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The Year That Was To Come: KPMG’s Regulatory Reflections and Predictions

In this podcast, Philip Deeks, Head of KPMG's Regulatory Insight Centre, shares how PIMFA member firms can snatch victory from the jaws of regulatory pressure in 2025. And whilst we take time on this podcast to look back - with some relief - on 2024, Philip shares KPMG's expectations and predictions as to how, over the next 12 months, wealth managers and financial advisers can seize, in his words, 'regulatory dividend' in the face of unprecedented regulatory change.

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Brexit

The UK's departure from the EU, requiring regulatory adjustments to ensure financial stability and consumer protection.
Hear from leading industry experts on the key issues facing compliance professionals in the investment management and financial advice world. Bringing together a high-level audience who can engage with the…
£275.00 – £590.00
Date & Time: 24th Sep 2026 (8:00) - 24th Sep 2026 (17:00)
CPD: TBC Location: Herbert Smith Freehills Kramer

PIMFA Key Successes Overview 2025/26

Read the overview of how we are continuing to deliver meaningful change and value. Looking at our successes over the last year in Policy and Advocacy and Regulation and Compliance, with an overview of PIMFA Groups, Event Highlights and Awards.

Shared Type: Shared Public
Published: March 27, 2026

A Fresh Perspective on Supporting Customer Vulnerability

In this podcast, David Ostojitsch and Alex Roberts from PIMFA discuss the importance of addressing customer vulnerability in financial services. They explore PIMFA’s newly launched ‘Customer Vulnerability Guide’. The conversation covers the challenges firms face in identifying vulnerable customers and the need for a supportive organisational culture. Additionally, they highlight the potential of technology to help identify vulnerabilities and offer resources to enhance firm practices.

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Customer Vulnerability

Where consumers may be more susceptible to harm, requiring firms to provide fair treatment, support, and tailored services.
Hear from leading industry experts on the key issues facing compliance professionals in the investment management and financial advice world. Bringing together a high-level audience who can engage with the…
£275.00 – £590.00
Date & Time: 24th Sep 2026 (8:00) - 24th Sep 2026 (17:00)
CPD: TBC Location: Herbert Smith Freehills Kramer
The purpose of the Regulatory Board Sub Committee is to advise PIMFA on all regulatory matters of significance to its...

Avyse Partners – FCA Focus on Stockbrokers – s166 Skilled Person Reflections

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:

  1. 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.
  2. 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.
  3. 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.

Weareverve.co.uk

Jo Campbell, Chief Operations Officer, Verve

The Accelerated Settlement Taskforce Technical Group – UK Implementation Plan for first day of trading for T+1 settlement – 11th October 2027

PIMFA Webinar: M&A in Wealth: Trends and Predictions in 2025

With yet another eventful year for M&A now behind us, what does 2025 hold for M&A activity in wealth and personal finance? In this free 60-minute webinar, we ask sellers, acquirers, advisory firms and M&A experts their views and opinions on:

  • Will deals continue in 2025? If so, at what pace?
  • Why consolidation trends remain robust among smaller firms.
  • What makes for a successful, credible deal in 2025?

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.

Why Wealth Management Firms Must Prioritise PEPs and Sanctions Screening

By employing PEPs and sanctions screening tools, wealth management firms can identify and avoid high-risk individuals and entities. Integrating AML practices ensures a transparent operating environment, fostering client confidence and preserving the firm’s integrity.

Achieving and Maintaining Regulatory Compliance

Regulatory expectations in wealth management are stringent, with a strong emphasis on preventing money laundering and financial crime. The FCA has highlighted its intrusive supervisory approach, with unannounced visits and increased scrutiny of firms’ compliance measures. Non-compliance could lead to severe penalties and legal ramifications.

PEPs and sanctions screening solutions enable firms to meet these regulatory requirements by flagging politically exposed and sanctioned individuals. Robust AML screening, ensures adherence to regulatory frameworks, helping firms avoid costly penalties and demonstrating their commitment to ethical operations.

