Focus: Constructive Advocacy
Annual Report 2024
The Future of UK Transaction Reporting: Penalties, Perspectives and Predictions
What does effective Transaction Reporting really look like and where are firms still getting it wrong? In this episode, PIMFA’s Maria Fritzsche and Kaizen’s Matthew Vincent join host David Ostojitsch to share expert insights, with a focus on how smaller firms can manage their reporting obligations more confidently and make better use of technology to stay compliant. Whether you’re a compliance officer or part of...
What does effective Transaction Reporting really look like and where are firms still getting it wrong? In this episode, PIMFA’s Maria Fritzsche and Kaizen’s Matthew Vincent join host David Ostojitsch to share expert insights, with a focus on how smaller firms can manage their reporting obligations more confidently and make better use of technology to stay compliant.
Whether you’re a compliance officer or part of a regulated firm, this episode offers actionable insights to support your reporting obligations and avoid costly mistakes.
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Transaction Reporting
The obligation for firms to report details of financial transactions to ensure market transparency and integrity.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
PIMFA Transaction Reporting Academy Session Overview
PIMFA welcomes new appointments Richard Flynn and Derek Miles to its Board
Richard Flynn is the Managing Director of Charles Schwab and an experienced financial professional with over 20 years of experience in equity markets, with specialisms in US investing and the delivery of financial advice. He has been with Charles Schwab for over 15 years and for the last seven years has served as Chief Executive of its UK retail business – Charles Schwab UK. Prior to joining Schwab, Richard graduated in Business & Law from University College Dublin and has worked in several financial firms such as Fisher Investments UK, Close Brothers Asset Management and Cornmarket Group Financial Services.
Derek Miles is the Chief Executive Officer of Titan Wealth Planning with over 25 years’ experience in strategic financial planning across various roles in the financial services sector. Appointed as Titan Wealth Planning’s CEO in 2022, Derek has previous experience at LEBC Group and as Founder and Managing Director of Aspira Corporate Solutions for seventeen years prior to that.
Richard Flynn, Managing Director, Charles Schwab said: “I am delighted to be joining the Board. PIMFA has a critical role to play – especially at this time of rapid change and innovation for our industry stemming from the challenging political and economic landscape – not to mention the evolving needs and demands of clients and regulators. I look forward to collaborating with Liz, the Board, and the team at PIMFA to address the challenges and opportunities head on to help build a flourishing future for our sector.”
Derek Miles, Chief Executive Officer, Titan Wealth Planning said: “I look forward to working with PIMFA and focusing our efforts on delivering value and keeping front of mind what matters most to our members and their clients. With so much volatility and change worldwide, we must ensure the sector remains robust and that we are able to position members to be able to deliver the value and confidence clients deserve and need for their financial lives.”
Liz Field, PIMFA Chief Executive said “I am pleased to welcome Richard and Derek to our board and look forward to working with them in the years to come as we continue to make impactful change as the voice of the industry. Their knowledge and passion for the industry, alongside their considerable experience and expertise, are huge assets to PIMFA. Both new Board members are fully aligned with our ambitions to build a culture of financial health that helps our member firms and their clients to thrive.”
ENDS
NOTES TO EDITORS:
Richard Flynn, Charles Schwab
Derek Miles, Titan Wealth
About PIMFA
PIMFA (The Personal Investment Management & Financial Advice Association) is the trade association for firms that provide wealth management, investment services, and financial advice and planning to everyone from individuals and families to charities, pension funds, trusts and companies.
The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.
PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including wealth management, financial advice and planning, as well as investment and execution services. They assist everyone from individuals and families to charities, pension funds, trusts and companies. Associate members provide professional services to the PIMFA community.
PIMFA leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena.
Our mission is to help create a UK culture of thriving financial health through constructive advocacy, creating connections and practical support.
PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991 – read more.
Further information can be found at pimfa.co.uk
Contact
For further information on this release or other press matters please contact:
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869 / +44 (0)7979 493225
Financial services leaders outline four key pillars to unlock UK growth potential
- A new report from PIMFA, UK Finance and KPMG UK finds that simpler and more predictable regulation, clearer tax policies and improved financial literacy will help drive growth and innovation in the UK’s private banking and wealth management sector.
