How to Produce an Effective Consumer Duty Board Report
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Consumer Duty

26 April 2024
PIMFA WealthTech, the market network and technology platform created with principal strategic partner Morningstar, a leading provider of independent investment insights, has today (26 April 2024) announced the Fintechs’ that have been selected to present their solutions for its latest ‘Tech Sprint’ focused on Environmental, Social and Governance (ESG) reporting, verification and disclosure processes in the sustainable finance sector.
The Fintech’s – Instinct Digital and Know Your Funds – were selected through a competitive process from a total of seven Fintech participants following demonstrations on how their technology could help wealth managers and advisers to navigate the huge amount of ESG data that exists in order to better serve their clients as well as fulfilling regulatory reporting requirements.
Instinct Digital is a provider of digital reporting solutions for asset managers designed to help them to unify their nreporting assets, digitise communications, and optimise reporting operations
Know Your Funds is a provider of a solution designed for the investment community with clients that already include are asset owners, asset managers and depositary service providers.
The two companies will now go forward to the Morningstar Investment Conference, which takes place in London on 1 May 2024, where they will be able to showcase their solutions to wealth managers, advisers and other interested stakeholders.
ESG and sustainable finance are a priority area of focus not only for wealth managers and advice firms, but also the Financial Conduct Authority (FCA). PIMFA, the trade association for the wealth management, investment services and the investment and financial advice industry, is taking a leading role in supporting the development of new guidance in partnership with the FCA to ensure the information provided to consumers is clear and consistent, and so as to eradicate, where possible, the detrimental impact of the phenomenon known as ‘greenwashing’.
PIMFA WealthTech has been created to address digital business transformation through the development and adoption of market-leading technologies. As a digital marketplace and industry network. PIMFA WealthTech’s objective is to drive innovation and enhance collaboration between Fintechs and wealth management and advice firms, operating an Advisory Council of leading wealth management and financial advice practitioners that cover all segments of the sector.
Richard Adler, Executive Director of PIMFA WealthTech, commented: “ESG and Sustainable Finance is a top priority for PIMFA members, with the recent FCA sustainability disclosure requirements and investment labels policy a key step for increasing trust in sustainable investments.
“The role technology can play in helping our members meet new requirements and serve their clients better has the potential to be enormous. We’re delighted to be working with Morningstar on this important Tech Sprint and are looking forward to both Know Your Funds and Instinct Design demonstrating the solutions they can offer at Morningstar’s Investment Conference next week.â€
Anastasia Georgiou, Director of Client Solutions, Adviser Segment, EMEA, Morningstar, commented: “We are proud to continue our longstanding strategic partnership with PIMFA WealthTech to showcase new technology solutions from Fintechs to the Wealth sector.
“Today, firms need to generate insights and ideas for sustainable investments and position new offerings in the market. This includes identifying innovative ways to address the challenge of harnessing the vast amount of data available, which is needed to provide accurate reporting and disclosures. Along with PIMFA, Morningstar is proud to help promote new solutions to help firms identify ESG risks and create new opportunities for clients.â€
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About PIMFA WealthTech
PIMFA WealthTech is part of the Personal Investment Management & Financial Advice Association (PIMFA), the trade association for the wealth management, investment services and the investment and financial advice industry, spanning 13,000 regulated firms that collectively manage the interests of almost £1.7trillion.
It believes that collaboration is essential to solving industry challenges and brings together senior industry decision-makers to address the most important and complex questions concerning technology focus, partnering and adoption as it applies across the value chain.
Our market network and technology platform has been created to bring the most innovative and relevant WealthTechs to our sector. Our teams work alongside leading financial institutions to identify, prototype and deliver enhancing technologies and breakthrough solutions that generate competitive advantage and business impact.
Further information can be found at pimfawealthtech.com
About PIMFA
About PIMFA – the Personal Investment Management & Financial Advice Association
About Morningstar, Inc.
Morningstar, Inc. is a leading provider of independent investment insights in North America, Europe, Australia, and Asia. The Company offers an extensive line of products and services for individual investors, financial advisors, asset managers and owners, retirement plan providers and sponsors, and institutional investors in the debt and private capital markets. Morningstar provides data and research insights on a wide range of investment offerings, , including managed investment products, publicly listed companies, private capital markets, debt securities, and real-time global market data. Morningstar also offers investment management services through its investment advisory subsidiaries, with approximately $294 billion in assets under advisement and management as of Mar. 31, 2024. The Company operates through wholly- or majority-owned subsidiaries in 32 countries. For more information, visit www.morningstar.com/company. Follow Morningstar on X @MorningstarInc.
NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
Contact
For further information on this release or other press matters please contact:
PIMFA Communications and PR – +44 (0)20 7382 0376 .
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869.
While client engagement remains the pillar of good practice in the industry, how we approach it is evolving.
Much of this has to do with the clients themselves, whose expectations of what constitutes good service have changed. Take Deloitte’s findings for example, which claim that, although investment performance remains a deciding factor, personalisation and timely interactions are essential for customer satisfaction.
