The Personal Investment Management & Financial Advice Association (PIMFA)

Dictionary

Login Home
Filter by Topics

Ongoing servicing: FCA findings for firms

The FCA’s commentary on ongoing servicing is something that we’ve all been talking about for a long time, and the findings have finally been released from the sample of advice firms reviewed.

The study found that in 83% of cases, ongoing reviews were carried out in line with service propositions; in 15% of cases clients had declined or not engaged with the request for information to conduct a review, while in 2% of cases firms had made no effort to conduct the review as part of the ongoing service the client was paying for.

Firms should take a sample of their own ongoing service clients to review and draw conclusions: are you meeting service standards, and if not, what are the next steps?

How firms can review their own ongoing servicing

When reviewing ongoing servicing, firms should take an original sample of ongoing service clients, ensuring it is representative of overall time periods, advisers, client type (accumulation/decumulation), service level, changes to systems or software and any acquisitions.

You should keep a record of the sample reviewed and your methodology used.

As part of your firm review, you should consider:

  • Where was the service set out? Terms of Business, Client agreement, suitability reports?
  • What did you agree to? Ongoing reviews? Frequency? Who was responsible for initiating them?
  • Did you do what you said you would do? If you didn’t, why? Did the client decline a review, no response, no firm action?
  • What was done as a result? Was the service agreement clear on the action taken for non-delivery and was action taken in line with this?

Ensure that your findings of the review are recorded and retained on file.

If you fall into the 83% of firms where you have met your service standards, and no redress is due, great!

Ensure that you keep a record of these findings and the work you have carried out on file and update your systems and controls document to reflect this.

What should firms do if redress is appropriate?

If you have deemed redress to be appropriate, are you comfortable with what the next steps are and how to calculate the redress due?

Questions to ask around redress include:

  • Is it calculated on a pro-rata basis? A client may not have had a review, but what did the rest of your ongoing service cover e.g performance reviews, arranging transactions, other contact throughout the year?
  • Do you consider the ongoing review to be the full service and therefore a full refund is due?
  • Have you considered lost investment growth, interest or any consequential losses (change in circumstances that would have changed the recommendation)?

Ensure all these factors are considered and you have a consistent firm approach to calculating this redress going forwards.

It’s unlikely that PI will cover any redress due for lack of service, so ensure that you have sufficient capital held to cover the liability.

Next steps for firms reviewing ongoing servicing

After reviewing your ongoing servicing and drawing conclusions, the next steps are:

  • Ensure that your service proposition, cost and frequency of reviews is clear and disclosed in the terms of business.
  • Keep a clear scheduling review process and evidence it. Are there limitations within your back office in terms of providing this data? Have you identified a training need? Now is the time to fix this as this will be key MI data going forwards.
  • Define a process to monitor the quality of your reviews and ensure consistency e.g. reassessing risk (attitude to risk, capacity for loss).
  • Get a clear non-interaction policy in place. Do you do desk-based reviews? After 1 year? 2 years? Not deem them appropriate? How are you re-confirming client objectives? Disengage unresponsive clients? Record the rationale behind this policy.
  • If you disengage – think about vulnerabilities and solutions that don’t require an adviser.
  • If making a refund of fees ensure you keep a record of this.
  • Good record keeping; are clients receiving written output?
  • MI – ensure this is continually monitoring quality and delivery of reviews.

In addition to this, as part of Consumer Duty, firms should be consistently monitoring if clients with ongoing servicing  actually benefit from the service, or alternatively if they’re in the correct service level (for example, if a client has a lot of AUM in a top level of service but actually only has simple needs, their service level may need a review).

Suggestions for firms performing desk-based reviews

I also suggest firms consider their approach to desk-based reviews. Questions to ask around desk-based reviews include:

  • How confident are you that the information you have is up to date?
  • What if there was an update to client circumstances that you are unaware of and would immediately alter the recommendation; can you do a review and confidently confirm your recommendation is still suitable?
  • How do you address these potential issues; do you work with the client to engage before you can do a review?
  • Or do you deem the client not engaged and disengage with them?