- Leaders are calling for reforms which can unlock the full potential of a sector managing over £1.6 trillion in assets and supporting more than 4 million clients.
- It finds the sector is ready to help deliver national priorities – including long-term investment, improved financial education and smarter use of technology – but only if key barriers are addressed.
20 May 2025, London – A new report from PIMFA, UK Finance and KPMG UK has revealed opportunities for how the government can further support the UK’s Private Banking and Wealth Management (PBWM) sector in helping to deliver growth, provided four key barriers can be addressed. This comes at a critical time as the Chancellor prepares her growth and competitiveness strategy for financial services.
Based on interviews with Chief Executives and senior leaders from across PBWM, financial advice and related services, “UK Private Banking and Wealth Management: Harnessing the Sector to Deliver Economic Growth” outlines the reforms required to unlock the sector’s full potential. The findings reflect a clear industry consensus that the sector is not only equipped but also eager to support the government’s growth ambitions. However, this potential will remain untapped unless underlying structural challenges are addressed.
Four key priorities for reform
The report outlines four key priorities for reform that industry leaders say are essential to unlocking the sector’s full potential and helping deliver long-term, inclusive growth across the UK economy.
- Fairer and more proportionate regulation: Policymaking and supervision should be more predictable, consistent, and supportive of the industry, along with closer collaboration between the Financial Conduct Authority (FCA), Financial Ombudsman Service (FOS) and Financial Services Compensation Scheme (FSCS), and further promotion of the sector’s positive contribution.
- Embracing innovation and smarter compliance: The sector is increasingly focused on how emerging technologies like AI can enhance client outcomes. With further support to manage compliance costs and strengthen firms’ investment capabilities, there is significant potential for growth. The government can play a key role by supporting incentives that boost investment and broaden retail participation in financial markets.
- A clearer, more stable tax environment: There is a valuable opportunity to build greater confidence by providing more certain and predictable tax policies and clearer direction. A well-signposted tax roadmap and targeted incentives would encourage long-term saving and wealth-building, attract global capital, and support early-stage UK business growth.
- Strengthening financial literacy: A persistent and critical gap in financial literacy remains a key concern for industry leaders. Improving financial literacy can unlock greater engagement with advice and better decision-making. This can involve embedding financial education across the curriculum and promoting public awareness.
Liz Field, Chief Executive at PIMFA, said: “We welcome recent signals from government and regulators around growth and competitiveness, but there’s a concern across our sector that without a more stable, proportionate, and joined-up policy environment, we risk missing a vital opportunity to unlock investment, drive innovation and promote greater financial resilience across society. Now is the time to go further, faster, and unlock the potential within the wealth management, financial advice and planning sector to unlock the growth we all want to see.”
Eric Leenders, Managing Director of Personal Finance at UK Finance, added: “This report provides a clear roadmap for how the wealth management and private banking sector can partner with government to drive growth. It also makes clear that if we want more people to benefit from financial advice and long-term investing, we need to remove barriers, modernise regulation and really invest in improving financial literacy.”
Daniel Barry, Partner at KPMG UK, said: “While recent government and regulatory initiatives to promote the sector’s growth and competitiveness are welcome, the report highlights the need to do more. But this isn’t just about driving economic growth, it’s about supporting individuals to achieve their financial goals. As risks to the UK’s financial stability are rising, the government has a significant opportunity to instil greater confidence among sector leaders at a time of great uncertainty and geopolitical volatility. Policymakers, supervisors and the sector must work together to both safeguard it and deliver growth.”
The Lord McNicol of West Kilbride, Iain McNicol, commented on the launch of the paper, saying: “The Private Banking and Wealth Management sector is a major contributor to UK economic growth. It boosts productivity and prosperity, and as such has a vital role to play in advancing the government’s growth agenda. So I’m delighted to see this report put forward a constructive set of proposals for how the sector can contribute further, and to commit to working closely with the government to make this growth a reality.”
The findings of the report suggest a sector that is both ambitious and aligned with the country’s broader growth agenda, ready to partner with government, regulators and the public to build a more inclusive, resilient and prosperous financial future.