The Unblu-Compeer report, which focuses on the UK market, adds a new layer of insight to this, claiming that even traditional clients are beginning to embrace digital channels. The report found that 51% of HNWIs want self-service tools and digital capabilities to receive advice and for portfolio management. Not offering these capabilities can have detrimental effects, as can be seen in the Canadian and US markets, where 77% of relationship managers reported losing out on business because they didn’t have the correct tools.
Stating that clients want easier and more varied access to their advisers is all well and good, but delivering on these expectations remains a challenge for firms and private banks.
Take the issue of compliance, which should never be far from any adviser’s mind. After all, since 2021, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have issued fines in excess of $2.75 billion to financial services companies – specifically because of errors in communication recording.
Tools like Unblu’s Secure Messenger offer clients a comfortable messaging experience that mimics how they interact in everyday life. What’s more, Secure Messenger solves the issue of communications regulatory compliance as it is built into a single, unified, and wholly secure platform.
Yet last year’s developments in generative AI threw another spanner into the works in terms of data privacy and compliance.
Generative AI isn’t just a fad – it is a powerful asset that can act as an adviser sidekick to speed up messenger interactions with quick, accurate, and insightful support. What’s more, 45% of WM professionals plan to adopt it in the near future, according to Forrester.
The key is to adopt it in a safe, strategically sound manner, avoiding unauthorised organisational use, otherwise known as ‘shadow AI’, which can put the firm or bank at serious risk. This technology is only going to become more widespread in the coming year, so taking steps to implement it now is essential.
The personal service that humans can offer will always trump technology in terms of trust, reassurance and overall client satisfaction. Yet relationship managers and advisers are finding it difficult to properly engage with clients given the sheer volume of administrative tasks that are part and parcel of their work. This is even hampering their ability to provide advice and deliver a quality service.
Once again, improved technological capabilities are necessary to reduce back-office tasks and increase the time that advisers have to interact with clients. Generative AI can help here, taking care of client onboarding, processing routine transactions, document verification, KYC checks, and more.
Likewise, platforms specialised in digital interaction, such as Unblu Spark, can help advisers to increase client collaboration while minimising non-core activities. The versatile mix of AI-enhanced secure messaging, video & voice, and visual collaboration, means that relationship managers or investment professionals have more freedom to exchange ideas, information, and documents – without sacrificing client authentication, data security, or regulatory compliance.
Our customers report that this can lead to a 25% increase in front office productivity and a 5-10% boost in the time that RMs spend with clients.
There is no doubt that an increase in quality client engagement and collaboration is a marker of success in wealth management contexts. More meetings and convenient spaces for client interactions directly leads to increased AUM growth and client loyalty.
This year is proving volatile, particularly due to increasing tensions and global conflicts. As a result, organisations should take active steps to ensure that they are available to engage with their clients and offer advice or reassurance as needed.
Danny Baggs Senior Director of Account-Based Marketing, Unblu
If you’re interested in a more in-depth overview of today’s WM context, we have put together all of our findings for 2024 on this website.
16 April 2024
Recent changes in culture within financial services firms still needs to become fully embedded in order to better attract female talent and female investors, Financial Conduct Authority (FCA) executive director, risk and compliance oversight, Sheree Howard, told delegates at PIMFA’s inaugural Women’s Symposium today (16 April).
Ms Howard said the wealth management and financial advice industry still needed a “different and better mix of advisers and advice” to ensure that women were receiving the help they needed.
While much had changed in the thirty years since she had begun working in financial services, Ms Howard said she feared the industry was in danger of “going backwards”. The rate of appointment of women to wealth management and financial advice boardrooms is continuing to fall and has fallen 28 percentage points in the last year, she said. Meanwhile, in the previous year a third of all board appointments were female directors, down from 61% the previous year.
There had also been a decline in the share of women employed in the industry overall, from 51% to 43%, despite the sector continuing to expand. While this was partly attributed to the removal of lower skilled roles in which women were more highly represented as well as advances in technology, there is more that is needed to be done to attract women into the industry, she said.
Financial services firms need to pivot towards “attracting women into more rewarding mid-level and senior roles” Ms Howard said. Adding that the way to do that was to ensure the right culture existed, so that the right female talent were attracted to the industry at the start of their career, that they were then promoted on their merit and hard work and also continue to be retained within the industry “whatever their life choices may be”.
One of the main deterrents to women entering financial services were the large instances of non-financial misconduct, which often took the form of sexual harassment and this misconduct could destroy a firm’s reputation, as well as contributing to toxic group think, she added.
Ms Howard called on firms to tackle those individuals that did “not meet their [professional] standards by risking their firm’s reputation, their clients’ money and their colleagues’ wellbeing,” she said.
She called it “striking” that 74% of respondents were supportive of recent FCA proposals to tackle non-financial misconduct.
And she also reminded delegates of the FCA’s whistleblowing hotline. She raised concerns about sexism in the City and what she called “the pernicious use of non-disclosure agreements to try to supress whistleblowing”.
“It is worth reminding ourselves collectively that nothing in an NDA can prevent an individual from reporting an incident to the FCA. And I mean nothing”.
“Treating colleagues well, protecting against group think and delivering for a diverse range of customers should not be controversial or antagonistic. It’s the right thing to do,” she said.
