Focus: Constructive Advocacy
PIMFA’s Successes 2024-2025 Infographic
CCI proposals are overly complex, prescriptive and represent a ‘missed opportunity’ for firms and consumers alike
20 March 2025
CCI proposals are overly complex, prescriptive and represent a ‘missed opportunity’ for firms and consumers alike
PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry, has warned that the FCA’s new disclosure regime remains overly prescriptive and complex for firms and consumers alike. In its response to the FCA’s consultation paper ‘A new product information framework for Consumer Composite Investments (CCI)’, PIMFA has highlighted that the Regulator’s proposals are incompatible with recent FCA findings on customers with characteristics of vulnerability, and the challenges many clients face when trying to absorb lengthy documents.
In its response, PIMFA has raised concerns that the current proposals will not enable consumers to compare products on a ‘like-for-like’ basis. Despite a level of prescription which runs counter to Consumer Duty principles, the proposals provide flexibility for manufacturers from presentation through to the ability to amend the output of risk scoring. Distributors are afforded the flexibility to create their own product information summary documents, or to amend those created by manufacturers. This subjectivity will make it difficult for direct comparisons to be made.
Whilst the potential for documents to be tailored to consumer cohorts with additional needs is welcome, the implied requirement for distributors to police and take liability for the documents is not.
PIMFA strongly believes that the proposals represent a missed opportunity to take account of industry feedback. PIMFA member firms have expressed frustration that challenges to the current PRIIPs costs and charges disclosure have been ignored, with a similar methodology proposed in the consultation. This will place a disproportionate focus on cost, with the calculation behind the headline figure remaining complex and opaque.
In its response, PIMFA has called for specific focus to be given to:
- Clarity on the interaction between MiFID and the CCI regime. The paper also signposts further consultation papers, but given the close interplay between MiFID and the proposed regime, it is hard to opine fully on the proposals without a full picture;
- The proposed timetable for implementation. The proposed 18-month transitional period will be challenging for firms to comply with and there is an added pressure for UCITs firms where the exemption from PRIIPs expires at the end of 2026. A policy statement would need to be issued by mid-year to ensure they benefit from the full exemption; and
- A clear roadmap to help firms understand the regulators ambition for the wider disclosure framework. This will help firms to plan change activity and also alleviate concerns that a piecemeal approach to reform will result in a disjointed and cumbersome regime.
Responding to the proposals, Julia Sage-Bell, Senior Policy Adviser at PIMFA said:
“Our abiding view of the proposals set out by the Regulator is one of an opportunity missed. When the government confirmed its decision to retire PRIIPS we were excited by the opportunity to reform the overall disclosure framework in line with the FCA’s stated aim to develop a flexible regime that reduced detailed disclosure rules. It is disappointing that what has been proposed is a replacement for the existing PRIIPs regime with little to no consideration given to the broader disclosure requirements. The result is a heavily prescribed, lengthy and complex set of rules which seem to run counter to outcomes focused regulation and do not appear to give much consideration to consumer understanding.
If the FCA decide to progress with these proposals as currently outlined, we would urge them, in particular, to provide clarity to firms on the interaction between MiFID and the CCI regime. We had anticipated that this would have been addressed within the consultation and are concerned that a decision on CCI rules will be taken without full regard to MiFID requirements. In addition, we would urge further consideration to be given to the proposed timeline. An effective disclosure regime is the cornerstone of the retail market framework. The industry needs to be given sufficient time to review and discuss the proposed methodologies and presentation once the MiFID component(s) of the consultation is known.”
NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
- 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 – 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.
Top considerations for financial intermediaries 2025
In recent years, financial intermediaries have had to navigate an investment landscape transformed by the converging risks of high inflation, rising yields, and market volatility. Between 2010 – 2020, inflation across the 38 OECD member countries hovered between 0% and 3%; by October 2022, aggregate inflation had surged to peak above 10.69%, transforming global monetary policy and the risk and market backdrop for global portfolios. Since then, the trajectory of global interest rates and inflation have dominated the market narrative, with markets gauging the likelihood of central bankers successfully navigating a soft landing for the global economy.
