direction - or confirmation of their progress.
We have also been in close negotiation with FSA on the direction and detail of the RDR. This regulatory programme "celebrated" its third anniversary on 14th June and AIFA has clearly influenced policy throughout that journey. With the next round of consultation due at the end of June, there couldn't be a better opportunity to prepare.
In our tenth year, we have a list of achievements and accomplishments to be proud of. I look forward to spending time with all those on PIMS not only discussing what AIFA has done - but far more importantly - hearing what more AIFA can do for them. I look forward to seeing you on-board!
This week’s ABI biennial conference saw a range of high profile speakers address the audience including Shadow Chancellor George Osborne, FSA Chairman Lord Turner, and FSA’s Dan Waters. Speeches covered the economic crisis, the state of the markets, the future of financial regulation as well as touching on the role of IFAs.
George Osborne told the conference the Conservative Party’s economic policy is routed in 3 priorities: the immediate need to restore Britain's international credibility, the medium term priority to move to an economy built on savings and investment and the long term priority to re-focus the economy from the rush for short-term gains to the pursuit of long-term returns. Osborne claimed the current model of economic growth is fundamentally broken, and said the drivers of growth we’ve previously depended on cannot be relied upon to drive the growth of the next decade. While better regulation is clearly necessary, Osborne said this doesn’t necessarily mean an overload of new regulation and uncompetitive tax regimes which would undermine the UK’s competitive advantage. He said that what we really need is a deep culture change of long-termism.
Interestingly, when asked about the burdens of qualifications being placed on IFAs and sales people, Osborne said FSA requirements should be “appropriate to the product and its complexity”. He said there shouldn’t be cumbersome sales processes for simple savings products as they simply “create another barrier to entry” and defeat the initial purpose of simple products. It was very positive to hear him add that the Conservatives want a vibrant IFA profession and that they hope that by encouraging long-term savings, this should provide a big opportunity for the industry.
The party is set to publish a detailed set of proposals for the Tripartite Authorities in the next few weeks which I’m sure will provide some interesting reading and food for thought.
On a similar note Lord Turner used his speech to outline some of the key recommendations from his recent report on the future of regulation, saying “a revolution in approach” was needed. He acknowledged that FSA has to reassure consumers and industry that they have a grip on the issues involved. He said FSA is therefore following up on its TCF work and continuing its focus on conduct of business as well as prudential regulation. Additionally FSA will be responding to people’s expectation it will pursue enforcement against those breaking the law.
Turner said FSA needs to ensure it is cost effective and that the “era of light touch regulation and supervision is over”. Echoing Osborne, Turner also spoke of the need to inculcate a savings culture and stop people from relying on house price appreciation for their pensions
Perhaps the most interesting and relevant comments of the day came from Dan Waters at the FSA who gave an insight into the current direction the RDR might be heading. Waters said one of the key drivers of the RDR has been “creating an environment in which consumers have confidence in the firms and advisers with whom they are dealing” and that a very important part of building that confidence has been raising the quality of the advice they receive. However he acknowledged that a lot of advisers might choose not to go through to the higher level of qualification which would have the effect of decreasing access to advice, ultimately compromising the initial objectives of the RDR.
He continued by saying that to allow sales people to call themselves advisers because MIFID allows it is “just a recipe for actually going nowhere in terms of trying to achieve those underlying objectives and boosting consumer confidence on the advisory process”.
AIFA obviously warmly welcomes these comments as Water’s views echo our own work which shows that consumers need to understand who can offer them professional, independent advice, and who is just focused on selling from a limited range of products. The FSA is to be commended for such a fresh and positive approach and has shown, as it did with the recent announcement relating to fee levels for the IFA profession, that it listens to AIFA.
So all in all some positive comments and messages emerging at the conference, from both the regulator and from the likely future Chancellor.
Back in October 2008 in an interview with the Financial Times, FSA Chairman Lord Turner, implied that intermediaries had been paying too much in regulatory fees, especially in relation to the levels of risk they posed to the economy when compared to larger institutions.
This issue once again came to the fore in February when FSA published their proposed regulatory fees and levies for 2009/10, proposals which saw intermediaries fees increase dramatically without justification.
As members know, AIFA launched a highly publicised ‘fees campaign’ in response, urging those in the profession to unite with one voice and respond to the FSA’s proposals.
We assembled and coordinated a fees strategy group to ensure members were fully informed of all the issues, to develop strong workable solutions and to mobilise grass-roots support. We also sent correspondence to hundreds of firms asking them to respond to the FSA’s fees consultation paper. Not only did the profession respond but you responded in force – an impressive 533 responses to be exact.
On the political side of things we engaged in a highly constructive dialogue with HM Treasury, as well as meeting with civil servants and politicians from across the spectrum to outline our concerns. Additionally AIFA’s Chairman, the Rt Hon John Gummer MP personally intervened on the matter due to his strength of feeling that fees needed to be reduced.
We also met with senior FSA staff to voice the distress of the profession, and embarked on a significant media programme to highlight the issues raised.
We were therefore delighted that FSA took note of our campaign and lobbying and this week reduced the level of fees payable by IFAs and mortgage advisers by £11.7million compared to the initial February proposals.