Mitigating Risk

Due diligence is a cornerstone of wealth management, where the stakes are high, and risks must be meticulously managed. PEPs and sanctions screening solutions empower firms to conduct thorough background checks, uncovering potential risks associated with politically exposed clients or blacklisted entities. By proactively addressing risks, wealth management businesses can protect their clients, assets, and reputation.

Driving Operational Efficiency

Manual AML compliance processes can hinder the efficiency of operations, causing frustrating delays when onboarding high-value clients and increasing operational costs. Automated PEPs and sanctions screening, powered by advanced AI, accelerates onboarding, ensuring real-time due diligence with accurate results.

Screening tools that incorporate AI reduce the burden on compliance teams by catching sophisticated AI-fraud and reducing instances of inaccurate false-positive results. When AML compliance with regulatory standards is automated and accurate, this frees wealth managers and advisors to focus on client engagement and strategic growth.

Strengthening Global Collaboration and Information Sharing

The fight against financial crime transcends borders, requiring cooperation across industries and jurisdictions. For wealth management firms operating internationally or with diverse client bases, access to up-to-date information on PEPs and sanctioned entities is critical.

Leveraging shared databases and collaborative networks enhances the accuracy of screening processes, aligning firms with global efforts to combat financial crime. This proactive approach reinforces the firm’s standing as a responsible participant in the financial ecosystem and supports long-term sector resilience.

Conclusion: A Call to Action for Wealth Management Firms

Wealth management companies operate in a high-risk, high-trust environment where client relationships and compliance are paramount. Ignoring the risks posed by money laundering, terrorist financing, and other financial crimes is not an option. By prioritising PEPs and sanctions screening alongside AML compliance and electronic identity verification, wealth management firms can safeguard their reputation, mitigate risks, and improve operational efficiency.

Adopting these measures is not only a regulatory requirement but also a step towards building a more transparent, secure, and ethical financial future. Firms that embrace these practices will be better positioned to navigate the complexities of the financial landscape, delivering exceptional outcomes for their clients and stakeholders.

Key Takeaways

  • Robust Screening is Essential: Wealth management firms must implement effective PEPs and sanctions screening to protect against money laundering, terrorist financing, and other financial crimes.
  • Reputation is at Stake: Failing to screen clients properly can result in reputational damage, loss of client trust, and diminished market standing.
  • Regulatory Compliance is Non-Negotiable: Adhering to stringent AML regulations is critical to avoid penalties and maintain operational integrity.
  • Proactive Risk Mitigation Pays Off: Enhanced due diligence processes reduce exposure to high-risk individuals and entities while safeguarding firm operations.
  • Efficiency and Collaboration Drive Success: Leveraging technology for automated screening and engaging in global information-sharing strengthens financial crime prevention efforts.

If you would like to discuss how digital identity verification and AML screening can benefit your wealth management practice, please feel free to email me: alex@id-pal.com or connect with me on LinkedIn here.

Alexander Blayney, Head of Strategic Partnerships and Enterprise Sales, id-pal

O-IM Three Years Of Solid Performance

O-IM’s Investment Team will reflect on their three-year track record, discuss the key drivers behind the performance, and share their outlook for the months ahead.

For more information contact john.muir@o-im.co.uk, 07821 535587 or click here.

Authentic Leadership Prospectus

Operational Resilience: Protect Investors & Enhance Compliance

Disruptions to critical, or important business services can have far-reaching consequences not just for the financial services, but national economies and consumers.

In this event, Ruleguard provides a snapshot of the UK’s operational resilience framework, outlines key requirements of the EU’s Digital Operational Resilience Act (DORA) and how operational resilience aids transparency and builds trust with consumers.

For further information click here.

Our Work

Our mission is to help create a UK culture of thriving financial health through constructive advocacy, creating connections and practical support.

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Artificial Intelligence

Technology using algorithms and data to enhance decision-making, improve efficiency, and manage risks.
What’s now possible for wealth firms when AI meets Consumer Duty? …
Free
Date & Time: 22nd Jun 2026 (8:45) - 22nd Jun 2026 (13:30)
Location: Marloo UK Ltd

The Wealth and Asset Management Operating Model Can’t Keep Up

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.