Liz Field, Chief Executive of PIMFA, commented: The financial services industry has seen tremendous progress in both providing women with the opportunities that they need as well as creating a workplace which allows them to truly fulfil their potential.
“While this progress is undeniable, it’s clear there is still much work to do and the figures outlined by the FCA are testament to that. Women are set to control 70% of global wealth within the next two generations which makes the business case for the change in culture we want to see undeniable, and I echo Sharee Howard’s sentiments that this should be a wake-up call to the industry.
“The PIMFA Women’s Symposium is an opportunity for our industry to recognise that business case and to seek to address the issues that matter to women, as well as learn more about the issues they face and concerns that have when it comes to navigating investing, saving and advice.
“We also strongly support the FCA’s expectations of firms to tackle individuals who do not meet their professional standards for both financial and non-financial misconduct. We believe that there is clear role for the Regulator to set out its expectations of firms in this regard and are committed to working with other relevant industry bodies to better equip firms with the tools needed to identify and act on issues of non-financial misconduct.”
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Notes for Editors
About PIMFA – the Personal Investment Management & Financial Advice Association
Contact
For further information on this release or other press matters please contact:
PIMFA Communications and PR – +44 (0)20 7382 0376
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869 / +44 (0)7979 49322
10 April 2024
PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry, is delighted to announce its annual Diversity & Inclusion Awards opens to entries today (10 April 2024).
Now in their fourth year PIMFA’s Diversity & Inclusion Awards seek to highlight the many instances of good practice which remain hidden or unrecognised within our industry. Businesses both large and small will have examples of innovation aimed at improving their inclusivity and performance, which in turn drives positive change across the industry.
This is an opportunity for firms to highlight where they are on their journey of embedding D&I within their firms and there are a couple of individual categories too to celebrate the exceptional, diverse talent coming up through the ranks in our industry that is changing businesses for the better or leading from the top.
As in previous years, the awards are free to enter and open to all Financial Conduct Authority (FCA) registered firms within the wealth management, investment services and the financial advice industry and stakeholders in the sector – you do not have to be a PIMFA member to enter. The closing date for entries this year is 14 June 2024 – full information and entries can be submitted at https://pimfadiawards.awardstage.com/#!/home.
This year’s event, held in partnership with Morningstar, Raymond James, FIS, Charles Schwab and supported by Mark Allen Financial Media, publishers of Portfolio Adviser, International Adviser, PA Europe and ESG Clarity, will celebrate the great work being undertaken by the industry with a gala awards ceremony and dinner at the Intercontinental Hotel, Park Lane, central London on 10 October 2024.
The PIMFA Diversity & Inclusion Awards include the following awards categories:
Award entries will, as in previous years, be judged by a group of industry peers alongside experts in diversity and inclusion from charities and stakeholders that PIMFA partner with. This includes Richard Flynn, Managing Director of Charles Schwab; Bukola Adisa, Founder of Career Masterclass; Peter Moores, Chief Executive of Raymond James; Fabio Peyer, Director of Indexes Marketing at Morningstar, Charlie Fisher, Senior Human Resources Manager at LGT Wealth Management, Richard Wilson, Chief Executive of Interactive Investor, Matt Cameron, Global Managing Director at LGBT Great, and Bev Shah, CEO & Founder, City Hive among others.
Liz Field, Chief Executive of PIMFA, commented: “We are delighted to open our fourth Diversity & Inclusion Awards to entries. The awards have gone from strength to strength as anyone that attended last year’s awards will I’m sure attest to and the response we receive each year from the industry shows how seriously firms take this issue.
“As always, the awards give us a great insight into the work being done by firms to better reflect the society we serve. Once again, I want to encourage firms of all sizes, as well as individuals, to examine what they are already doing to bring about change and enter the awards so that we can shine a light on the great work that is taking place out there and can promote the good practices we are seeing.”
<ENDS>
Notes for Editors
About PIMFA – the Personal Investment Management & Financial Advice Association
Contact
For further information on this release or other press matters please contact:
PIMFA Communications and PR – +44 (0)20 7382 0376
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869 / +44 (0)7979 493225
How embedded is Consumer Duty in your cultural footprint?
Picture this: You’re a call centre operator at a Financial Services firm. It’s 4:55pm, and you’re about to finish your shift. You need to leave on time to catch a train and cook dinner. Just as you’re about to log off, you receive a call from a distressed individual with a bereavement to communicate. What would you do? What would your colleagues do? What would your leadership expect you to do?
What does the organisation want you to do?
The FCA’s Consumer Duty fundamentally changes how financial services firms interact with their customers, setting a higher expectation for customer care. To meet this, many firms require a significant shift in culture and behaviour, where employees consistently focus on generating continuous positive outcomes for customers – this is not just a tick box exercise. This cultural change will be brought about through sustained changes in the everyday decisions and actions people take, with people at all levels taking ownership for decision-making.
Just over six months in, firms are continuing work on embedding the Duty in their ways of working to ensure it is truly sustainable. This requires exploring what it means for their strategy, their business, and their culture.