Our annual 2025 Themes and Opportunities paper delves into the evolving structural trends expected to shape portfolios over the long term, highlighting financial intermediaries and their clients to reevaluate strategic priorities across asset allocations. As we enter a period marked by heightened uncertainty and a shifting macroeconomic environment, the paper underscores the importance of adaptable approaches to balance risk and opportunity.
A focal point of the paper is rising concentration risk within global equity markets, where a narrow set of high-performing stocks dominates returns, potentially increasing vulnerability to market corrections. Paired with the complexities of a new macroeconomic regime — characterised by persistent inflationary pressures, elevated interest rates, and shifting geopolitical landscapes — the potential for heightened volatility has grown. The paper explores how these dynamics may challenge traditional investment models, highlighting the need for diversified, forward-looking strategies that can respond effectively to unpredictable market conditions and emerging structural shifts.
The 2025 Top considerations for financial intermediaries paper explores in more detail how financial intermediaries can achieve this, and the key considerations for investors seeking to diversify portfolios across asset classes, geographies, sectors, and investment styles to better withstand higher-for-longer interest rates and an uncertain growth outlook.
It highlights key shifts that financial intermediaries should consider in their portfolio construction, from the blurring lines between private market strategies and the risks of market concentration to the total portfolio impacts of the trajectory of interest rates and inflation.
In today’s environment, flexibility and diversification are key. Semi-liquid funds are providing a route into private markets for a broader set of wealth investors, while next-generation infrastructure investments align with long-term secular trends like the energy transition and digitalisation. Hedge funds can be used to take advantage of market volatility, while active ETFs — which are revolutionising active exposures across the wealth landscape — offer tactical liquidity and cost efficiency.
We believe that emerging market equities remain attractive despite recent underperformance and view this dynamic market complex as an important strategic allocation as the global economy becomes increasingly ‘multi-polar’.
To effectively manage portfolios in this complex environment, ongoing assessment of strategies and the flexibility to recalibrate allocations will be key to success for financial intermediaries. By expanding their focus and embracing a more diversified, adaptable approach, financial intermediaries can help clients manage risks and seize opportunities in a volatile global economy.
We recommend considering the following five opportunities:
- Semi-liquid funds
- Next-generation infrastructure
- Hedge funds
- Active ETFs
- Listed EM equity
Read the full report here.
Sebastian Maciocia, Director of Wealth Management UK, Mercer
PIMFA Response to FCA CP24/30 A new product information framework for Consumer Composite Investments
PIMFA Response to CP24/28: Operational Incident and Third Party Reporting
Financial Conduct Authority – Review of firms’ approaches to the Consumer Support Outcome: good practices and areas for improvement
Finding annuity purpose
Finding annuity purpose Data from the Association of British Insurers (ABI) shows that annuity sales increased by 24% for the year to 2024 to record sales of £7 billion. For context, the years 2015 to 2022 were in the region of £4 billion each year while 2023 exceeded £5 billion.
This increase is probably not that surprising. We have had rising interest rates and, maybe to a less extent, some fears around the future market conditions. Interestingly though, this same data set shows that annuity purchases by 36% of buyers in 2024 were those who bought their annuity after taking advice, a notable increase from the 29% that did so in 2023. This shows us more advisers are looking at annuities which perhaps was not the case.
We would expect this 36% to increase over the next year too, now that we have the threat of IHT hanging over drawdown. In this context it is worth looking at how annuities shape up in the world where pensions are subject to IHT.
We know from the legislative plans (which are of course subject to change) that almost all forms of defined contribution pensions are within the scope of IHT. Combined with exceeding the LSDBA or being subject to beneficiary tax after age 75, there is potential for relatively large tax bills for some.
How do annuity death benefits compare?
The main death benefit by far is a spouse/dependent pension. If the annuitant dies before the age of 75, the income is tax-free for the spouse/dependent. After 75, it’s is taxable as earned income.