ENDS
NOTES TO EDITORS:
Methodology
PIMFA, UK Finance, and KPMG UK engaged Chief Executives and Board-level representatives from 19 firms that constituted a broad cross-section of the Private Banking and Wealth Management sector, including wealth managers, financial advisers, financial planners, distributors (including platforms), and private banks.
The information gathered from interviews with each stakeholder has been anonymised and aggregated into the views expressed in the paper. This has been supplemented with additional publicly available data and observations, as well as proprietary research from PIMFA, UK Finance, and KPMG UK.
The views, opinions and proposed actions and approaches expressed herein are those of PIMFA, UK Finance and their members and do not necessarily represent the views and opinions of KPMG.
About PIMFA
The Personal Investment Management & Financial Advice Association (PIMFA) is the trade association for firms that provide wealth management, investment services and financial advice.
Our members offer a range of financial solutions, including financial advice, portfolio management, and investment and execution services. They assist individuals, families, charities, pension funds, trusts, and companies. Our sector manages £1.65 trillion in private savings and investments and employs over 63,000 people.
Further information is available at: www.pimfa.co.uk
About UK Finance
Representing 300 firms, we are a centre of trust, expertise and collaboration at the heart of financial services. Championing a thriving sector and building a better society. The financial services industry plays a vital and often underappreciated role in enabling individuals, families and communities to achieve their ambitions in a safe and sustainable way – through home ownership, starting a new business or saving for retirement.
The sector is fundamental to people’s lives, and we are proud to promote the work it is doing to support customers and businesses up and down the country. Whether it is through innovating for the future, driving economic growth, helping struggling customers amid increases in the cost of living, fighting economic crime or working to finance the net zero transition – the industry is having an overwhelmingly positive effect on the lives of people across the UK and improving the society we live in.
Further information is available at: www.ukfinance.org.uk
About KPMG
KPMG LLP, a UK limited liability partnership, operates across the UK with approximately 17,000 partners and staff. The UK firm recorded a revenue of £2.99 billion in the year ended 30 September 2024.
KPMG is a global organisation of independent professional services firms providing Audit, Legal, Tax and Advisory services. It operates in 143 countries and territories with more than 275,000 partners and employees working in member firms around the world. Each KPMG firm is a legally distinct and separate entity and describes itself as such. KPMG International Limited is a private English company limited by guarantee. KPMG International Limited and its related entities do not provide services to clients.
Building a diverse future in finance – Verve
PIMFA Response to FCA CP25/8: Data Decommissioning – removing reporting and notification requirements
PIMFA Response to FCA Paper CP25/7 – FCA regulated fees and levies: rates proposals for 2025/26
Joint Financial Services trade association letter regarding the Home Office ransomware proposals
Ongoing servicing: FCA findings for firms
The FCA’s commentary on ongoing servicing is something that we’ve all been talking about for a long time, and the findings have finally been released from the sample of advice firms reviewed.
The study found that in 83% of cases, ongoing reviews were carried out in line with service propositions; in 15% of cases clients had declined or not engaged with the request for information to conduct a review, while in 2% of cases firms had made no effort to conduct the review as part of the ongoing service the client was paying for.
Firms should take a sample of their own ongoing service clients to review and draw conclusions: are you meeting service standards, and if not, what are the next steps?
How firms can review their own ongoing servicing
When reviewing ongoing servicing, firms should take an original sample of ongoing service clients, ensuring it is representative of overall time periods, advisers, client type (accumulation/decumulation), service level, changes to systems or software and any acquisitions.
You should keep a record of the sample reviewed and your methodology used.
As part of your firm review, you should consider:
- Where was the service set out? Terms of Business, Client agreement, suitability reports?
- What did you agree to? Ongoing reviews? Frequency? Who was responsible for initiating them?
- Did you do what you said you would do? If you didn’t, why? Did the client decline a review, no response, no firm action?
- What was done as a result? Was the service agreement clear on the action taken for non-delivery and was action taken in line with this?
Ensure that your findings of the review are recorded and retained on file.
If you fall into the 83% of firms where you have met your service standards, and no redress is due, great!
Ensure that you keep a record of these findings and the work you have carried out on file and update your systems and controls document to reflect this.
