Seasons Greetings from Target… CONTENTS€¦ · Seasons Greetings from Target… In this final...

ISSUE NINETEEN DECEMBER 2008

Seasons Greetings from Target… In this final edition of 2008 we lead with the recent FSA review of pension switch-ing, an area highlighted in Target back in June 2007. As well as highlighting the FSA’s findings, we have also included examples of good and poor practice to assist you in ensuring your approach to this business line is compliant. Also this month we highlight the recent clarification by the FSA regarding the requirement to disclose the total premium in relation to non-investment insur-ance business. We also provide details of the recent amendments to the Joint Money Laundering Steering Group (JMLSG) guidance notes and cover further changes to deposit protection limits. We also provide a round up of the flurry of information released by the regulator prior to the festive break. Finally, we would like to wish you a happy and prosperous New Year and we look forward to continuing to work in partnership in order to help you successfully navigate the rapidly changing IFA landscape in 2009.

CONTENTS • FSA Review - Pension Switching

• The FSA provide further clarification on the ICOBS requirement to disclose the total premium

• FSCS decision to over-rule FOS definition of “low risk”

• Summary of Amendments to the Joint Money Laundering Steering Group (JMLSG) Guidance Notes

• FSA to allow separate deposit protection limits

• FSA fines AWD Chase de Vere Wealth Management Ltd £1.12 million for mis-selling

• Conduct of Business sourcebook post implementation review

• Changes to FSA Handbook – income withdrawals and short term annuities

• CII and ANZIFF Merger terminated

• The FSA’s Agenda for Fighting Financial Crime in 2009

• Pension Reviews - Article from Scottish Equitable

FSA Review – Pension Switching

The FSA has recently issued a report on the findings of its thematic review into pension switching. Back in June 2007 we included an article in Target which highlighted the concerns of the FSA in this area and we highlighted the FSA’s comments at the time in relation to best practice. In September 2007 an FSA Newsletter confirmed that they were to undertake this review because of concerns about the fact that consumers are being transferred into higher charging pensions with features or additional flexibility which is not required. The review has looked at transfers from all types of pension schemes into personal pensions and SIPPs since A-Day. Unsuitable advice was found in 16% of the cases reviewed. The main causes of unsuitable advice were:

• switches involving extra costs without good reason (identified in 79% of unsuitable cases);

• recommendations that did not match the customer's attitude to risk and personal circumstances;

• failure to explain the need for, or put in place, ongoing reviews when these were necessary; and

• loss of benefits from existing pension schemes without good reason.

Paradigm would like to wish all our

Partner Firms a Happy and Prosperous New Year


Charges In relation to the first of these points, which was identified as an issue in 79% of unsuitable cases, FSA found that customers were being advised to switch into more expensive contracts without good reason, examples include:

• Switching for investment flexibility when this is unlikely to be used

• Switching for better performance without evidence that performance in the new scheme is likely to be better

• Switching for flexibility of a drawdown option when there is no evidence this was likely to be used

• Switching for consolidation without justification for additional costs

• Recommending a pension that is more expensive than a stakeholder, but a stakeholder would meet the customer needs FSA have provided examples of good and bad practice when carrying out cost comparisons: Good practice The firm set out a section in its template suitability report outlining any switch penalties on the ceding scheme and clearly explained the impact of charges of the switch. They did this by comparing the reduction in yield (RIY) figures for the ceding and new scheme (they used a software system to calculate the RIY of the ceding scheme). The firm also had guidelines around the level of additional charges that were considered acceptable and although these could be exceeded, this could only be done with head office agreement. Another firm had a similar process but used projected fund values instead of RIY figures. Poor practice The firm included a table in its suitability reports setting out and comparing the projected retirement fund value from the ceding scheme and the new scheme. These typically showed that the new scheme had lower charges. The advisers indicated that the new scheme involved lower costs and therefore this formed part of the reason for switching. However, the projection of the new scheme was often on the basis of 100% investment in a cash fund (which had no charges) where the fund was to be managed by a discretionary fund manager. The projections left out the cost of the discretionary management service and any underlying funds. Therefore the comparative table and the advice were misleading. Attitude to risk In the majority of cases where risk was the reason for the case being found unsuitable, this was because the funds recommended were too high risk for the client. The main issues identified here were:

• the nature and overall risk level of the investment(s) recommended;

• the impact the term of the policy has on the choice of funds. For example, in some cases there was little understanding that a fund that is suitable over a term of ten years is unlikely to be suitable for a term of three years for a customer with the same ATR;

• the customer’s investment knowledge and experience; and

• the benefits of diversification – sometimes the adviser did not appear to appreciate that investing in a single area or asset class (for example, property) is more risky as the customer has ‘all their eggs in one basket’.