This option is completely outside the scope of IHT for both the original annuitant and the beneficiary. This means the only type of tax paid here is personal rates of income tax by the recipient.
Guarantee Period
The structure of a guarantee period, when included in an annuity, usually takes the form of an ongoing income payment made by the insurer to the next of kin/estate of the annuitant for the amount of time selected (anywhere from 1-30 years typically).
The income from a guarantee period is similar to the spouse/dependent pension in terms of being tax-free before 75, but taxable if death is after 75.
In terms of IHT, the guaranteed income is outside the estate only if the direction of this benefit is ‘subject to the discretion of the provider’. Essentially this means as long as the annuitant is not mandating how the benefit is paid, it is free of IHT. This is similar to how, under current legislation, pension death benefits are outside the estate when not subject to a binding nomination.
Value Protection
The alternative to a guarantee period is to protect the lump sum used to purchase the annuity. A value of between 0% and 100% can be protected and each annuity income payment reduces the amount that could be paid out.
Like the other death benefits covered, this is tax-free / taxable depending on if death falls before or after age 75.
The full lump sum paid out is however considered part of the estate for IHT purposes, regardless of where it is paid and under whose discretion.
Death benefits overview
The overview of the above is as follows:
| Death before 75 | Death after 75 | |||
| IHT | Income Tax | IHT | Income Tax | |
| Drawdown | Yes | No | Yes | Yes |
| Annuity – Spouse Pension | No | No | No | Yes |
| Annuity – Guarantee Period | No* | No | No* | Yes |
| Annuity – Value Protection | Yes | No | Yes | Yes |
*Assuming no binding direction is setup by the annuitant
From a strictly tax perspective, the guarantee period seems to be the most effective way of avoiding IHT. A 15-year guarantee will completely cover annuities over 6.66% while a 30-year guarantee will cover annuity rates over 3.33%.
So, what are the disadvantages of buying an annuity with a long guarantee period to mitigate IHT? Well, opportunity cost and tax are two main ones.
Opportunity cost in that the potential of 10, 20 or 30 years of investment return on an uncrystallised/drawdown pot could lead to a higher net value (even after a 40% tax charge) compared to avoiding IHT by using a guarantee period.
Purchasing an annuity will also likely involve tax paid on each income payment. The cumulative effect of this over time could outweigh any IHT saving made. Purchasing an annuity will also involve a loss of flexibility to respond to changes in taxation and/or legislation, and a commitment to a specific annuity at the outset.
Conclusion
Death benefits are going to be more important as we move toward April 2027 and knowing how certain annuities sit in this regard, to compare against the uncrystallised/drawdown pension, is key to ensuring the right decisions are made for clients.
For more information or support with any technical queries, contact the Verve team at hello@weareverve.co.uk
Grant Callaghan, Financial Planning Specialist, We Are Verve
PIMFA’s Response to FCA DP24/3: Pensions: Adapting our requirements for a changing market
The Road to T+1 Settlement
The Accelerated Settlement Taskforce (AST), the body charged with enabling this transition, recently published an implementation plan which sets out the changes their members believe market participants need to deliver and contains a recommended UK T+1 ‘live date’ of 11 October 2027.
Here we look at why the move to T+1 is an important step and where the main benefits lie.
International competitiveness
If the UK wishes to maintain its competitive position as a leading global financial hub, it needs to ensure that it is aligned with other progressive, forward-thinking financial centres.
Many of the major markets around the world have already moved to T+1 settlement. China was the first market to adopt T+1 DVP in December 2022, India moved to T+1 at the start of 2023, and the US, Canadian and Mexican markets adopted T+1 as their standard settlement period in May 2024. The EU and Switzerland have decided to move to T+1 on 11 October 2027, to align with the UK.
The benefits of moving to T+1 settlement?
For investors, it will reduce risk, increase efficiency, enable clients to achieve faster access to their funds or securities and, due to the shorter settlement cycle, reduces exposure to credit and counterparty risk.
For financial markets, a shorter settlement cycle can reduce costs related to collateral and trading operations, increase efficiency by eliminating delays in the trading and settlement processes and promote more effective use of capital and the reduction of margin requirements.