Consumer Duty requires a sustained change in culture
At KPMG, we believe culture is influenced by purpose, vision and values, and demonstrated in the day-to-day behaviours of people across the organisation; the things they say and do. Their behaviours are directed by the actions and decisions of their leaders and managers and are influenced by training, communications, and how they are incentivised. It’s critical that firms create the right environment and ways of working to minimise barriers to doing the right thing and encourage ‘good’ behaviours. What their teammates and colleagues do or ‘get away with’ is influential – as Steve Gruenert and Todd Whitaker famously said, “The culture of any organisation is the worst behaviour the leader is willing to tolerateâ€.
How do you know whether your culture supports good customer outcomes?
Measuring culture is notoriously hard. In relation to the Duty, many organisations either don’t measure it or rely on surveys asking their people to rate their understanding of Consumer Duty. These surveys have a place; but understanding the Duty does not necessarily translate to behaviour and actions on the ground. Many other organisations will opt to evaluate the appropriateness and effectiveness of the things that influence culture like training, communications, performance management and incentives, as these are easier to measure, and data often already exists.
More effective ways to measure whether your culture supports good outcomes is by measuring the decisions and actions people take day-to-day, particularly in circumstances such as our opening scenario where there are competing priorities. Questions about leadership and managerial actions and the level of psychological safety to speak up are also very valuable as they highlight potential barriers to ‘good’ behaviours.
What should organisations focus on now and in the longer term?
Organisations should:
Reflection: How embedded are Consumer Duty behaviours across your firm?
Thinking back to our opening scenario; firms can have the best processes, technology, and data, yet the outcome for the customer is heavily reliant on the decisions and actions of the person answering the call. We all think we would take the time to help someone and assume our colleagues would do the same, but would they?
Our latest Consumer Duty culture offering combines our people, culture and regulatory expertise to assist firms in understanding and predicting behaviours that individuals are likely to take which could give rise to poor outcomes for consumers. Utilising KPMG’s purpose-built scenario-based survey tool, our analysis produces insight on the types of situation and groups of people that provide greater concern and how to address these challenges early. Please get in touch for a discussion to hear more about how our expert team and bespoke survey tool can support.
This article was co-authored by Mita Dave, Katie Paton, Lauren Smith, Jackie Todd and Hannah Jordan.
Europe’s flagship ETF event provides investors and the wider ETF ecosystem with insights into the trends shaping the European ETF market over the next 12 months. This is an ecosystem that is experiencing dramatic growth and change so we believe it is crucial attendees gain an edge in an increasingly competitive market.
Day 1 is for professional investors only. Hear from leading experts on the latest ideas around asset allocation and portfolio construction, all through an ETF lens.
Topics include:
– The fixed income conundrum and the role of ETFs
– Analysing Europe’s ETF product pipeline
– What next when allocating to China?
– ETF investing in volatile markets
Day 2 is open to the wider ETF industry where we will explore the crucial developments from across the European ETF ecosystem.
Topics include:
– Key ETF regulatory developments
– Changes in Europe’s market structure
– The shifting indexing landscape
– The future of ETF trading
Contact information: –
Bob Shearwood:
bob.shearwood@etfstream.com
+44 20 3922 0877
Preparing and planning for your next CASS audit is a complex, costly and a time-consuming process. There’s no magic bullet to solve this annual challenge, but measurable progress can be made to strengthen your framework and controls.
In this FREE 60-minute webinar we put three CASS experts under the spotlight to share their key strategies and approaches your firm can take in 2024 to ensure readiness for your next CASS audit.
Key discussion topics panellists debate include:
1. How your firm can complete a CASS audit in less time
2. Why CASS audit fees are rising and what you can do about it
3. The increasing role and importance of technology in your approach to CASS
4. What’s the upside of conducting a CASS health check
For years, wealth managers have retained a reputation of being an appealing target for cyber criminals looking to exploit the vast amount of sensitive client data and client monies they hold. The National Cyber Security Centre (NCSC) along with the Information Commissioner’s Office (ICO) continue to remind firms of their role in reducing cyber risk, and particularly ransomware risk – the biggest online threat to the UK. Therefore, it’s vital that businesses understand what they can do to reduce the risk of a cyber attack.
Ransomware payments on the rise
Ransomware attacks have become increasingly problematic as cybercriminals realise the value of extorting and disclosing sensitive data. In the past, ransomware attackers would infiltrate a business’s systems, encrypt data, and demand payment. However, the introduction of data exfiltration adds a new layer of complexity. Now, attackers threaten to publish stolen data unless ransom demands are met. This tactic significantly amplifies the potential reputational damage, making businesses more inclined to pay the ransom, even if they have backup systems in place.
Evidence suggests this strategy is working. The cybersecurity firm, Sophos, revealed that ransomware payments have nearly doubled in the past year, with UK companies paying more than the global average. They found that average ransomware payments globally rose to $1.5m, up from $812,000 the previous year. By contrast, the average payment made by UK organisations stood at $2.1m. The NCSC has also expressed concerns regarding the intersection of ransomware and artificial intelligence, which further exacerbates cyber risks.
The impact of ransomware risk transfer
Ransomware attacks can wreak havoc on a business’s operations in a matter of minutes and cause serious financial harm. As such, cyber insurance plays a critical role in mitigating the financial and operational fallout of cyber attacks.