What should firms do if redress is appropriate?
If you have deemed redress to be appropriate, are you comfortable with what the next steps are and how to calculate the redress due?
Questions to ask around redress include:
- Is it calculated on a pro-rata basis? A client may not have had a review, but what did the rest of your ongoing service cover e.g performance reviews, arranging transactions, other contact throughout the year?
- Do you consider the ongoing review to be the full service and therefore a full refund is due?
- Have you considered lost investment growth, interest or any consequential losses (change in circumstances that would have changed the recommendation)?
Ensure all these factors are considered and you have a consistent firm approach to calculating this redress going forwards.
It’s unlikely that PI will cover any redress due for lack of service, so ensure that you have sufficient capital held to cover the liability.
Next steps for firms reviewing ongoing servicing
After reviewing your ongoing servicing and drawing conclusions, the next steps are:
- Ensure that your service proposition, cost and frequency of reviews is clear and disclosed in the terms of business.
- Keep a clear scheduling review process and evidence it. Are there limitations within your back office in terms of providing this data? Have you identified a training need? Now is the time to fix this as this will be key MI data going forwards.
- Define a process to monitor the quality of your reviews and ensure consistency e.g. reassessing risk (attitude to risk, capacity for loss).
- Get a clear non-interaction policy in place. Do you do desk-based reviews? After 1 year? 2 years? Not deem them appropriate? How are you re-confirming client objectives? Disengage unresponsive clients? Record the rationale behind this policy.
- If you disengage – think about vulnerabilities and solutions that don’t require an adviser.
- If making a refund of fees ensure you keep a record of this.
- Good record keeping; are clients receiving written output?
- MI – ensure this is continually monitoring quality and delivery of reviews.
In addition to this, as part of Consumer Duty, firms should be consistently monitoring if clients with ongoing servicing actually benefit from the service, or alternatively if they’re in the correct service level (for example, if a client has a lot of AUM in a top level of service but actually only has simple needs, their service level may need a review).
Suggestions for firms performing desk-based reviews
I also suggest firms consider their approach to desk-based reviews. Questions to ask around desk-based reviews include:
- How confident are you that the information you have is up to date?
- What if there was an update to client circumstances that you are unaware of and would immediately alter the recommendation; can you do a review and confidently confirm your recommendation is still suitable?
- How do you address these potential issues; do you work with the client to engage before you can do a review?
- Or do you deem the client not engaged and disengage with them?
If you do provide desk-based reviews, ensure that you clearly state that it is based on the information you have and anything you are unaware of may change your advice. If you do disengage with a client, consider any vulnerabilities clients have or this may cause.
What’s next from the FCA?
The FCA will be monitoring the work firms have done on carrying out their review of this ‘later in 2025’. Going forwards, the FCA will be working on these rules and has committed to policy work in 2025, and in 2026 will be doing data led supervision. Ensure that as a firm you’re not resting on your laurels and are proactive with your work on this.
This could be interesting given the current climate, the engagement of younger people who aren’t as engaged with meetings as other generations and want to rely on tech more; could we see scope for lighter touch services in the future?
For support with Consumer Duty, ongoing services or any other issues discussed in this article, contact Alanis Daniel at Verve using alanis.daniel@weareverve.co.uk.
Alanis Daniel
Compliance Consultant at Verve
From Fines to Regulation: Understanding the FCA’s Approach to Financial Crime with Daren Allen, Shoosmiths
In this episode, host Philip Allen sits down with Daren Allen, a partner in the Dispute Resolution and Litigation team at law firm Shoosmiths, to discuss the latest trends in financial crime and enforcement actions taken by the FCA in 2024, offering insights for PIMFA member firms on what to expect in 2025. Topics covered in this episode include the FCA’s ongoing focus on combating...
In this episode, host Philip Allen sits down with Daren Allen, a partner in the Dispute Resolution and Litigation team at law firm Shoosmiths, to discuss the latest trends in financial crime and enforcement actions taken by the FCA in 2024, offering insights for PIMFA member firms on what to expect in 2025.