If you do provide desk-based reviews, ensure that you clearly state that it is based on the information you have and anything you are unaware of may change your advice. If you do disengage with a client, consider any vulnerabilities clients have or this may cause.

What’s next from the FCA?

The FCA will be monitoring the work firms have done on carrying out their review of this ‘later in 2025’. Going forwards, the FCA will be working on these rules and has committed to policy work in 2025, and in 2026 will be doing data led supervision. Ensure that as a firm you’re not resting on your laurels and are proactive with your work on this.

This could be interesting given the current climate, the engagement of younger people who aren’t as engaged with meetings as other generations and want to rely on tech more; could we see scope for lighter touch services in the future?

For support with Consumer Duty, ongoing services or any other issues discussed in this article, contact Alanis Daniel at Verve using alanis.daniel@weareverve.co.uk.

Alanis Daniel
Compliance Consultant at Verve

PIMFA Summary of FCA – retail banking multi firm review on the treatment of customers in vulnerable circumstances (findings) April 2025

More about PIMFA

PIMFA Members

PIMFA’s membership is corporate and consists of two groups – Full and Associate member firms. Full members provide a range of financial solutions including wealth management, financial advice and planning and execution services. They assist everyone from individuals and families to charities, pension funds, trusts and companies.  Associate members provide professional services to the PIMFA community.

About Our Industry

Firms within the sector are also changing due to competition, M&A activity, heightened regulatory scrutiny, changing customer expectations, the need to invest in technology, and a talent shortage, which all impact decisions about the future of their firms.

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.

Read some of the industry thought pieces

You may also be interested in

Financial Crime

Protecting against activities like fraud, money laundering, and market abuse, threatening financial system integrity and consumer protection.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
The purpose of the Regulatory Board Sub Committee is to advise PIMFA on all regulatory matters of significance to its...

Protecting Investments

The UK wealth and advice sector is one of the leading global financial services centres and plays a pivotal role in the financial wellbeing of an increasingly wide range of customers. 

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.

You may also be interested in

Investment

The act of buying something such as a share in a company or other financial instrument with the hope of it increasing in value.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
The purpose of the Regulatory Board Sub Committee is to advise PIMFA on all regulatory matters of significance to its...

PIMFA’s Golden Rules of Investment

Read PIMFA's infographic on the Golden Rules of Investment.

You may also be interested in

Investment

The act of buying something such as a share in a company or other financial instrument with the hope of it increasing in value.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
The purpose of the Regulatory Board Sub Committee is to advise PIMFA on all regulatory matters of significance to its...

PIMFA calls for 12-month delay to implementation of Sustainability Disclosure Requirement rules for Portfolio Management

17 June 2024

 

PIMFA calls for 12-month delay to implementation of Sustainability Disclosure Requirement rules for Portfolio Management

 

PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry, has called on the Financial Conduct Authority (FCA) to delay the deadline for the implementation of Sustainability Disclosure Requirements (SDR) for portfolio management by 12 months, in order to allow firms sufficient time to implement the final rules.

While PIMFA is supportive of the intended purpose and spirit of the proposals put forward by the FCA, they fail to sufficiently take account of the unique requirements of the market for portfolio management and of retail investors.

In its response to the Regulator’s consultation, PIMFA has highlighted its significant concerns around the timing of the implementation. PIMFA has significant concerns regarding some of the proposals put forward by the Regulator and given those concerns, considers it may be unrealistic to believe the final SDR rules for portfolio management will be agreed by October. Even if they are, the final implementation deadline of 2 December does not provide adequate time for firms.

This would create a significant challenge for firms, placing considerable regulatory burden on them to complete structural work to meet the requirements for extending SDR to portfolio management in only six weeks.