In one case study, a professional services firm suffered an elaborate ransomware attack in which all its computer systems and data were encrypted, including customer data. The ransomware also encrypted the company’s backups. Unable to afford the ransom demand, the company reached out to its insurer. Within minutes, the insurer’s security incident response team contacted company employees to diagnose the damage and minimise further loss.
Ultimately, the insurance not only covered the ransom demand but also provided support for business interruption, forensic investigation, and data restoration.
Cybersecurity best practice
Leading experts in cybersecurity and risk management advocate for robust cybersecurity measures as a strategic necessity rather than a luxury. Likewise, insurers now demand stringent cybersecurity controls before offering coverage. These controls include:
Moreover, businesses are encouraged to implement preventative and detective controls such as privileged access management, business continuity planning, and continuous monitoring. While insurers may vary in their specific requirements, adhering to these standards is considered fundamental business practice.
Embracing cybersecurity
The prevalence of cyber risks facing wealth managers necessitates a proactive approach to cybersecurity. By implementing robust cybersecurity measures, businesses can not only mitigate risks, but also safeguard their reputation and support sustainable growth.
For more information, visit Lockton’s Cyber page, or contact:
Jack Bassett, Assistant Vice President, Lockton Global Cyber & Technology
Laura Skaanild, Head of Global Financial Institutions, Lockton
20 March 2024
PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry, has raised serious concerns about the Financial Conduct Authority’s (FCA) proposals for personal investment firms (PIFs) to calculate their potential redress liabilities and has called for further engagement with the industry.
While the proposals put forward by the FCA to increase the accountability of firms that have exposure to redress liabilities are welcome in that they are a move towards a ‘polluter pays’ model, which PIMFA has been advocating for, for several years, they however raise significant concerns.
As they currently stand the proposals would see well-run firms holding additional capital for redress that may never be required and paying higher Professional Indemnity (PI) premiums. They would lead to PI providers taking defensive positions against customer claims that might never materialise through additional policy exemptions, and in the worst cases they would lead to firm failures as a result of additional capital allocation requirements that would still leave clients falling on the FSCS. All the while leaving bad actors free to continue to behave in a way in which well-run firms end up paying for their failures.
Under the current proposals firms will find it extremely difficult to assess their potential redress liabilities as these will be subjective and open to interpretation. Any assessment will amount to firms sticking their finger in the air and guessing at what their liability for redress may be. It may be entirely possible that a firm makes a capital allocation for redress for something where no complaint ever arises.
The proposals provide no clarity on the regulatory mechanisms that will need to be in place to ensure that calculations are correct and are accurately reported. There is also concern about how the proposals will be supervised and enforced, especially as the FCA does not directly supervise the majority of smaller firms.
The proposals require firms to do their own calculations and self-reporting and make a reasonable estimate of the amount of funds they would need to provide in the form of redress to each customer if a liability crystallised.
But while well-run firms will carry out this exercise diligently, spending time and resources to make an accurate assessment, there is serious concern that the ‘bad actors’ will not carry out the calculations correctly or, most likely, simply ignore them.
Ultimately this will leave the ‘good actors’ continuing to pay for the poor behaviour of a minority of firms instead of reinvesting it into developing their own businesses.
Moreover, given the FCA is considering moving towards a more comprehensive prudential regime for PIFs, drawing on the experience of introducing the Investment Firms Prudential Regime (IFPR) in January 2022, PIMFA argues the current proposals are premature.
PIMFA is strongly in favour of a review of the PIFs’ prudential regime and moving towards an alignment with MiFID investment firms in a reasonable and proportionate manner.
A reformed prudential regime would provide increased capital/liquidity requirements and improved risk management for PIFs (e.g. provisions for a form of ICARA and wind-down planning) and would address the objectives of this consultation, delivering equivalent outcomes with less complexity, subjectivity, and burden placed on all firms. On this basis, any future review and move towards a more comprehensive prudential regime for PIFs would make many of the proposed rules in this consultation unnecessary and redundant.
PIMFA would therefore prefer clarity on the proposed timing of any future prudential review to reduce the duplication of effort and additional work this would introduce to firms, but of more importance, further discussion with the industry on the merits of these proposals versus moving to a simpler alignment of the PIF prudential regime with MiFID investment firms.
Alexandra Roberts, Head of Regulatory Policy and Compliance at PIMFA, commented: “While the intent of the FCA’s proposals is welcomed, the requirements and process are overly subjective and complex and do not provide sufficient confidence in the effectiveness of how they will be supervised and enforced to achieve their aims.
“It will, therefore, result in a considerable burden, in terms of time and resources, for the diligent and prudent firms while having little to no impact on the bad actors who are knowingly responsible for high redress claims.
“In short, the proposals will impose sweeping and extensive obligations on all 5,000 PIFs to address the actions of 75, which appears unnecessary and disproportionate.
“It would be preferable to consider the proposals to increase the prudential alignment of PIFs with MiFID investment firms instead. This action would resolve some of the issues in relation to redress claims falling onto the FSCS and be a more straightforward and logical solution.”
NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
Contact
For further information on this release or other press matters please contact:
PIMFA Communications and PR – +44 (0)20 7382 0376 .