Topics covered in this episode include the FCA’s ongoing focus on combating financial crime despite fewer regulatory investigations and fines, the new legislation regarding fraud, and the importance of building a robust culture of compliance. Daren emphasises the necessity of thorough risk assessments, appropriate resources, and effective governance to avoid regulatory scrutiny. He also touches on the role of AI in financial crime prevention and anticipates increased FCA visits and skilled person reviews in the upcoming year.
Timestamps
00:00 Introduction to Financial Crime Trends
00:56 FCA Enforcement Data and Trends
02:34 Fraud Compliance for PIM Firms
04:38 Risk Assessments and Procedures
06:52 Regulatory Scrutiny and Penalties
10:42 Governance and Culture in Compliance
17:13 Future of Financial Crime Prevention
21:26 Conclusion and Key Takeaways
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Financial Crime
Protecting against activities like fraud, money laundering, and market abuse, threatening financial system integrity and consumer protection.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
The purpose of the Regulatory Board Sub Committee is to advise PIMFA on all regulatory matters of significance to its...
About Us
More about PIMFA
PIMFA Members
PIMFA’s membership is corporate and consists of two groups – Full and Associate member firms.
Full members provide a range of financial solutions including wealth management, financial advice and planning and execution services. They assist everyone from individuals and families to charities, pension funds, trusts and companies. Associate members provide professional services to the PIMFA community.
Corporate Social Responsibility/Sustainability
Taking environmental, social and governance (ESG) issues into account is an important consideration for PIMFA.
As a small business we work to be as sustainable as possible and acts as champion for the issues across the industry, helping our members grapple with the ongoing developments in this area.
Environmental
PIMFA is committed to reducing our carbon footprint and delivering our services to our members in an environmentally sustainable manner.
Social
This is an area of strategic focus for PIMFA making sure we are championing a high standard the future of the association and the industry more widely.
View more of our work in this area.
Governance
Read PIMFA’s governance rules.
Read PIMFA’s membership rules.
Find out more about PIMFA’s Board.
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Sustainable Finance and ESG
Integrating environmental, social, and governance factors into investment decisions to promote long-term positive impact.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
ASG Meeting Notes 13 November 2024
PIMFA calls for 12-month delay to implementation of Sustainability Disclosure Requirement rules for Portfolio Management
17 June 2024
PIMFA calls for 12-month delay to implementation of Sustainability Disclosure Requirement rules for Portfolio Management
PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry, has called on the Financial Conduct Authority (FCA) to delay the deadline for the implementation of Sustainability Disclosure Requirements (SDR) for portfolio management by 12 months, in order to allow firms sufficient time to implement the final rules.
While PIMFA is supportive of the intended purpose and spirit of the proposals put forward by the FCA, they fail to sufficiently take account of the unique requirements of the market for portfolio management and of retail investors.
In its response to the Regulator’s consultation, PIMFA has highlighted its significant concerns around the timing of the implementation. PIMFA has significant concerns regarding some of the proposals put forward by the Regulator and given those concerns, considers it may be unrealistic to believe the final SDR rules for portfolio management will be agreed by October. Even if they are, the final implementation deadline of 2 December does not provide adequate time for firms.
This would create a significant challenge for firms, placing considerable regulatory burden on them to complete structural work to meet the requirements for extending SDR to portfolio management in only six weeks.
PIMFA believes it is important to allow the SDR fund regime to embed properly, as the pace of implementation of the first tranche of SDR rules will influence portfolio management firms.
Firms in our sector will find it challenging to continue to work with some smaller fund houses and have them represented in their portfolios because these have not met the SDR labelling standards yet and will not adopt the labels for another year or two. This would unintentionally reduce choice of investments for portfolios and may affect end client outcomes.
Additionally, PIMFA is calling on the FCA to reconsider including bespoke portfolios in the SDR regime. Bespoke portfolios are not products, they are services, and more clarity is needed on how firms would be expected to apply a product label to a service-based investment approach.
PIMFA would also like to see the Regulator provide more clarity around the inclusion of overseas funds which are currently out of scope of the SDR and the role of portfolio manager when including them in portfolios. The current proposals make it difficult for investors to understand why SDR applies to some funds but not others making it difficult for them to make informed decisions.