PIMFA believes it is important to allow the SDR fund regime to embed properly, as the pace of implementation of the first tranche of SDR rules will influence portfolio management firms.

Firms in our sector will find it challenging to continue to work with some smaller fund houses and have them represented in their portfolios because these have not met the SDR labelling standards yet and will not adopt the labels for another year or two. This would unintentionally reduce choice of investments for portfolios and may affect end client outcomes.

Additionally, PIMFA is calling on the FCA to reconsider including bespoke portfolios in the SDR regime. Bespoke portfolios are not products, they are services, and more clarity is needed on how firms would be expected to apply a product label to a service-based investment approach.

PIMFA would also like to see the Regulator provide more clarity around the inclusion of overseas funds which are currently out of scope of the SDR and the role of portfolio manager when including them in portfolios. The current proposals make it difficult for investors to understand why SDR applies to some funds but not others making it difficult for them to make informed decisions.

Further, PIMFA would like to see the 70% threshold for labels lowered to avoid any unintended consequences for portfolio managers and avoid potential confusion that a lower risk portfolio cannot be sustainable. Portfolio managers may have a sustainable label for their higher risk portfolios (which will be heavily weighted towards equities) but not for their lower risk portfolios. This could be the case even though the underlying assets were the same, just in different weightings. This would imply that sustainable labels are only for higher risk (and higher return) portfolios.

Maja Erceg, Senior Policy Adviser EU and Government Affairs, PIMFA at PIMFA commented: “We are broadly supportive of the work the FCA is doing around SDR but the timing to agree the rules for portfolio management firms let alone implement them is not merely challenging, it is close to impossible.

“We have specific concerns around both the timeframe as well as labelling, which could cause confusion for retail investors, making it difficult for investors to understand why SDR applies to some funds but not others, such as overseas funds. This will make it challenging for consumers to make informed decisions about their investments.

“It is vital that these rules are agreed and implemented correctly. In order for these proposals to successfully meet the policy objectives, we strongly believe that it would be better to delay the implementation period by 12 months in order to give firms the time to comply with these rules.”

<ENDS>

 

NOTES TO EDITORS

About PIMFA – the Personal Investment Management & Financial Advice Association

Read PIMFA’s agenda: ‘Creating a UK Culture of Thriving Financial Health’ here.

• PIMFA is the trade association for firms that provide wealth management, investment services and the investment and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.

• The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.

• PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including financial advice, portfolio management, as well as investment and execution services. They assist everyone from individuals and families to charities and pension funds, all the way to trusts and companies.  Associate members provide professional services to the PIMFA community.

• PIMFA  leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena. Our mission is to create an optimal operating environment so that its member firms can focus on delivering the best service to clients, providing responsible stewardship for their long-term savings and investments.

• PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991.
Further information can be found at pimfa.co.uk

• Visit PIMFA’s public affairs web area here.

Supporting Practice

PIMFA are dedicated to providing hands-on guidance and practical support to our members on the wide-ranging issues across regulatory compliance and policy. We work to ensure that our members have all the latest knowledge and support available to enable them to navigate the complexities of the ever-changing landscape with confidence.

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.

Click below to read our 2024/25 successes report

Click below to read a summary of our 2024/25 successes

The MSCI PIMFA Private Investor Index Series

This index series has been in existence since 1997 (under different names) and consists of five composite indexes  and includes weightings of Equities, Fixed Income, Real Estate, Cash and Alternatives.

There are five composite indices , to reflect the differing aims of investors

  • the Conservative index
  • the Income index
  • the Growth index
  • the Balanced index and
  • the Global Growth index

This Index Series can provide

  • A basis for discussing and reviewing the asset allocation and structure of your portfolio with your fund manager or stockbroker.
  • A benchmark for assessing and comparing the performance of discretionary fund managers.
  • A measure to compare the performance of similar Income, Growth and Balanced based funds.