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869.
Are you prepared for the upcoming Digital Operational Resilience Act (DORA)?
With its enforcement starting on January 17th, 2025, failing to comply with DORA could lead to significant fines for your organisation. Entities found to be in violation of the Act’s requirements may face fines of up to 2% of their total annual worldwide turnover. The supervisory body may also issue cease-and-desist orders, termination notices, additional pecuniary measures, and public notices.
With only 10 months to go it is crucial to begin preparations now.
Katie Barnett, Director of Cyber Security of Toro shares vital insights into DORA, including its purpose, key components, and what you need to do to get your organisation ready.
What is the purpose of DORA?
The financial sector’s reliance on ICT and digital information has grown significantly over the last several years.
Covid-19 acted as a further catalyst as organisations became more reliant on the availability of digital systems to conduct day-to-day operations in a remote setting.
More than ever, the finance sector is a prime target for cyber-attacks.
DORA aims to tackle this vulnerability by providing clear guidance and standards to effectively manage and mitigate information, communication, and technology (ICT) risks.
Who does DORA impact?
DORA applies to a broad range of financial entities, including investment firms, (re)insurance undertakings and electronic money organisations operating in the European Union. It also extends to ‘critical ICT providers,’ including cloud service providers who support financial organisations.
Understanding DORA
DORA is an EU (European Union) regulation designed to strengthen the financial sector’s IT security posture.
As articulated in Recital 105, its objective is to achieve a high level of digital operational resilience for regulated financial entities.
The regulation has two main goals: comprehensively addressing ICT risk management within the financial services sector and harmonising existing ICT risk management regulations across the EU.
What does it cover?
The focus for DORA is to set a clear standard on how financial institutes will manage their ICT risks. These risks have been broken into five foundational pillars.
What should I do now?
Based on my experience, preparing for the initial implementation of new regulations can be much more time-consuming and resource-intensive than anticipated.
The first thing I would recommend is that you speak to your IT team and ask them to conduct a gap analysis and create a roadmap to compliance. If required, external providers such as Toro can help by giving you access to DORA gap assessment tools and services.
It is important that you thoroughly analyse your current process for risk management, incident management and reporting, resilience testing, third-party management, and threat intelligence to understand where your gaps exist.
Once you know your gaps, you can identify and implement remediations to meet the DORA requirements.
By taking a proactive approach now you will be able to develop a realistic and achievable implementation plan that will keep you on the front foot and ensure your compliance with the regulation.
If you have questions regarding DORA and want to understand how Toro can support, please get in touch.
Katie Barnett, Director of Cyber Security, Toro Solutions
The FCA expects your first Consumer Duty Board report to be ‘signed, sealed, and delivered’ in less than five months. At their peril, firms underestimate the time, process, and planning required to produce a Board-approved report by 31 July 2024.
The stakes are high, and although there is a temptation to populate a template, your first Consumer Duty Board Report is a critical document that must be personalised to suit your firm.
The FCA has put firms on notice, reminding them that they will “need to be able to provide it [their Board Reports], and the management information that sits behind it, on request” – the key here being the evidence that sits behind it.
As time is of the essence, PIMFA, in partnership with consultancy firm Square 4, has designed this three-hour masterclass to help you compile your first Consumer Duty annual assessment report in line with FCA expectations.
Format
Part one of this online masterclass takes you step by step through how to best prepare, structure, format and populate your report. In part two, you will, with the support of regulatory experts, drill down into the 10 critical elements of your Board report that Square 4 has identified will attract greater FCA scrutiny.
Content
This live and interactive masterclass will address the ten critical elements of the Board report that firms must get right:
1. The Executive Summary
2. Customer outcome monitoring
3. Root cause analysis
4. Actions
5. 3LOD assurance
6. Culture and purpose
7. FCA engagement
8. Consumer Duty Champion
9. Business strategy
10. Board approval
Key questions this masterclass will answer includes, how your firm can:
1. What does a detailed and well evidenced Report Board Report look like?
2. Determine what resources you need to put the Board Report together
3. Reveal and address the gaps in your outcomes monitoring framework and Reporting
4. Obtain an appropriate range of relevant qualitative and quantitative metrics
5. Ensure that the report is effectively owned doesn’t get stuck in the second line
6. Retain a sense of proportionality, whilst retaining the quality and completeness the FCA expects
7. Evidence that your firm’s culture and purpose align with the Duty
8. Identify and document poor outcomes, detailing the remedial action(s) taken
9. Grasp what good practice looks like when it comes to documenting your approach to vulnerable customers
10. Demonstrate that there has been robust engagement, scrutiny and challenge from Senior Management, NEDS and the Consumer Duty Board champion
11. Construct a plan to improve outcomes and evolve compliance with the Duty
12. Assess how future business strategy is consistent with the Duty
By attending this masterclass, you will be able to:
1. Follow a clear plan of action to produce a Board Report that aligns to the FCA’s guidance
2. Compare your approach to Board Reporting with industry peers and regulatory expectations
3. Reflect, in your report, the perspectives and priorities of the Board/governing body
4. Develop a clear approach to writing a Report that is purposely, focused and more balanced
5. Employ proven design principles, in line with industry good practice
6. Avoid the trap of presenting too much data and too little information
7. Making the mistake of Reporting too much on what has happened
8. Reflect in your content, the areas the FCA will focus and scrutinise
9. Use the time to complete a robust ‘dry run’ to identify any gaps and issues
10. Create a plan of action up to July, to allow for any necessary reviews and governance steps
Who should attend this masterclass?