For the economy, T+1 can increase overall market liquidity and enhance resiliency
Why is this report such a milestone achievement?
Given that the AST participants and their firms have their own priorities, including focusing on regulatory change, managing clients and building their businesses, persuading the market to focus on T+1 and agree an implementation plan and Code of Conduct has involved a lot of skilful negotiation, but also a willingness on the part of firms to work together to achieve an agreed approach that functions well for everyone.
Andrew Douglas, as Chair of the Accelerated Settlement Taskforce Technical Group, has marshalled the forces of 450+ representatives from 116 market participant firms, and managed the process of gaining agreement to:
- the scope of changes needed to the UK Central Securities Depositories Regulation (UK CSDR);
- a UK T+1 Code of Conduct, which contains the scope and a timetable of recommended actions to enhance market practices;
- a set of expected behaviours necessary for firms to meet their T+1 legislative obligations under UK CSDR; and
- twelve critical actions in four business areas, which all participants need to implement to ensure a successful and sustainable transition to T+1.
Learning from the US experience
By publishing the implementation plan now – effectively, a roadmap for firms to follow going forward – the AST has given UK firms considerable time to prepare.
Whilst the US, Canadian and Mexican markets’ move to T+1 in May 2024 was considered a very successful venture, the scope of the project was not clearly defined and agreed until just three months before live date. Some firms were obliged to hire in extra staff to help them manage in the early days, because they hadn’t had the time to fully prepare.
Some firms may choose to move some or all of their transactions to T+1 in advance of October 2027, so they have the opportunity to trial the process, but with the option to fall back to T+2 if they encounter any issues.
What is the impact on PIMFA members?
For PIMFA members, settling T+1 is familiar territory – transactions in Gilts are already settled on T+1, as the standard settlement cycle for gilt edged securities. Euroclear’s CREST system, which settles UK equities transactions, already has the capacity to settle T+1 today, so the settlement systems are in place, tried and tested.
When reading the AST report, PIMFA firms should consider the twelve critical actions across four business areas listed and decide which they need to act upon. Some will not be relevant – many PIMFA members are not involved in activities such as securities financing / stock lending. However, there are other areas worthy of consideration.
Whilst firms can already settle T+1, the volume of these transactions is currently quite low. Many firms will not have tested their capacity and ability to process high volumes of transactions that settle T+1, because there has never been a need to do so. Firms may want to consider moving to T+1 settlement for some of their equity transactions in advance of the 11 October 2027 T+1 ‘live’ date, so ironing out any bottlenecks or issues, ensuring their processing works seamlessly and is ready by the launch date.
Firms may also want to consider how they are going to explain the move to their clients, and confer with their counterparties, to ensure everyone is on the same T+1 page.
11 October 2027 may seem a long way off, but the next twenty months will fly by – now is a good time to start planning for UK T+1 settlement and thinking through the impact on your firm, your clients and your counterparties.
PIMFA runs a T+1 working Group for its members and associates – if you would be interested in joining in, please contact info@pimfa.co.uk.
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PIMFA Response to FCA discussion Paper DP24/2: Improving the UK transaction reporting regime
Targeted support is a welcome intervention but needs to sufficiently delineate itself from advice
13 February 2025
Targeted support is a welcome intervention but needs to sufficiently delineate itself from advice
PIMFA urges the FCA to ensure that the value of financial advice remains obvious to consumers and the boundary is not further blurred
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 ensure that in progressing its targeted support reforms, the attractiveness of mass market financial advice is preserved.
In its response to the consultation paper ‘Advice Guidance Boundary Review – proposed targeted support regime for pensions’, PIMFA has argued that whilst it is right that targeted support should be able to provide what is currently tantamount to a personal recommendation, it cannot go so far as to confuse consumers about the type of service they are receiving or diminish the attractiveness of financial advice.