Helpful Resources

You may also be interested in

Indices

Used properly, an index series can provide a useful perspective in the world of stocks and shares to compare portfolio performance. PIMFA provides the methodology for the MSCI PIMFA Private Investor Index Series and Equity Risk Index Series and you can find out more information here.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
This committee is responsible for ensuring the current asset allocations of the PIMFA / MSCI Private Investor Index and the...

The MSCI PIMFA Equity Risk Index Series

This series was launched on 1st November 2019 following the changing demands of the market and our members. It consists of five composite indices and includes weightings of equities, bonds, real estate and “alternative” investments based on the strategic asset allocations (SAA) of PIMFA member firms grouped by the percentage of equities held in the strategies.

The Equity Risk Index Series has five composite indices, to reflect the differing aims of investors

  • Equity Risk 1 Index (RBI 1) – Equity 10 – 25%
  • Equity Risk 2 Index (RBI 2) – Equity 26 – 46%
  • Equity Risk 3 Index (RBI 3) – Equity 47 – 66%
  • Equity Risk 4 Index (RBI 4) – Equity 67 – 85%
  • Equity Risk 5 Index (RBI 5) – Equity 86 – 100%

This Index Series can provide

  • Risk characteristics to align to client risk profiles more readily.
  • These represent the strategic asset allocations of member firms to help firms/individuals understand long term strategy of the UK market.
  • Created due to demand from member firms who wished to see a new range of indices based on this new methodology.

Helpful Resources

You may also be interested in

Indices

Used properly, an index series can provide a useful perspective in the world of stocks and shares to compare portfolio performance. PIMFA provides the methodology for the MSCI PIMFA Private Investor Index Series and Equity Risk Index Series and you can find out more information here.
Following from the HUGE success of the PIMFA Women’s Symposium 2025, we are delighted to announce details of the 2026 event. …
£350.00 – £1,100.00
Date & Time: 19th May 2026 (8:00) - 20th May 2026 (17:00)
Location: London excel
This committee is responsible for ensuring the current asset allocations of the PIMFA / MSCI Private Investor Index and the...

Strategic, sustainable and selective: 3 ways to manage retirement income

Retirement income, and certainly generating a sustainable income, is a very different kettle of fish when compared to investing where long-term growth is the primary objective; at the very least there are additional considerations around risk, capacity for loss, investment performance (returns and volatility) and investment philosophy.

There are three main ways to manage flexible pension drawdown for income. There is also no right answer as all three methods have their own benefits and drawbacks that should ideally be linked to the client’s circumstances; also not forgetting the role that annuities can play, which we will cover later.

Method 1: Safe withdrawal rate

The first method is the tried and tested ‘safe withdrawal rate’ where retirees should theoretically be able to draw down 4% of the value of their invested pension per annum from a balanced portfolio (60:40 equities and bonds) without it affecting the capital.

The main benefit is that this method is simple to set up and manage – less time spent on managing nuances within this drawdown process in turn means it costs less to deliver. Coupled with the fact that the concept is relatively easy for the client to understand (hello Consumer Duty), particularly if they’re lacking knowledge and experience.

The main drawback is that it doesn’t address sequencing risk, meaning that the strategy is more susceptible to ‘pound cost ravaging’ (i.e. having to sell a greater number of fund units to achieve the same level of cash income once sold) in falling markets.

This style of strategy typically lends itself to clients who have relatively straightforward income needs from a single wrapper; or for those clients who are not looking for a long-term sustainable income and looking to draw down their pension pot to zero in their lifetime.

Method 2: Natural-income portfolio

The second tried and tested method is a natural-income portfolio. This is where the underlying investments are relied upon to generate an income yield through dividends and interest that are paid out from the investments rather than re-invested for growth.