In respect of this area, the following example of good practice was provided by FSA: Good practice The firm used a risk profiling tool to make an initial assessment of the customer’s ATR. They then used a stochastic modelling tool to create a series of model portfolios, with the individual funds selected by an independent fund research company. Although systematised, the approach was not used as a ‘black box’ – the tools were used as a basis for discussion and the process was adapted, when merited, for individual customers.


Ongoing advice Where an ‘asset allocation’ approach has been taken, the scheme should be reviewed and rebalanced periodically to ensure it remains suitable. In such circumstances it is expected that the adviser would explain the importance of reviews or offer to put them in place, however there were a number of cases where this was not done. Again examples of good and bad practice have been provided as follows: Good practice One firm had a very clear explanation in the template suitability report describing why ongoing reviews and rebalancing were needed for their portfolios (where an asset allocation approach had been recommended). Their standard service for customers also incorporated a full annual review and biannual rebalancing. Poor practice Many firms had not clearly established the risk of investments becoming unbalanced over time without readjustment back in line with the customer’s risk profile, and had not explained this to customers18. Although in most cases advisers had ongoing relationships with customers, it was not clear that these arrangements addressed the issue of rebalancing on a consistent basis. Loss of benefits There were also a smaller number of cases where advisers recommended transfers out of pension plans which offered valuable features, such as guaranteed annuity rates or guaranteed minimum pensions, without good reason. The following examples of good and bad practice have been provided: Good practice When recommending switching from a pension with a GAR (for valid reasons which benefited the customer) one firm would quote the current market annuity rate alongside the guaranteed annuity rate (on a like-for-like basis) in the suitability report. This helped the customer understand the value of the GAR. Poor practice The adviser did not adequately consider the nature of the existing with-profits policy. The policy included a significant guaranteed sum assured and also a GAR. The with-profits fund was highly rated. The new pension would have had to provide a net return of over 5% per annum just to match the scheme’s existing guaranteed benefits, ignoring any future bonuses. Procedural Failings In addition to the above other procedural failings were identified which, whilst not resulting in unsuitable advice, did increase the risk of this. These include:

• failing to adequately evidence the customer’s needs;

• failing to adequately consider the ceding scheme, its options and whether it was able to meet the customer’s needs (for example, by means of a fund switch);

• failing to ascertain whether the new scheme was more expensive than the old scheme(s);

• failing to explain why the product or the provider was recommended; and

• failing to consider or discount a stakeholder pension


The FSA has reminded firms of their responsibilities in enabling customers to make an informed decision when purchasing Mortgage Payment Protection Insurance (MPPI) as well as other general insurance and protection products. In July this year the FSA sent letters to various trade bodies setting out their expectations of firms selling MPPI in relation to the disclosure of total premium. The FSA has discovered that a number of firms selling MPPI only disclose the monthly premium and their interpretation of total premium falls short of the regulator's expectations that sufficient information should be provided to customers to enable them to make an informed decision about products. In the statement the FSA reminds firms that in accordance with ICOBS 6.1.5R firms must take reasonable steps to ensure that a customer is given appropriate information about a policy in a comprehensible form and in good time. The guidance (in ICOBS 6.1.6G) sets out that the price of the policy should be set out. The FSA states that a disclosure of monthly premium alone will not be adequate to enable customers to make an informed decision. The FSA draws attention to the previous rule in ICOB 5.5.14R which required firms to provide customers with a statement of price which included the total amount of the premium or at least the basis upon which premium would be calculated. The move to principles-based guidance does not change what needs to be disclosed. The FSA has examined MPPI contracts described as “monthly renewable” and states that these policies are not contracts of a month’s duration as the customer cannot in effect opt in or out each month and the terms of the policies are clearly linked to events over longer periods of time. For these reasons disclosing a monthly premium is insufficient for consumer’s ability to make an informed decision. The FSA considers that with annually renewable contracts where the customer is offered the opportunity to renew or opt out at the appropriate intervals, disclosure of the total annual premium is sufficient. However for “monthly renewable” contracts where renewal is automatic, the FSA does not consider the disclosure of the monthly premium amount to be sufficient as it does not represent the likely total amount payable by the customer over the duration of the contract. For these contracts the FSA has suggested the following possible ways of disclosing information which would comply with the rules:

• Disclosing the total premium over a period defined by reference to the list of events which the insurance contract says will cause the cover to cease, e.g. the customer reaching age 65;

• An illustration of the cumulative cost of the policy for milestone durations, for example 1,5 and 10 years; and

• For reviewable premium policies, disclosure of the total premium as set out in the first point above, or an illustration of cumulative costs as set out in the second point, noting that it is subject to review.

Paradigm Partner firms should note that in July 2008, the FSA gave all firms 6 months in which to ensure that their practices with regards to disclosure of premium met FSA requirements. The FSA will subsequently expect compliance by 15 January 2009.

The FSA provide further clarification on the ICOBS requirement to disclose the total premium

Systems & Controls Issues were also identified with systems and controls. Whilst firms have sales processes and compliance monitoring in place, it has been found in some cases that the procedures were inadequate or processes were not followed correctly. The FSA is determined to ensure all firms are meeting the required standard of advice in this area and are therefore in the process of writing to over 4,500 firms to set out its findings and the standard it expects from firms. Further assessment will also be undertaken in the third quarter of 2009 to see if firms are meeting the required standards. Partner Firms should, in the first instance, contact their Paradigm Business Consultant should they require guidance in this area.


FSA to allow separate deposit protection limits

In November, the FSA introduced a rule change to enable building societies which merge to keep their separate compensation limits. This rule change has been introduced following recent concern that building society customers with savings in two merging societies can find that their combined investment in the successor society exceeds the £50,000 maximum deposit protection limit for the Financial Services Compensation Scheme (FSCS). It is hoped that introducing this rule will help savers remain below the compensation limit and reduce withdrawals from building societies which are driven by compensation concerns. The new rules will operate on a temporary basis until September 2009 in order to address an immediate issue of consumer detriment which could transpire following any building society merger. The FSA plans to consult in the New Year on wider reforms to the FSCS including the rules surrounding whether deposits are covered on a legal entity, a ‘brand’ or an 'account' basis, and put the appropriate permanent solution in place during next year. We will provide further information as and when available.

FSA fines AWD Chase de Vere Wealth Management Ltd £1.12 million for Mis-selling

The FSA has fined AWD Chase De Vere £1.12 m for serious failings in its pension transfer, pension annuity and income withdrawal business that resulted in mis-selling. The fine would have reached £1.6 million had AWD not agreed to settle early and start paying compensation to customers who had lost money as a result of poor advice. The FSA said that as many as 800 people may have been badly advised in relation to 1,200 sales overseen by the adviser during the 19 months between February 2006 and October last year. It is the largest fine for pensions mis-selling levied by the FSA for more than five years. The FSA said the firm mis-sold pension transfers and pension annuities by recommending unsuitable products to customers who were already covered. It also said the group failed properly to disclose the risks associated with the products it was recommending. It said Chase had mitigated some of its failings by restructuring senior management, overhauling its compliance checks and changing its reward policies for sales managers. Chase De Vere has agreed to make compensation payments where necessary by next August. Further to the lead article in this issue, Paradigm Partner Firms should be aware that the FSA recommends that firms must take note of this thematic work and amend their own processes where necessary. Partner Firms should, in the first instance, contact their Paradigm Business Consultant should they require guidance in this area.


FSCS decision to over-rule FOS definition of “low risk”

It seems the split-caps investigation has become the biggest and one of the most chaotic in the history of the regulator. We therefore thought it pertinent to highlight the most recent developments to Paradigm Partner firms. Recently the FSCS has overruled the FOS definition of “low risk” in relation to split cap misselling and is refusing to pay out on cases upheld by the FOS. As one example, BFS Investments had 400 consumer complaints referred to the FOS before it went into administration in February 2006. FOS adjudicators have already upheld some of these complaints as they believe that these products should never have been described as low risk to consumers before the firm’s demise. When the firm went into administration these complaints were referred to the FSCS. The FSCS subsequently informed these complainants that it would not be paying any compensation as they believe the products were accurately described. The FSCS said that describing something as low risk is a “statement of intention” and “a subsequent change in the risk at a later date does not mean that the fund was misrepresented at the time of purchase”.