PIMFA has called on the Regulator to ensure that certain protections are embedded within the regime to ensure that targeted support is sufficiently distinguished from holistic advice. It has identified three areas for focus here, namely:
1. How suggestions are communicated to the consumer,
2. How information is collected to assign a consumer to a relevant segment and, where possible,
3. Ensuring that the consumer is presented with a restricted set of options when they are being encouraged to make a transaction.
Simon Harrington, Head of Public Affairs at PIMFA, commented:
“Targeted support can be genuinely transformational. There is a very obvious support gap which exists in the pensions space in particular which we think targeted support can fill assuming – and it is a big assumption – that consumers are willing to engage with it’.
‘But we remain somewhat frustrated with the focus of the FCA’s proposals, given that they appear to see the primary utility of targeted support as a method to help consumers buy different products rather than as a method to help them get better outcomes out of the ones they already own. By making targeted support transactional it risks blurring the boundary between advice and the new regime in
an unhelpful manner.
‘We are comfortable with targeted support being able to provide what is currently tantamount to a personal recommendation, and we are comfortable with it being transactional, but the focus of the suggestions provided need to be focused on what a consumer could do, rather than being presented as something which they should do. As it brings forward its rules at the next stage, we have encouraged the FCA to think about how they can adequately delineate targeted support from financial advice. We believe that firms should have flexibility to design and deliver targeted support journeys which they think will benefit their customers most, but there need to be clear and unambiguous parameters in which these firms operate in as well as in how they communicate and disclose this service to consumers.”
NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
- 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 – 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.
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The suitability of suitability reports
We are often asked to review a firms suitability report templates to assess their (ahem) suitability for purpose and this has increased massively in the post-Consumer Duty world we find ourselves in, where consumer understanding has never been more relevant and prevalent.
First the compliance stuff.
The FCA cover the requirement to provide a suitability report in COBS 9.4 and in 9A.3. Excluding defined benefit and opt-outs which have different standards, COBS 9.4.7 outlines what should be provided as a minimum in a suitability report which is:
- The clients demands and needs (basically their objectives)
- An explanation of why the recommendation is suitable for the client
- An explanation of any possible disadvantages of the transaction
COBS 9A3.3 then expands on the above to include:
- How the recommendation is suitable with reference to the investment term required, the client’s knowledge and experience, and the client’s attitude to risk and their capacity for loss.
- Confirmation on whether the recommendations are likely to require the client to seek ongoing advice (through periodic reviews)
It is also worth noting that in the event of an investigation it is not only the suitability report that will come under fire, but that of the whole file and the suitability of the advice will be judged as much by the KYC information and the risk analysis as it will be by if you’ve explained what an ISA is in your report.
A bad file can make a good suitability report redundant when assessing competent and appropriate advice as much as the opposite is also true in that a bad report sat amongst a good file is like having a spot on your nose on the day you’re having your photo taken for the website.
Now the fun bit.
Taking the above (sparse) information into account, along with additional elements firms wish to add, then adding a Consumer Duty filter on top has resulted in many advice firms feeling lost when approaching their templates. The result of which can be a risk-based approach of throwing everything in the report in the hope that it covers your back.
However, with the focus upon consumer understanding through the Duty, this is ironically an approach which can result in the exact opposite of what you are trying to achieve. It is more likely that a complaint will be upheld because the client had too much information and was unable to understand the important parts. Clarity and brevity, therefore, are the pillars upon which you should begin approaching your template design.
So what is my view on suitability report writing in a Consumer Duty world? Taking all of the above into account I have concluded the following essential 3 points:
- Suitability reports should be short, concise and include only the relevant information as required by the FCA or what is needed to satisfy the consumer understanding outcome of the Consumer Duty.
- The report should not repeat information that is already included in the file or has been presented to the client separately. For example, factfind information, KFD/technical data, cashflow or information from a DFM portfolio report. It can and should certainly reference these in the advantages and disadvantages section where appropriate though.