Further, PIMFA would like to see the 70% threshold for labels lowered to avoid any unintended consequences for portfolio managers and avoid potential confusion that a lower risk portfolio cannot be sustainable. Portfolio managers may have a sustainable label for their higher risk portfolios (which will be heavily weighted towards equities) but not for their lower risk portfolios. This could be the case even though the underlying assets were the same, just in different weightings. This would imply that sustainable labels are only for higher risk (and higher return) portfolios.
Maja Erceg, Senior Policy Adviser EU and Government Affairs, PIMFA at PIMFA commented: “We are broadly supportive of the work the FCA is doing around SDR but the timing to agree the rules for portfolio management firms let alone implement them is not merely challenging, it is close to impossible.
“We have specific concerns around both the timeframe as well as labelling, which could cause confusion for retail investors, making it difficult for investors to understand why SDR applies to some funds but not others, such as overseas funds. This will make it challenging for consumers to make informed decisions about their investments.
“It is vital that these rules are agreed and implemented correctly. In order for these proposals to successfully meet the policy objectives, we strongly believe that it would be better to delay the implementation period by 12 months in order to give firms the time to comply with these rules.”
<ENDS>
NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
• Read PIMFA’s agenda: ‘Creating a UK Culture of Thriving Financial Health’ here.
• PIMFA is the trade association for firms that provide wealth management, investment services and the investment and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.
• The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.
• PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including financial advice, portfolio management, as well as investment and execution services. They assist everyone from individuals and families to charities and pension funds, all the way to trusts and companies. Associate members provide professional services to the PIMFA community.
• PIMFA leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena. Our mission is to create an optimal operating environment so that its member firms can focus on delivering the best service to clients, providing responsible stewardship for their long-term savings and investments.
• PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991.
Further information can be found at pimfa.co.uk
• Visit PIMFA’s public affairs web area here.
Constructive Advocacy
As the voice of the industry, PIMFA champions our members to key stakeholders such as regulators, policymakers, business leaders, media and consumers.
Through our renowned compliance, regulatory and public affairs work, we work to actively educate and positively impact perceptions of our sector. We promote our sector as a force for good to help build a thriving culture of financial health and a culture of saving and investment in the UK.
We also promote access and nurture innovation by leading the way in developing best practice across the industry in areas of change and advancement such as digital transformation, DE&I and ESG.
Click below to read our 2024/25 successes report
Click below to read a summary of our 2024/25 successes
Navigating Financial Crime Risks: Insights from PIMFA Conference and Beyond
In this episode, PIMFA’s Philip Allen is joined by financial crime consultants Holly Avent and Poppy Penson from Avyse Partners to unpack the critical insights shared at PIMFA’s 2025 financial crime conference. The discussion covers various topics, including the increasing prevalence of cyber threats, the significance of effective and interactive training programs to change behaviour, and the impact of forthcoming regulations, such as the ‘failure...
In this episode, PIMFA’s Philip Allen is joined by financial crime consultants Holly Avent and Poppy Penson from Avyse Partners to unpack the critical insights shared at PIMFA’s 2025 financial crime conference.
The discussion covers various topics, including the increasing prevalence of cyber threats, the significance of effective and interactive training programs to change behaviour, and the impact of forthcoming regulations, such as the ‘failure to prevent fraud offence’. Our guests also emphasise the importance of maintaining a robust AML framework, the benefits of independent reviews and conducting mock regulatory visits to assess the effectiveness of your firm’s measures to prevent and detect money laundering activities. Practical advice and tools, such as gap analysis templates provided by Avyse Partners, are discussed to help firms stay ahead of financial crime risks.
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Financial Crime
Protecting against activities like fraud, money laundering, and market abuse, threatening financial system integrity and consumer protection.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
The purpose of the Regulatory Board Sub Committee is to advise PIMFA on all regulatory matters of significance to its...
The MSCI PIMFA Private Investor Index Series
This index series has been in existence since 1997 (under different names) and consists of five composite indexes and includes weightings of Equities, Fixed Income, Real Estate, Cash and Alternatives.
There are five composite indices , to reflect the differing aims of investors
- the Conservative index
- the Income index
- the Growth index
- the Balanced index and
- the Global Growth index
This Index Series can provide
- A basis for discussing and reviewing the asset allocation and structure of your portfolio with your fund manager or stockbroker.
