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How to Design Your T&C Proposition for the Post RDR World John Williams Principal, Skillfit...
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Transcript of How to Design Your T&C Proposition for the Post RDR World John Williams Principal, Skillfit...
How to Design Your T&C Proposition for the Post RDR World
John WilliamsPrincipal, Skillfit Solutions
How to Design Your T&C Proposition for the Post RDR World
•Why Have a T&C Scheme
•RDR – T&C Impact
•T&C for the Post RDR World
• Competence
• CPD
• New Beginners
•Questions
Why Have a T&C Scheme?
Regulatorycompliance
Commercialbenefit
Why Have a T&C Scheme?
Regulatorycompliance:•Risk mitigation•Customer fairness•Minimum standards•One size fits all
Commercialbenefit:•Customer experience and value•Business model•Competitive advantage
RDR – T&C ImpactCompetence• Focus on ‘competence’ and who is responsible
• Training is just one of the solutions
Professionalism• Appropriate Qualification
• Level 4
• CPD• Explicit and formal requirement
• Independent Verification• Role of Accredited Body• SPS• APER compliance
RDR – T&C ImpactCompetence Measurements• Qualification time limit
• CPD – hours and type
Data Capture and Reporting• Professional Standards data
• Quarterly reporting
Notifications• Significant events
• Competence and supervision failings
• APER compliance failure
RDR – T&C Impact
Is This Good Enough for the Post RDR World?• Entry level standard
• One size fits all
• Monitoring to avoid failure
Questions for you
• Firms’ responsibilities?
• Business and advice model?
• Professionalism?
• Will this be right for your customers?
RDR – T&C Impact
“Firms should ensure that their systems
and controls, including competence of employees, keep pace with any changes in their strategy and business model and with any new services the firm is offering”
FSA’s Retail Conduct Risk Outlook 2012
T&C for the Post RDR World
Commercial Benefit
• Customer experience and value
• Business model
• Competitive advantage
T&C for the Post RDR World
Commercial Benefit
• Customer experience and value
• Business model
• Competitive advantage
…. Delivered through the Quality of Your People!
T&C for the Post RDR World
Competence•Defined as:
Knowledge ~ Skills ~ Expertise ~ Ethics
T&C for the Post RDR World
Competence•Defined as:
Knowledge ~ Skills ~ Expertise ~ Ethics
• In the context of YOUR:• Business model
• Services offered
• Customers
• Reputation
T&C for the Post RDR World
Competence Define Standards
T&C for the Post RDR World
Competence
• Core• Firm Specific• Application• Qualification
T&C for the Post RDR World
Competence
• Advice Process• Information
Management• Technology
• Core• Firm Specific• Application• Qualification
T&C for the Post RDR World
Competence
• Fairness• Conduct• Customer
Experience
• Advice Process• Information
Management• Technology
• Core• Firm Specific• Application• Qualification
T&C for the Post RDR World
Competence•Assessment – Robust, Meaningful and Current
• Evidence
• Confidence
•Supervisors• Development required?
• Critical skills – observation / coaching / feedback
•KPI Framework• Business model changes
• New risks
• Data or Information?
T&C for the Post RDR World
Competence – Resources
• On-line competence systems
• National Occupational Standards – Financial Planning
• PFS – Pathways guides
• FSA Resources for SME firms – fact sheets, guides,case studies, good practice, etc.
• Financial Skills Partnership – T&C Guidance
T&C for the Post RDR World
CPDSome Questions
Maintenance or Development?
What to use?
How much is enough?
Where to get it from?
Who decides?
What evidence should I keep?
T&C for the Post RDR World
CPD•Who decides?
• Individual – APER
• Firm – SYSC competent employees rule
• Accredited Body – independent verification
T&C for the Post RDR World
CPD – How to Decide•Gap-fill is the way forward!
• Current competence standards
• Current performance record
• Self-appraisal
• Performance review
• Performance evidence e.g. KPIs, test results, customer feedback etc.
• Performance development
• Development plan – ideally quarterly cycle
T&C for the Post RDR World
CPD for Professionals
•Select carefully – there is plenty of choice!
•It has to be relevant to qualify – but all CPD doesn’t have to qualify!
•Complete the development process
•Maintain the evidence you need
•Work closely with your Accredited Body
T&C for the Post RDR WorldT&C for Beginners
•Trainee financial advisers:
• Recruitment
• Training
T&C for the Post RDR World
T&C for Beginners – Trainees
T&C for the Post RDR WorldT&C for Beginners – Trainees
Factors which make this more difficult:
• New standards
• Longer lead-in time
• Higher costs
• Smaller talent pools
• Increased risk
T&C for the Post RDR WorldT&C for Beginners – Trainees
•Career structures
•New adviser programmes e.g. Financial Adviser School
•Graduate programmes• Financial services degrees
• Graduate Foundation College
• Internships
•Resources• PFS Pathways
• Directions website
T&C for the Post RDR World
“....where our judgement is that a particular aspect of a firm’s business model – its product selection, its remuneration
practices, its training or recruitment for instance – is likely to give rise to poor customer outcomes. We won’t wait to
see if those outcomes occur.”
Tracy McDermott, Director of Enforcement and Financial Crime, FSA
T&C for the Post RDR World
Any Questions?