Consumer Duty Champions/ Non-Executive Director (NED) who need to know that the Board report reflects the concerns of the Board and contains the MI, evidence and supporting commentary for a robust discussion and debate to occur before the 31 July 2024.
Board members of firms who have already created their annual Board report or are advanced in their preparations and now seek assurance that the work undertaken to date is complete and aligned with regulatory expectations and industry good practice.
Senior executives concerned that their plans and preparations are falling behind schedule which now need a reboot with a clear set of roles and responsibilities and a plan of action to produce the report by 31 July 2024.
6 March 2024
PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry, has responded today (6 March 2024) to the Chancellor of the Exchequer’s proposal to introduce a British ISA limited to investing in British companies in today’s Budget, raising concerns that there will be little appetite for yet another ISA.
Simon Harrington, Head of Public Affairs at PIMFA, comments: “While we strongly believe in the principle that retail investors can and should be encouraged to play a positive role in supporting UK businesses with private capital, it is not immediately clear to us that the British ISA represents anything more than a policy announcement in search of a headline.
“We see very little appetite to offer such a wrapper while the operational burden, which this would place on firms suggests that even if appetite were there it seems unlikely that firms would want to offer it.
“If the Government is really committed to reviving retail investment in UK PLC we would suggest simpler measures like a reduction or abolition of Stamp Duty on share purchases rather than the introduction of yet another ISA into the market”.
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NOTES TO EDITORS
About PIMFA – the Personal Investment Management & Financial Advice Association
Contact
For further information on this release or other press matters please contact:
PIMFA Communications and PR – +44 (0)20 7382 0376 .
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869.
5 March 2024
PIMFA WealthTech, the market network and technology platform created with principal strategic partner Morningstar, a leading provider of independent investment insights, has today (5 March 2024) launched its latest ‘Tech Sprint’ this time focused on Environmental, Social and Governance (ESG) factors.
FinTechs active in this area are invited to participate in, and demonstrate how, their technologies and solutions can make a difference to ESG and sustainable finance reporting, verification and disclosure.
If you are a FinTech, which fits the criteria and can demonstrate to wealth managers how your technology can benefit clients with the use of Morningstar data, please complete the registration form here for more information. Registrations are open now and will close on Friday, 15 March 2024, at 5pm.
PIMFA WealthTech is seeking high-growth, market-innovating scale-up firms, which are typically post Seed/Series A funding. FinTechs should have a demonstrable minimum viable product and, ideally, already be engaged with the financial services sector, although this is not essential.
Participating FinTechs will need to demonstrate how Morningstar datasets can be incorporated within their respective solutions, with a preference for solutions that utilise APIs, Open Data and Artificial Intelligence (AI).
A briefing session for chosen FinTechs will be held on 20 March, and FinTechs will be invited to showcase their solutions at the Morningstar Investment Conference on 1 May.
ESG and sustainable finance are a priority area of focus not only for wealth managers and advice firms, but also the Financial Conduct Authority (FCA). PIMFA, the trade association for the wealth management, investment services and the investment and financial advice industry, is taking a leading role in supporting the development of new guidance in partnership with the FCA to ensure the information provided to consumers is clear and consistent and so as to eradicate, where possible, the detrimental impact of the phenomenon known as ‘greenwashing’.
Research conducted by PIMFA last year, conducted in association with Alpha FMC a specialist management consultancy for the wealth and asset management industries, indicates the ESG data market is becoming increasingly challenging for firms to navigate, that technology solutions in this area will become invaluable and that using innovative technology, such as AI could prove vital for integrating all aspects of ESG and sustainable finance into a firm’s offering and operations. For example, where providers can help to aggregate, analyse and populate information needed for climate-related disclosures at an entity, product or consumer-facing level.
Morningstar and PIMFA WealthTech have over the past 12 months collaborated on a number of ‘Tech Sprints’ to address common issues within the wealth management and advice sector where new technology could offer the most effective solution for all parties.
The first Tech Sprints in 2023 examined how customer-focused technology can be deployed to support the needs of wealth managers with the requirements of Consumer Duty. Subsequent Tech Sprints in late 2023 focused on how new technology and Fintech providers can support wealth managers and advisers with client profiling, onboarding and experience.
PIMFA WealthTech has been created to address digital business transformation through the development and adoption of market-leading technologies. As a digital marketplace and industry network. PIMFA WealthTech’s objective is to drive innovation and enhance collaboration between FinTechs and wealth management and advice firms, operating an Advisory Council of leading wealth management and financial advice practitioners that cover all segments of the sector.
Richard Adler, Executive Director of PIMFA WealthTech, commented: “ESG and Sustainable Finance is a top priority for PIMFA members, with the recent FCA sustainability disclosure requirements and investment labels policy a key step for increasing trust in sustainable investments.