- A benchmark for assessing and comparing the performance of discretionary fund managers.
- A measure to compare the performance of similar Income, Growth and Balanced based funds.
Helpful Resources
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Indices
Used properly, an index series can provide a useful perspective in the world of stocks and shares to compare portfolio performance. PIMFA provides the methodology for the MSCI PIMFA Private Investor Index Series and Equity Risk Index Series and you can find out more information here.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
This committee is responsible for ensuring the current asset allocations of the PIMFA / MSCI Private Investor Index and the...
The MSCI PIMFA Equity Risk Index Series
This series was launched on 1st November 2019 following the changing demands of the market and our members.
It consists of five composite indices and includes weightings of equities, bonds, real estate and “alternative” investments based on the strategic asset allocations (SAA) of PIMFA member firms grouped by the percentage of equities held in the strategies.
The Equity Risk Index Series has five composite indices, to reflect the differing aims of investors
- Equity Risk 1 Index (RBI 1) – Equity 10 – 25%
- Equity Risk 2 Index (RBI 2) – Equity 26 – 46%
- Equity Risk 3 Index (RBI 3) – Equity 47 – 66%
- Equity Risk 4 Index (RBI 4) – Equity 67 – 85%
- Equity Risk 5 Index (RBI 5) – Equity 86 – 100%
This Index Series can provide
- Risk characteristics to align to client risk profiles more readily.
- These represent the strategic asset allocations of member firms to help firms/individuals understand long term strategy of the UK market.
- Created due to demand from member firms who wished to see a new range of indices based on this new methodology.
Helpful Resources
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Indices
Used properly, an index series can provide a useful perspective in the world of stocks and shares to compare portfolio performance. PIMFA provides the methodology for the MSCI PIMFA Private Investor Index Series and Equity Risk Index Series and you can find out more information here.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
This committee is responsible for ensuring the current asset allocations of the PIMFA / MSCI Private Investor Index and the...
Strategic, sustainable and selective: 3 ways to manage retirement income
Retirement income, and certainly generating a sustainable income, is a very different kettle of fish when compared to investing where long-term growth is the primary objective; at the very least there are additional considerations around risk, capacity for loss, investment performance (returns and volatility) and investment philosophy.
There are three main ways to manage flexible pension drawdown for income. There is also no right answer as all three methods have their own benefits and drawbacks that should ideally be linked to the client’s circumstances; also not forgetting the role that annuities can play, which we will cover later.
Method 1: Safe withdrawal rate
The first method is the tried and tested ‘safe withdrawal rate’ where retirees should theoretically be able to draw down 4% of the value of their invested pension per annum from a balanced portfolio (60:40 equities and bonds) without it affecting the capital.
The main benefit is that this method is simple to set up and manage – less time spent on managing nuances within this drawdown process in turn means it costs less to deliver. Coupled with the fact that the concept is relatively easy for the client to understand (hello Consumer Duty), particularly if they’re lacking knowledge and experience.
The main drawback is that it doesn’t address sequencing risk, meaning that the strategy is more susceptible to ‘pound cost ravaging’ (i.e. having to sell a greater number of fund units to achieve the same level of cash income once sold) in falling markets.
This style of strategy typically lends itself to clients who have relatively straightforward income needs from a single wrapper; or for those clients who are not looking for a long-term sustainable income and looking to draw down their pension pot to zero in their lifetime.
Method 2: Natural-income portfolio
The second tried and tested method is a natural-income portfolio. This is where the underlying investments are relied upon to generate an income yield through dividends and interest that are paid out from the investments rather than re-invested for growth.
A natural income portfolio is also relatively simple to set up and can be very tax-efficient, particularly if the assets are outside of a pension wrapper (retirement income needn’t all be about pensions!). Natural income is also relatively easy to monitor and manage once set up, and is again a straightforward concept that the majority of advised clients will have little trouble understanding. As the types of underlying assets within an income portfolio are generally lower risk (cash, fixed income and large, mature company equities with a strong dividend yield) they can be useful for those clients of a lower risk profile.