Shared Type: Shared Public
Published: April 28, 2026

PIMFA Webinar: The Duty to Prevent Sexual Harassment

On 26 October 2024, a new section of the Equality Act 2010 came into force, placing a new duty on firms to take reasonable steps to prevent the harassment of a sexual nature of workers in the course of their employment.

In this FREE 60-minute webinar, employment law experts from DAC Beachcroft LLP will explore what the newly established legal obligation is, means in practice and what steps should be taken to avoid falling foul of the new law as well as for employers regarding the prevention of sexual harassment in the workplace taking a deep-dive look into how PIMFA member firms, can simply and effectively create a culture of accountability and openness, where employees feel empowered to report incidents of any form of harassment without fear of retaliation.

Time has been set aside on the webinar to ask our experts how these changes impact your firm’s responsibilities and employee rights, showcasing how leading firms are building a safer and more inclusive work environment.

Key points discussed:

• What is the new duty?
• Key responsibilities of employers
• Recognising, addressing, and preventing harassment
• Reasonable steps
• Strategies for encouraging bystander intervention and promoting respectful workplace behaviour.
• Consequences of non-compliance
• Can we expect further change?

Wealth Management: Finding the Industry’s iPod Moment

Wealth Management: Finding the Industry’s iPod Moment

When I left my first city job back in 2006, my colleagues gifted me an iPod. At the time, I didn’t fully grasp its value and left it boxed for over a year. Eventually, I gave it a go, and it completely transformed the way I experienced music. My CD collection, once a source of pride, was relegated to memorabilia, later encased in a friend’s clear flooring—a quirky reminder of the shift in how music was consumed.

This experience feels oddly parallel to where we stand in WealthTech today. The industry is brimming with innovative technology, but its value remains underappreciated or misused. Much like my pre-iPod music world, wealth management is struggling with outdated systems and the challenge of integrating new tools into a legacy infrastructure. Without a unifying leap forward—a “Bluetooth moment”—we risk limiting the full potential of emerging advancements.

The Industry’s Tipping Point

Nearly half of IFAs (Independent Financial Advisers) are expected to retire in the next five years. This inevitable shift is fuelling a wave of consolidation and represents a golden opportunity for the next generation of business leaders to reshape the status quo. Digital transformation is no longer optional; it’s essential. However, transformation doesn’t have to mean adopting fully automated robo-advisors. Instead, it’s about harnessing technology to improve efficiency and refocus on what truly matters: building relationships and delivering value.

A significant roadblock is integration—or the lack thereof. Across the supply chain, too much time is spent transferring data manually between systems. In few other sectors do key personnel waste so much time wrestling with outdated processes. My iPod moment came when a colleague helped me load my entire music library. Suddenly, I had access to a vast collection, streamlined for every context: jogging, reminiscing, or hosting a party. It revolutionised my relationship with music, much like better integration could redefine wealth management workflows.

Streaming, But Not Yet Streaming-Ready

In a previous blog, I touched on the need for streaming-style services in wealth management: low-cost, high-accessibility, and client-centric solutions. But the reality is that many businesses aren’t ready for this kind of disruption. Without tackling the challenge of integrating legacy systems, the industry risks skipping a crucial evolutionary step.

Wealth management has yet to experience its iPod moment, let alone its Spotify revolution. To unlock the benefits of cutting-edge technology, we must first embrace solutions that bring cohesion between the old and the new. The tools for automation and AI are already accessible; what’s missing is a willingness to take that leap, often requiring a champion within the organisation to show the way.

Platform 3.0:

Consider the emergence of Platform 3.0, the new generation of investment platforms. These promise richer functionality, tighter integration, and even innovative business models, such as Adviser-as-a-Platform. However, integration challenges remain. Asset allocation processes, for example, are still disconnected. Similarly, portfolio products rely on a supply chain push model with minimal coupling due to a lack of straight-through processing. Advisors influence where assets are directed, but the upstream inefficiencies often go unnoticed.