“The role technology can play in helping our members meet new requirements and serve their clients better has the potential to be enormous. We’re delighted to be working with Morningstar on this important Tech Sprint and invite FinTechs in this space to participate and demonstrate to the wealth management industry the type of innovation and support they can offer.â€
Anastasia Georgiou, Director of Client Solutions, Adviser Segment, EMEA, Morningstar, commented: “We are proud to continue our longstanding strategic partnership with PIMFA WealthTech to showcase new technology solutions from FinTechs to the Wealth sector.
“Today, firms need to generate insights and ideas for sustainable investments and position new offerings in the market. This includes identifying innovative ways to address the challenge of harnessing the vast amount of data available which is needed to provide accurate reporting and disclosures. Along with PIMFA, Morningstar is proud to help promote new solutions to help firms identify ESG risks and create new opportunities for clients.â€
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About PIMFA WealthTech
PIMFA WealthTech is part of the Personal Investment Management & Financial Advice Association (PIMFA), the trade association for the wealth management, investment services and the investment and financial advice industry, spanning 13,000 regulated firms that collectively manage the interests of almost £1.7trillion.
It believes that collaboration is essential to solving industry challenges and brings together senior industry decision-makers to address the most important and complex questions concerning technology focus, partnering and adoption as it applies across the value chain.
Our market network and technology platform has been created to bring the most innovative and relevant WealthTechs to our sector. Our teams work alongside leading financial institutions to identify, prototype and deliver enhancing technologies and breakthrough solutions that generate competitive advantage and business impact.
Further information can be found at pimfawealthtech.com
About PIMFA
About PIMFA – the Personal Investment Management & Financial Advice Association
About Morningstar, Inc.
Morningstar, Inc. is a leading provider of independent investment insights in North America, Europe, Australia, and Asia. The Company offers an extensive line of products and services for individual investors, financial advisors, asset managers and owners, retirement plan providers and sponsors, and institutional investors in the debt and private capital markets. Morningstar provides data and research insights on a wide range of investment offerings, , including managed investment products, publicly listed companies, private capital markets, debt securities, and real-time global market data. Morningstar also offers investment management services through its investment advisory subsidiaries, with approximately $286 billion in assets under advisement and management as of Dec. 31, 2023. The Company operates through wholly- or majority-owned subsidiaries in 32 countries. For more information, visit www.morningstar.com/company. Follow Morningstar on X @MorningstarInc.
Contact
For further information on this release or other press matters please contact:
PIMFA Communications and PR – +44 (0)20 7382 0376
Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk, +44 (0)20 7011 9869 / +44 (0)7979 493225
PIMFA has the pleasure to announce that the date has now been set for the upcoming PIMFA Senior Leadership Summit & Dinner 2024.
The event is open to senior member firm colleagues and strictly by invitation only. The aim is to provide a forum where relevant content will be presented and an opportunity for you to network with your peers will be provided.
The event is open to Wealth Management firms CEOs and nominated guests only.
If you have any interest in sponsoring or have any questions about this event please email events@pimfa.co.uk
SHORTLIST ANNOUNCED
CONGRATULATIONS TO ALL FINALISTS
PIMFA is the trade association for the wealth management, investment services and financial advice sector. One of its roles is to promote talent, diversity and inclusion within this space, highlight best practice and develop initiatives to help build an industry which better reflects its increasingly diverse customer base.
There are many instances of good practice which remain hidden or unrecognised. Businesses both large and small will have examples of innovation aimed at improving their inclusivity and performance, which in turn drives positive change across the industry.
Further, there is a stream of exceptional, diverse talent coming up through the ranks in our industry that is changing businesses for the better, engendering greater support for diverse communities and clients, and helping to develop and lead innovation.
We have launched the PIMFA D&I Awards to celebrate this.
The Awards are FREE to enter and open to all firms and stakeholders in the sector – you do not have to be a PIMFA member to enter.
Please see the 2024 timeline below:
April 10 – Entries are open
June 21 – Entries close
WC July 15 – Shortlist announced
October 10 – Winners announced
For further information and to see this year’s categories and criteria click here
If you have any questions about booking your table for the 2024 Awards ceremony, please contact PIMFA’s Events Team on events@pimfa.co.uk.
Awards ceremony details:
Date: October 10
Time: 18:30 – late
Venue: InterContinental Hotel, Park Lane, London
More information about the awards can be found here
Change is happening, both at a macro level and within our industry. Governments are legislating for mandatory sustainability disclosures and new rules and regulations are constantly being announced while impacts on firms are still being evaluated. The PIMFA ESG Seminar aims to provide attendees with the latest information firms will require to ensure they are ready for what is coming and the opportunities these changes will create for their clients and the sector.
Numbers will be restricted to ensure attendees not only benefit from hearing from subject matter experts addressing them, but also have the opportunity to participate in a discussion on the key themes with peers under the Chatham House Rule. Themes for the seminar will include…
To access the PIMFA member discount you will need to log in to your account first.
Event Details:
Date: 19 June 2024
Times: 09:00 – 16:30
Venue: Fidelity International, 4 Cannon St, London EC4M 5AB
If you would like to discuss speaking or sponsorship opportunities please email events@pimfa.co.uk