However, there is no guarantee of the level of income as dividends, in particular, are not guaranteed and are relative to the capital value of the holding – not ideal in a market crash. Interest-rate risk also comes into play and will depend on prevailing market conditions (it is currently, as of April 2025, relatively high compared to the overall post-2008 landscape but is likely to continue falling progressively over the next few years). Natural income yields are also relatively low – typically (again, as at the time of writing!) between 3% and 4% per annum, with some higher-yielding strategies available that also come with higher risks on the capital side. Ultimately, this means clients will ideally have the combination of a large investment portfolio combined with a modest expenditure to get the best out of a natural income portfolio.
Method 3: Multi-risk bucket approach
The final method for flexible income is one that has really been picking up pace in recent years, and that is the Multi-Risk bucket approach (or cascading approach, or waterfall strategy, or potting strategy – take your pick!) The thinking behind this is to manage client assets over differing levels of risk to build additional resilience should markets drop. It needn’t be a market crash either, a bucketing approach can help ride out a stagnant or steadily falling market too.
There is no correct answer on how to run a bucketing strategy either – it can work with as few as two buckets with some discretionary fund managers using seven. The investment time horizons are also very much down to the preference of the advice firm, perhaps having to work around how a risk profiler works with some being easier than others. The most common approach here though is the three-bucket strategy with a set number of years’ income in cash (usually between 1-2 years) with 4-5 years in a ‘consolidation’ pot (purely to keep pace with inflation) with the remainder being invested in a higher risk portfolio to drive the long-term growth. The rationale here is that the client can comfortably ride out a 1-2 year period in the aftermath of a market crash without having to sell down their investment assets at a loss, perhaps a significant loss, and crucially can leave these assets invested for the inevitable recovery.
The main benefit of this style of approach is that, in theory, you can achieve the highest levels of investment growth whilst also having some protections in place for sequencing risk mitigation – during unfavourable market conditions, the process of topping up the lower-risk buckets can be switched off without detriment to the client (hello once again, Consumer Duty and prevention of foreseeable harm) for however long their cash bucket is able to fund their income.
A bucketing approach is a lot more hands-on to manage though, with multiple investment strategies to monitor in terms of performance and having to hold a review meeting at least every year where the buckets are rebalanced to ensure the strategy is ready to kick in should markets take a turn. This style of strategy also ideally needs a sizeable pot of invested assets (again, it doesn’t need to just be within a pension, but ISAs and GIAs can also play a valuable role) relative to the client’s desired level of income to operate to its maximum potential. Clients who are not well-versed in investments may also struggle to grasp the concept of how it works and be more likely to panic-sell assets from their high-risk growth pot in difficult market conditions; in light of Consumer Duty, this could be considered a foreseeable harm and care should be taken as to who this style of strategy could be suitable for.
It is very good practice to secure a client’s essential expenditure at the minimum with some form of guaranteed income before implementing any of the above drawdown processes. If a client’s State Pension or any Defined Benefit pension income (the two most common forms of guaranteed income) are not sufficient for this, then this is the perfect case for an annuity. As a very brief recap, an annuity will pay a certain level of income agreed at outset, over a certain time frame agreed at outset (can be fixed term if you are just bridging a gap for other forms of guaranteed income to come into payment or set up for a lifetime income) for an agreed initial lump sum payment or ‘premium’. Coming back to the prevention of foreseeable harm, securing a client’s essential expenditure with guaranteed income ensures they will be able to get by without potentially falling into income problems during retirement.
Concluding thoughts
In conclusion, there are many ways of going about securing a sustainable retirement income from invested assets and there is no perfect answer, or indeed even a correct answer. Any of the above approaches are viable but they must be considered alongside the client’s individual circumstances, the way your firm operates and, ideally, a cashflow forecast should be prepared to ensure the sustainability of income before proceeding with any strategy. Perhaps most importantly with the FCA not stating how retirement income should be managed it should have a robust rationale behind it. To quote my old maths teacher on the bigger and more complex questions “The examiner is not looking for the correct answer, they are looking for how you got to it” and I think that is a good mantra to follow when it comes to implementing a retirement income process.
Alasdair Wilson – Investment Specialist at Verve