Selected Issue 6 - Summer 2019


also require mortgage advisers to keep a record of why they did not recommend a cheaper mortgage, if the product recommended was not the cheapest policy that met the customer’s needs and circumstances. These proposals are one part of a package of remedies from the Mortgages Market Study. You can read more about the final report on page 8. In March, the regulator also stated it was concerned consumers were being “unnecessarily channelled” into advice and said its rules on advice could have been a barrier to the development of tools that help consumers choose and buy a mortgage. Based on the fact that the original Mortgages Market Study found that the mortgage market is working well for most customers, these developments are concerning – if it ain’t broke, don’t fix it comes to mind! We will therefore be keeping a close eye on how this progresses and as ever, represent your best interests via my board position within AMI and other channels.

to better enable the public to understand what to expect from regulated advice. The gold standard is linked to an adviser code, based on nine principles underpinning good practice in pension transfer advice and firms need to have PI insurance that meets Financial Conduct Authority (FCA) threshold conditions. We can help you with potential amendments to your IDD and client agreement, so please contact the Compliance Helpdesk for support if you decide to apply. Increased FOS compensation limit From 1st April, the Financial Ombudsman Service compensation limit increased from £150,000 to £350,000 for complaints about actions by firms on or after that date. There has been a lot of concern within the market about what the effect on advice firms and professional indemnity insurers will be. Your PII cover requirement is unlikely to be affected by the increase in the award however, in so far as the cover you have in place needs to comply with the levels set out in the FCA Handbook, but it is widely expected that premiums will increase in the future, as a result of the risk of higher compensation awards. If you do have any issues on the PII front, don’t forget that Tenet has a scheme in conjunction with Lloyds-registered specialist insurance brokers, Protean Risk, for delivering high quality insurance solutions. Mortgages Market Study As I write, the FCA has published its consultation on mortgage advice and selling standards, which includes proposals to change its mortgage advice rules to make it easier to offer execution-only options to borrowers and to equalise treatment of advised and execution-only sales. It will

If you feel that your firm would benefit from an overview of the FCA’s expectations in these areas therefore, and a review of the outcomes that you need to be delivering, we offer a range of audit and file checking services that can help offer peace of mind. Please contact your account manager for more information. SMCR Update Are you on track with your planning for the introduction of the Senior Manager’s Regime? According to the timeline mapped out in our comprehensive SMCR guide, by April you should have by now identified the prescribed responsibilities and produced a first draft of the Statement of Responsibilities (SoR) for each senior manager. Our updated SMCR guide, plus template material, including a job description template, SoR guide and template can be downloaded from our SMCR area on the extranet and includes useful checklists for Core and Limited Scope firms. The FCA has also published guidance on statements of responsibilities, setting out their purpose and providing some questions for firms to ask themselves, as well as outlining examples of good and poor practice. It would be good practice therefore to download the FCA’s Finalised Guidance FG19/2 SMCR and review this in relation to your own structure. PFS Pension Transfer Gold Standard As you would expect, Tenet is a huge advocate of the recently launched PFS Pension Transfer Gold Standard. The regulator’s focus in this area is not going to diminish and this is a positive move by the PFS in the wake of the British Steel scandal

Simon Broadley Adviser Propositions Director

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