Summary of Amendments to the Joint Money Laundering Steering Group (JMLSG) Guidance Notes The JMLSG have recently amended its guidance following a consultation version published in August. The amendments relate to Part I of the December 2007 Guidance and include the following: Chapter 5 • Paragraph 5.7.7 has been revised to highlight the expiry date of photographs in new driving licences. The Guidance now

states it should be noted that as well as a general expiry date for UK driving licences, the photograph has a separate expiry date (10 years from first issue). Northern Ireland driving licences have a single expiry date, which is ten years from date of issue.

• Paragraph 5.3.211 amended information about "designated" solicitors' client accounts. Independent legal professionals that are subject to Money Laundering Regulations, and which hold client money in pooled accounts, are obliged to verify the identities of their clients. Financial services firms where such clients’ accounts are held are not required to identify the beneficial owners of such funds, provided that the information of the identity of the beneficial owner is available, on request, to the firm. As a practical matter, firms may reasonably apply a similar approach to such client accounts which only contain the funds of a single beneficial owner.

Chapter 6 • Several paragraphs have been amended and/or added to incorporate the provisions relating to reporting and tipping off, to

bring UK law into line with the Third Money Laundering Directive.

• Paragraphs on external reporting have been amended to reflect that, following advice from SOCA, and after reviewing consultation responses, the Home Office will not pursue its original intention to lay down a prescribed form for making reports.


CII and ANZIFF Merger terminated

In Target last month we advised you of the proposed merger between The Chartered Insurance Institute (CII) and the Australian and New Zealand Institute of Insurance and Finance (ANZIIF). However, it has since been announced that merger talks between the two parties have been terminated. ANZIIF chief executive officer Joan Fitzpatrick has stated that the merger has been deferred, due to economic conditions and “significant resistance” in the UK market. However, the CII has claimed that a number of financial discrepancies have just emerged in ANZIIF’s accounts and so it has taken the decision to terminate the merger. A CII spokeswoman has said: “It has become apparent that ANZIIF’s revenues are falling dramatically and it is potentially heading for a loss this year. This is the second year running ANZIIF will lose money.”

In a recent handbook notice, the FSA have confirmed a small change to the COBS handbook to clarify the disclosure requirements relating to income withdrawals from a personal pension scheme. The amendment has been made in order to clarify the requirement to provide a retail client with such information as is necessary for the client to understand the consequences of drawdown when that client elects to begin drawdown for an existing pension. This change is unlikely to affect the way a firm conducts business as we would expect firms will already be providing the relevant information, including illustrations, for clients who start taking income withdrawals from pension plans.

In November 2007 significant changes were made to the FSA Handbook and the Conduct of Business Sourcebook as COB was replaced by the new, more principles-based COBS sourcebook. FSA are now conducting a post-implementation review of the new COBS sourcebook, running through to 2010, and have recently released an interim statement on the review. The key findings of the review are detailed below.

• In the majority of cases firms and FSA staff find COBS easier to use and understand than COB

• Most firms have reviewed their procedures following the introduction of COBS to identify where changes may be required and many acknowledge that COBS will allow greater discretion in terms of their approach to compliance, but as yet few have made many changes

• In respect of financial promotions, the new requirements are more high level than the previous rules, but with the same intended outcome. Whilst it is noted that the standards for financial promotions have been maintained, firms are not really taking advantage of the extra flexibility offered under COBS although many have reviewed the ways promotions are produced

• With regard to disclosure documentation, FSA have found that a high proportion of the documents aimed to follow the IDD/menu templates fail to comply in various respects. These include missing registered trademark symbol when using the ‘keyfacts’ logo, missing information on the varying cost of personal pensions and presenting incorrect payment options. A number of IDD/menu documents also include out-of-date text. However, in contrast a review of documents developed by firms and advisers as alternatives to using the templates were all compliant and made good use of the flexibility offered by COBS – this very much ties in with our advocating of the use of the Client Agreement as a standalone disclosure document which firms can tailor to suit their own business model.

