The growth of Investment Platforms and how Post Trade services are evolving – Clearstream
The PIMFA HR Briefing, supported by the employment team at Clyde & Co., is an engaging, deep-dive review of the most pressing HR concerns that impact PIMFA member firms. In each quarterly online session, we tackle real HR issues and collectively provide new perspectives, ideas and solutions that senior HR, DEI, Talent and L&D professionals within Wealth can immediately put into practice.
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In April, the FCA announced that it will no longer bring forward proposals requiring many firms to develop a diversity and inclusion strategy, collect and share data, and set targets to address underrepresentation. That said, the regulator still believes that DEI can deliver improved internal governance, decision-making, and risk management. Contrast this with the rollback on DEI initiatives by the US government with many firms like Google, META, and Adobe following suit and scaling back their diversity, equity, and inclusion (DEI) efforts; where does that leave HR in the UK advice firms leading and managing their firms’ DEI initiatives?
In this session of PIMFA’s HR Briefing, delivered by the employment team at Clyde & Co., HR leaders will share their strategies and approaches to DEI, equality, and weaving inclusivity into the fabric of workplace culture.
You won’t want to miss this discussion, so secure your FREE place today!s
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:
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:
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:
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:
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
Read this article from the PIMFA Journal #33 by Richard Doherty and Sumit Johri at Publicis Sapient about the traditional playbook built on manual processes, siloed business and technology functions, and relationship-driven models is no longer sufficient.
Wealth management services, financial advice and financial planning are part of a diverse financial market within the UK, and there is a general expectation that it will continue to grow as it looks to utilise innovative thinking to provide new services and integrate digital and human capabilities to offer targeted, self-service products and personalised investment advice.
Our industry helps people navigate the difficult financial decisions needed throughout the various stages of their life. These professionals provide valuable expertise and support for people to better understand the financial decisions before them and help tailor solutions specifically to their needs and circumstances.
Through advice, execution or discretionary services our industry helps individuals achieve the goals that are important to them, be it saving for retirement, being able to support their family or a myriad of other things.

Used well it can substantially improve the lives and wellbeing of people in a myriad of ways, helping them to achieve their ambitions and lifegoals.
However, criminals can seek to abuse the system, and financial crime, defined as ‘any kind of criminal conduct relating to money or to financial services or markets’, including fraud, terrorist financing, money laundering, sanctions, boiler rooms, impersonation etc and it currently costs £38.3bn* a year in the UK.
If you are an investor, it is very important to make sure you use a reputable, regulated firm, be aware of your rights around compensation and appeal if things do go wrong and know how to protect yourself and your savings.
If you are a wealth services and advice professional there are a myriad of developments, innovations and challenges in this space, and PIMFA is leading the way on representing members and their clients’ interests to government and regulators through constructive advocacy. We also provide a wide array of support in the form of practical guides, CPD events and learning, committees, resources and more.
Find out more about our financial crime work and cyber security work.
17 June 2024
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.”
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.
Our expert team address firms’ specific queries and provide support when it’s needed most – while also giving a useful indication of where the rest of the industry’s thinking lies. We work continuously to help our members stay ahead of ever-evolving regulations, empowering them to remain compliant and proactive in a challenging regulatory environment so their businesses can thrive.
Members can also access, for free or at a discount, our training courses, academies, webinars and podcasts, through which our member firms can ensure their staff are keeping up to date with the latest changes and innovations while also remaining compliant and proving their commitment to continuous professional development.
Alongside these initiatives, PIMFA provides a wealth of resources to support our members to ensure they are fully equipped with the latest insights and practical guidance on industry developments.
For example, in the last year alone we published expert analysis via more than 90 publications in the form of member-only guides, consultation papers, whitepapers, magazines and newsletters, facilitating thought leadership and supporting understanding across key topics such as Customer Vulnerability, the Future of Supervision, Consumer Duty, ESG and Artificial Intelligence.
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