- The report should be constructed and presented in a way that maximises the engagement of the reader and eases their understanding. Think tables, charts, colours and visuals. However, most importantly consider your use of language. Our industry is full of jargon and very technical aspects so breaking those down into words that anyone can understand and follow is essential. Consider for example, using ‘tax free cash’ rather than PCLS – Pension Commencement Lump Sum and consistently link the advice to their specific goals. Talk about how saving into a pension will help them buy a house abroad as per their dream and not so much about all of the technical aspects that a pension provides. You can signpost them to the KFD for that.
At Verve, for our internal report templates used by our Paraplanning arm we have split these into two parts. Part 1 is the main report which has all of the above information in and is only a few pages long. Part 2 is a supplementary report, dubbed ‘the small print’ which expands on some of the themes of part 1, provides additional details and can add further context. It is up to the adviser and the client whether they provide both reports or just the main report with the supplementary report sitting on file for reference. This ensures that you can get all of the salient information across to the client before they get bored (or put off by the tome hitting their doormat), but for that inevitable client (former accountant usually) who wants to know the ins and outs of everything, you have that option too.
This is a high-level approach to post CD suitability templates but we have so much more we could touch on. If you would like help with your own templates, please get in touch.
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PIMFA calls for an ambitious and assertive approach in modernising the redress system
30 January 2025
PIMFA calls for an ambitious and assertive approach in modernising the redress system
The trade association urges the FCA to reconsider the role of FOS, and explore consolidating the regulatory regime for CMCs
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 be ambitious in its proposals to modernise the redress system and look beyond the iterative proposals they have put forward in their recent discussion paper on modernising the redress system. In its response to the paper, PIMFA has argued that whilst the headline proposal of ‘defining a mass redress event’ would be a welcome intervention, many of the concrete proposals set out within the paper would have mixed results and would prove minor in their nature.
Instead, PIMFA has suggested reforms which would both improve the current approach to mass redress events as well as strengthen the regulator’s oversight of the complaints process.
Where these mass redress events occur, PIMFA believes that there is scope in resetting the boundaries around how the Financial Ombudsman Service (FOS) operates and, crucially, about what it does not do, which would likely significantly reduce the operational pressure on the FOS.
Consequently, PIMFA believes that in the case of mass redress events, and where firm-led solutions have been agreed in dialogue with the FCA and/or a Skilled Person, the FOS should only follow on from the agreed redress programme outcome – acting as a final backstop to consider if the programme parameters have not been fulfilled where the customer remains unhappy with the outcome.
Beyond the scope of mass redress events, the trade body also outlined how the FCA and government should consider consolidating the disparate regulatory regimes governing CMCs to overcome that the current regulatory arbitrage with the two primary regulatory regimes. This would result in more consistent experiences for consumers and better regulation of the CMC sector more generally. PIMFA would favour the FCA having powers over all financial services focused CMCs rather than the current regime which provides for some Solicitors Regulation Authority (SRA) regulated ‘professional representatives to bring forward financial services claims.
Simon Harrington, Head of Public Affairs at PIMFA, commented: “Ensuring that we have a fit for purpose redress system when things go wrong on a major scale is an important step in ensuring that consumers who have been let down receive a fair outcome. Whilst we think that it is right that the FCA have identified some areas for reform – specifically the need to identify when a mass redress event has occurred, we also believe there is scope for them to be more ambitious and assertive in their proposals.”
“We strongly believe that the FCA should give consideration to the role of the FOS and how it currently involves itself in mass redress events, and where they have worked closely with firms and/or a Skilled Person to identify and resolve any failings, the FOS should be out of scope, giving firms the breathing space they need to meet their redress obligations.
Only once a consumer has received and understood an offer of redress, do we believe that the FOS should be in scope to ensure the process is as efficient as possible and that consumers who have been let down do not inadvertently find themselves further delayed by process and bureaucracy.”
“We would also strongly urge the FCA to look beyond the crystallisation of mass redress events and consider the regulatory regime which governs complaints more broadly. To this end, we strongly believe that there is scope for the FCA, in consultation with government, to consolidate the regulatory regimes which currently governs the CMC sector. It is vital that there is consistency of consumer experience, and most pressingly, consistency of standards across the board and this can only be achieved through a consolidated regulatory regime.”
NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
- 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 – 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.