The increase in fees for IFA’s, which were slated to rise by 15%, will now increase by just 4.8%. Mortgage brokers will only see a 2.7% hike, compared to the original proposed increase of 21.2%. And for firms with general insurance exposure, fees will increase by 9% compared to the proposed 19.8% increase. The FSA says once the financial penalty rebate is applied, approximately 10,000 of the smallest firms will see a fee reduction compared to the previous year.
This is an appropriate and welcome measure in difficult economic times. AIFA strongly believes that regulatory resources, and therefore costs, should be focused on those firms that require increased supervision and not those in the IFA and mortgage advice professions.
This announcement also shows the power of constructive lobbying and it is testament to the whole profession that uniting with one single voice on such a key issue has resulted in such a positive outcome, providing significant savings for firms.
Finally I want to echo John Gummer’s sentiments in thanking FSA for their bravery in changing their minds on such a key issue.
What better way for AIFA to celebrate our ten year anniversary than with the FSA announcement to review its fee allocation and significantly reduce the cost for intermediaries. This is an important win for AIFA and our members, and demonstrates how far we have come over the last ten years.
A defining factor of the fees campaign was the input and support that we received from members on the issue. The sheer weight of the response, which numbered over 500, meant that your views could not be ignored. The real triumph of the fees campaign was the ability of our members to unite with one, forceful voice when needed. We appreciate that members are extremely busy in this challenging and difficult time but hope members appreciate the difference that can be achieved. In the context of the fees campaign the difference has been a saving of £11.7m!
The proposed fees announced back in February were extremely unfair and it was forgivable to believe that FSA had perhaps underestimated the role that intermediary firms play in serving the UK public as well as their contribution to UK plc. However, our success over the fees issue should reassure members that on such important matters clear, concise, evidence-backed messages to the regulator are heeded and acted upon. This is a time of great change in regulation and for UK financial services as a whole, but after ten years of our active, campaigning style of lobbying, we do have the standing to influence change and improve the business environment for our members.
The key messages of our campaign have been taken on board by FSA and Lord Turner has reaffirmed that in the past “high impact banks were being regulated on the cheap.” Therefore the final fees increase for banks and deposit takers will be 109.4% compared to the 94.9% rise originally proposed. This does mean that firms requiring greater regulation will be meeting these costs not low impact advisory firms. Further, both Lord Turner and Hector Sants have provided reassurance that after this large hike in FSA’s budget they will work to ensure that the cost of regulation does not continue to increase year on year unchecked. AIFA will of course continue to work with FSA on its funding to make sure our members do receive a fair deal.
I am en route to speak at today's FSA conference on the mortgage market. The day started early with interviews on Radio 5's wake up to money slot and then on the Today programme on Radio 4. While it's true that the mortgage market makes headlines these days, it's not always for the right reasons!
The FSA will announce their thoughts for wholesale reform of the mortgage market. I am told their ideas will be very "green" (in the sense of open to consultation as opposed to environmentally friendly - though a reform of disclosure to cut down on paper would help on both counts!). The regulator has an opportunity to do some good in the industry and actually help would-be borrowers and those looking to remortgage. However, there is also the danger that innovation will be curbed, costs added and consumers actually made worse off. There are some "knife edge" decisions to be made.
There has been much discussion of "product regulation". Well, we've tried CAT standards (and the Sandler suite) and it failed miserably. So it's not retail product regulation that's the answer but institutional and funding regulation that needs to be addressed. Too many lending institutions flooding the market with poorly risk-assessed and untenable products helps no-one and builds a propensity to bubble-like conditions.
FSA need to review their authorisation process. Time and time again we see the regulator assessing firms which are behaving poorly... but they are the ones who granted the people running the firm the remit to do so - and were supposed to check the business plan for robustness and also make sure that's what the firm actually did! The whole process needs root and branch reform.
The financial promotions and disclosure regimes are simply out-dated. If this were not the case high street institutions would not be able to run adverts claiming to offer "impartial" advice that actually offered little more than slick-sales. Where is the regulator's enforcement team one wonders?
We have seen a huge focus on mortgage fraud - and rightly as it is a cancer that eats at the reputation of the sector. Yet the only action taken is against bad intermediaries who should not have been granted authorisation in the first place. But can an intermediary commit "fraud"
in isolation? Surely if it is a "successful" fraud monies must have been released from lending institutions... Were they complicit or duped? And if duped how was it possible for such small firms to beat the systems and controls of far larger institutions? I am waiting for the other shoe to drop and the suspense has been building for a long time; one wonders what is causing such a delay and where the police interest is in such matters?
This is a time for joined up thinking between the Treasury, Bank of England and FSA. We need to see lenders being "encouraged" to lend rather than having mixed messages delivered to them about capital protection, rebuilding balance sheets and offering some limited lending. The state controlled lenders should have a segregated funding commitment to lend to first time buyers as a way of kick-starting the market.
We have recently published two reports that explore these ideas more and they can be accessed through our website. The first is a report on the Fiscal Stimulus needed for the market, the second looks at the future of retail regulation. Members' views are sought on both topics so that we can lobby for your, and your clients', best long term interests.
Today is the day to express your views. The mortgage market, and wider housing policy, will affect your business, speak up and speak loudly!
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Financial Planning Through Retirement
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