• Feedback from firms to FSA on the reformulated suitability requirements has been positive, however the findings in respect of retail intermediaries suggest that those who demonstrated poorer standards under COB continue to do so, although others have maintained the high standards of fact finding and recommendations which were in place under COB. In addition, there is evidence that a number of firms have made changes to the format and approach of their suitability reports since November 2007, although in the majority of cases this has not lead to any change or improvement in the standards of such documents.

• COBS also introduced new rules in respect of KFDs and illustrations with the aim of making these documents easier to understand for the intended audience. Because the main COBS transitional period has only recently ended it is difficult to assess the impact of the new rules but a review of a sample of KFDs suggests that the new standards are achievable and reasonable.

At this stage of the review no areas have been identified as needing substantial change, however some issues of clarity have been identified and FSA will consider action in respect of these in 2009. The review will continue through next year with the findings of the review to be published in 2010. Paradigm will keep you up to date with any further notices or publications in respect of this review.

Changes to FSA Handbook – income withdrawals and short term annuities

Conduct of Business sourcebook : Post implementation review


The FSA’s Agenda for Fighting Financial Crime in 2009

At the BBA Annual Financial Crime conference in November 2008 Philip Robinson, Financial Crime & Intelligence Division Director at the FSA, spoke about how firms’ reactions to the credit crunch may affect their vulnerability to financial crime. There are a number of key issues highlighted within the speech which we feel will be useful reminders to Paradigm Partner firms. Mr Robinsion explains that whilst we have seen a number of unprecedented events in the global financial landscape there have also been constants in that criminals are still out there and still want to steal from firms; gaining management agreement to use part of the budget for financial crime is always difficult not to mention when purse strings are even tighter; and demonstrating a favourable outcome from prevention activity continues to be a challenge. Despite the recent market turbulence Robinson makes a point about the continued effort and focus in the FSA’s strategic aim to promote efficient, orderly and fair markets. He emphasised that the FSA’s fight against financial crime has not been forgotten. During the speech the Financial Crime & Intelligence Division Director highlighted the breakdown in operation risk management at Societe Generale in January ’08 which resulted in net losses for the company of €4.9 billion. All of this was believed to be down to one ‘rogue-trader’. Issues relating to the firms internal governance and systems and controls where highlighted including corporate culture; quality and relevance of Management Information; segregation of duties and IT security. Robinson emphasised the fact that evidencing strong internal governance procedures is one of the key elements in demonstrating that firms are taking their responsibilities seriously in the fight against financial crime. Furthermore he stated that “an organisation without a fraud adverse culture is likely to have higher levels of fraud risk”. He stressed the importance of not cutting back on operational risk management especially in light of recent market turbulence. He continued by explaining that one of the key financial crime risks is a failure to protect customers’ personal information. The FSA’s review of firms’ practices published last April highlighted inadequate information security controls about which the FSA voiced its concerns. Philip reminded firms that only recently the FSA had, for the first time, prosecuted a mortgage advisor for providing false information in an application for approval or authorisation. As part of its role as gatekeeper the FSA have been encouraged by many in the industry to maintain the effectiveness of the approved persons regime. He explained that this regime relies on the disclosures that people make of which many have been checked by the FSA. Firms should be aware that over the last year the FSA have subjected a significant sample of people applying for approved person status to a Criminal Records Bureau check. Additionally the FSA has seen an increase in the amount of people of “doubtful integrity” attempting to buy controlling stakes in smaller firms. Philip clearly suggests that vendors and advisers are clear about the source of funds of any potential purchaser. With regards to Financial Sanctions, Robinson highlighted the fact that a key weakness found as part of the FSA’s review was that when dealing with customers of another FSA authorised firm, a lot of firms assumed that their counterparties had already carried out sufficient checks, and did not take the necessary steps to satisfy themselves that this was in fact so and that these checks were adequate. In particular some small firms believed that financial sanctions checks were not required because they did not hold client money or make third party payments. Robinson emphasised an important point relating to weaknesses in anti-financial crime systems and controls. He explained that whilst firms may have high level policies in place, there are sometimes inadequate detailed procedures which lead to poor understanding by staff about how to comply with these requirements. It is vital that customer facing staff understand their responsibilities in relation to anti-financial crime and that the appropriate compliance culture is embedded throughout the firm. Firms may be aware that recently the FSA has asked for their assistance in the fight against mortgage fraud. This is reiterated within the speech. Robinson explains the importance of firms, the police and regulators working together to identify and eradicate suspect mortgage intermediaries. The speech concludes with some commentary about consumer protection. This is of course the ultimate goal. By improving communications to consumers and making people aware of the risks thus enabling them to be one step ahead can only assist in building and maintaining consumer confidence in somewhat uncertain times.