A natural income portfolio is also relatively simple to set up and can be very tax-efficient, particularly if the assets are outside of a pension wrapper (retirement income needn’t all be about pensions!). Natural income is also relatively easy to monitor and manage once set up,  and is again a straightforward concept that the majority of advised clients will have little trouble understanding. As the types of underlying assets within an income portfolio are generally lower risk (cash, fixed income and large, mature company equities with a strong dividend yield) they can be useful for those clients of a lower risk profile.

However, there is no guarantee of the level of income as dividends, in particular, are not guaranteed and are relative to the capital value of the holding – not ideal in a market crash. Interest-rate risk also comes into play and will depend on prevailing market conditions (it is currently, as of April 2025, relatively high compared to the overall post-2008 landscape but is likely to continue falling progressively over the next few years). Natural income yields are also relatively low – typically (again, as at the time of writing!) between 3% and 4% per annum, with some higher-yielding strategies available that also come with higher risks on the capital side. Ultimately, this means clients will ideally have the combination of a large investment portfolio combined with a modest expenditure to get the best out of a natural income portfolio.

Method 3: Multi-risk bucket approach

The final method for flexible income is one that has really been picking up pace in recent years, and that is the Multi-Risk bucket approach (or cascading approach, or waterfall strategy, or potting strategy – take your pick!) The thinking behind this is to manage client assets over differing levels of risk to build additional resilience should markets drop. It needn’t be a market crash either, a bucketing approach can help ride out a stagnant or steadily falling market too.

There is no correct answer on how to run a bucketing strategy either – it can work with as few as two buckets with some discretionary fund managers using seven. The investment time horizons are also very much down to the preference of the advice firm, perhaps having to work around how a risk profiler works with some being easier than others. The most common approach here though is the three-bucket strategy with a set number of years’ income in cash (usually between 1-2 years) with 4-5 years in a ‘consolidation’ pot (purely to keep pace with inflation) with the remainder being invested in a higher risk portfolio to drive the long-term growth. The rationale here is that the client can comfortably ride out a 1-2 year period in the aftermath of a market crash without having to sell down their investment assets at a loss, perhaps a significant loss, and crucially can leave these assets invested for the inevitable recovery.

The main benefit of this style of approach is that, in theory, you can achieve the highest levels of investment growth whilst also having some protections in place for sequencing risk mitigation – during unfavourable market conditions, the process of topping up the lower-risk buckets can be switched off without detriment to the client (hello once again, Consumer Duty and prevention of foreseeable harm) for however long their cash bucket is able to fund their income.

A bucketing approach is a lot more hands-on to manage though, with multiple investment strategies to monitor in terms of performance and having to hold a review meeting at least every year where the buckets are rebalanced to ensure the strategy is ready to kick in should markets take a turn. This style of strategy also ideally needs a sizeable pot of invested assets (again, it doesn’t need to just be within a pension, but ISAs and GIAs can also play a valuable role) relative to the client’s desired level of income to operate to its maximum potential. Clients who are not well-versed in investments may also struggle to grasp the concept of how it works and be more likely to panic-sell assets from their high-risk growth pot in difficult market conditions; in light of Consumer Duty, this could be considered a foreseeable harm and care should be taken as to who this style of strategy could be suitable for.

It is very good practice to secure a client’s essential expenditure at the minimum with some form of guaranteed income before implementing any of the above drawdown processes. If a client’s State Pension or any Defined Benefit pension income (the two most common forms of guaranteed income) are not sufficient for this, then this is the perfect case for an annuity. As a very brief recap, an annuity will pay a certain level of income agreed at outset, over a certain time frame agreed at outset (can be fixed term if you are just bridging a gap for other forms of guaranteed income to come into payment or set up for a lifetime income) for an agreed initial lump sum payment or ‘premium’. Coming back to the prevention of foreseeable harm, securing a client’s essential expenditure with guaranteed income ensures they will be able to get by without potentially falling into income problems during retirement.