In an integrated ecosystem, the industry could achieve far more. Advisors could offer bespoke products tailored to specific investor groups, while discretionary portfolio managers could keep allocations aligned with greater precision. Platforms would better manage liquidity and inventory, and fund managers at the top of the chain could expedite the release of funds and special share classes. The result? More choice, lower costs, enhanced risk management, and improved outcomes for end investors.

Andrew Spence, of Aspen Advisers, has often presented the game changing effect that multi-platform integration could have on the model portfolio (MPS) landscape.

Commenting on his vision, he stated that “The Aspen business was initially going to be fully customisable portfolios – the optimal mix of assets for a client’s circumstances and needs – in a move away from traditional “cookie cutter” models. But it was a non-starter across multiple platforms. So, we needed to scale that back and offer advisers a complete CIP experience using model portfolio building blocks. Still, multi-platform integration of this scale takes time and resource. Better integration is badly needed”.

Tikker are working with Aspen to automate Portfolio Operations cross-platform, bringing this evolution within reach.

Overcoming the CD Era

Right now, the wealth management industry feels stuck in its pre-iPod phase—juggling stacks of CDs, painstakingly organising them, and dealing with inefficiencies that make progress feel like an uphill climb. Worse still, these inefficiencies ripple through the supply chain, consuming valuable time and increasing the risk of errors.

What’s needed is an iPod moment: a unifying system that bridges legacy technology and modern tools, streamlining processes to unlock new possibilities. With integration and automation, the industry can shed its clunky inefficiencies, empowering advisors to focus on delivering genuine value to clients.

The Next Generation’s Opportunity

The next wave of wealth management leaders holds the key to this transformation. They must embrace technology not as a threat but as an enabler of better client experiences and operational efficiencies. This might mean prioritising solutions that balance creditworthiness with operational risk, acknowledging the role of custodians in securing holdings.

By bridging the gaps between legacy and modern systems, the industry can evolve into something far greater. The question is whether today’s leaders will seize the opportunity—or let it pass, leaving the wealth management sector to languish in an outdated era. For those ready to embrace change, the tools are already within reach. What’s needed now is the courage to press play.

 

Tom Whittle, Founder, Tikker

tom.whittle@tikker.co.uk

ASG Meeting Notes 17 October 2024

PIMFA Response Papers

PIMFA responds on behalf of our membership to numerous key issues within our industry.

PIMFA Response Papers

PIMFA responds on behalf of our membership to numerous key issues within our industry. We do this via vital feedback and discussion with member firms via our committees, working parties and industry forums.

From this member feedback PIMFA create responses to consultation documents and discussion papers issued by bodies such as the UK’s regulator, the Financial Conduct Authority (FCA), Government departments and many European and International bodies.

Found 235 Results
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: May 22, 2026
Paper Type: PIMFA Response Papers
Recipients: Home Office UK
Month Published: May 18, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: May 12, 2026
Paper Type: PIMFA Response Papers
Recipients: Cabinet Office
Month Published: May 7, 2026
Paper Type: PIMFA Response Papers
Recipients: HM Treasury
Month Published: April 9, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: March 31, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: March 6, 2026
Paper Type: PIMFA Discussion Papers
Recipients: UK Listing Authority (managed by the FCA)
Month Published: March 6, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: February 20, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: February 19, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: February 2, 2026
Paper Type: PIMFA Response Papers
Recipients: The Financial Ombudsman Service (FOS)
Month Published: January 27, 2026

The scope of regulation is increasing all the time and one of PIMFA’s key objectives is to ensure this regulation is proportionate and fair, bringing real benefits to the investment management and financial advice community and their clients.

Past consultation responses from WMA and APFA can be accessed via their respective archives.

PIMFA Journal Edition #29

Can NextGen tech make wealth management more human?

Why investing in wellbeing makes financial sense

Border Control: Why Offshoring is not Always Good for KYC Operations

Third-Party Risk Blind Spots: Are You Leaving Your Business Exposed?