Reviewing the situation – why the time is right for pension reviews There’s no longer such a thing as a ‘job for life’. Today’s school leavers can expect to have up to a dozen jobs in their working lives, compared with an average of seven for people currently at retirement age.* It’s therefore becoming increasingly common for clients to have several pension pots with a number of different companies. As a result, some may have lost track of their pension savings – it’s estimated that £3 billion in pension benefits has gone unclaimed.** This means that people could be missing out on some of the income they’re entitled to when they reach retirement age. With the current economic uncertainty and volatile market conditions, consumers are becoming more concerned about their long-term financial security – which offers the perfect opportunity to help them review their pension savings options.

Review time Our research shows that the main reasons people transfer their pensions are to consolidate them or to achieve better investment performance.† Some people may simply want to ‘tidy up’ their pension savings to find out what their existing benefits are worth and what level of retirement income they can expect. Others may have contributed to a company pension scheme in the past, but no longer do so and as a result feel cut off from the way their pension is managed. Alternatively, they may not have had access to an employer pension scheme and instead built up a succession of private pension pots. No two clients have the same needs, and everyone has different future aspirations and attitudes to risk. When it comes to pensions, one size doesn’t fit all, so it’s important to find the right solution for each unique customer.

Finding the right solution Reviewing your clients’ pensions is an opportunity to look at new ways to invest their savings, whether by transferring to a new pension product or consolidating multiple plans. When you’re reviewing your clients’ situations, our Flexible Pension Plan (FPP) can help by offering a range of options that can be adapted to the individual. Whether your clients are cautious or adventurous investors, our FPP has a solution for them. There’s also a self-investment option that can be ‘switched on’ when it’s needed, and your clients are only charged for it at that stage. And if they do choose the self-investment option, our FPP can now accept protected rights funds. In light of the recent credit crunch, reviewing your clients’ pensions savings is even more of a priority. Make sure they don’t lose out by taking a short-term view of their long-term savings. To find out more about our FPP, go to www.aegonse.co.uk/fpp, contact your AEGON Scottish Equitable consultant or call your access account manager on 0845 61 000 61.

*Moneywise, June 2007 **www.unclaimedassets.co.uk

†AEGON pension transfer survey report, July 2007

Pension Reviews

http://www.aegonse.co.uk/fpp�

http://www.unclaimedassets.co.uk/�

PARADIGM TECHNICAL SERVICES An integral part of Paradigm Compliance is Paradigm Technical Services. Our experienced, Head Office based team complements the service offered by our field based Paradigm Business Consultants and is and is on hand to offer assistance and guidance with the following:

• All various day-to-day compliance queries • Financial Promotions • Technical queries • Remote File Reviews • RMAR completion • FSA Applications (including Change of Entity • Complaints Guidance / Variation of Permissions / Approved Persons)

Available between 9.00am and 5.00pm Monday to Friday.

The Technical Services team can be contacted as follows:

General Enquiries Financial Promotion Submissions Remote File Review* • Email: • Email: • Email: [email protected] [email protected] [email protected] Telephone 0845 620 1998 Fax 0845 303 8333

*Please note that the Remote File Review service is only available via prior arrangement with your Paradigm Business Consultant.

This newsletter has been prepared with all possible care to ensure it's accuracy. It is based on our current understanding of legislation and Inland Revenue practice and is supplied to Paradigm Partner Firms purely for their information, not for presentation to clients. Neither Paradigm Partners LLP nor any of its partners or employees can accept responsibility for any errors or omissions.

Paradigm Partners LLP. Registered in England and Wales. Company No: OC323405. Registered Office: Paradigm Partners LLP, Paradigm House, Brooke Court, Wilmslow, Cheshire, SK9 3ND. Paradigm Partners LLP is a Limited Liability Partnership.


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