Concluding thoughts

In conclusion, there are many ways of going about securing a sustainable retirement income from invested assets and there is no perfect answer, or indeed even a correct answer. Any of the above approaches are viable but they must be considered alongside the client’s individual circumstances, the way your firm operates and, ideally, a cashflow forecast should be prepared to ensure the sustainability of income before proceeding with any strategy. Perhaps most importantly with the FCA not stating how retirement income should be managed it should have a robust rationale behind it. To quote my old maths teacher on the bigger and more complex questions “The examiner is not looking for the correct answer, they are looking for how you got to it” and I think that is a good mantra to follow when it comes to implementing a retirement income process.

Alasdair Wilson – Investment Specialist at Verve

The PIMFA Annual M&A Summit 2025

Register your interest to attend PIMFA’s M&A Summit HERE 

 Why attend 

  •  Get the inside track: We are witnessing a fundamental shift in the advice market. Regulators, acquirers and sellers are faced with a multitude of challenges and opportunities. Find out how they’re responding and reacting at the M&A Summit. 
  •  Maximise deal value: Discover from SEI how to build a comprehensive IT integration plan to ensure your firm reaps the benefits of a merger. 
  • Buy or sell with confidence: Grasp from legal experts Farrer & Co. how to maximise value at each stage of the M&A deal cycle. 
  • Avoid due diligence pitfalls: Learn from Square 4 partners how acquirers and sellers can conduct enhanced due diligence to uncover and mitigate any potential risks and liabilities and avoid greater regulatory scrutiny. 

Who Should Attend 

  • CEOs, managing directors, finance directors, and M&A leaders of acquiring firms who want to meet their buyer network face-to-face in a confidential environment, including corporate acquirers, private equity, sellers, and more.
  • Financial Advisors looking to gain vital information to help make an informed decision on how to sell their business.
  • Private equity investors and other key stakeholders in the sector seeking to meet and grow their network of deal referral sources. 

 

Register your interest to attend M&A Summit HERE 

 

Interested in sponsoring PIMFA’s M&A Summit? Reach out to Philip Allen, Head of Learning HERE 

AI and the Environment: A Double-Edged Sword for the Investment Industry

The adoption of AI remains a topic of debate. On one side, critics voice concerns about how AI might disrupt the workplace of wealth managers and advisers. On the other, proponents highlight its potential to boost productivity, reduce human error, and enhance cost-efficiency through automation and speed, and its potential to enhance the client experience. However, the promise of AI stands in a delicate balance with the growing emphasis on sustainability in investment practices.

A recent survey revealed that 62% of wealth management firms believe AI will significantly reshape their operations. This shift aligns with investor expectations for digital experiences on par with leading technology firms. Yet, the infrastructure powering AI, such as data centres, poses a substantial environmental challenge, generating vast amounts of e-waste and consuming significant energy.

The Promise and Paradox of AI in Sustainable Investing

AI could be immensely useful for sustainable investing. Its ability to verify and analyse data rapidly is a game changer, offering insights by processing vast quantities of structured and unstructured data into reliable, actionable information. This efficiency could support ESG (Environmental, Social, and Governance) investing by helping firms identify sustainable opportunities with precision.

However, the environmental cost of AI should be considered. Training advanced AI models often results in a significant carbon footprint. For instance, training a large language model (LLM) can generate more emissions than 125 round-trip flights between Beijing and New York[1]. This stark contrast between AI’s potential benefits and its environmental toll warrants closer scrutiny.

The Hidden Environmental Costs of AI

When firms are considering the adoption of AI solutions, they will need to start taking account of their impact on the environment. On the face of it, AI looks like a clean, environmentally friendly resource, but there is an environmental cost which needs to be considered.

Beyond carbon emissions, AI’s environmental impact extends to water consumption, a resource essential to both AI infrastructure and operations. Some of the aspects to consider are:

  1. Chip Manufacturing: Production of microchips, the backbone of AI systems, requires approximately 2,200 gallons of ultra-pure water. Semiconductor factories, which produce these chips, consume as much water annually as 7.5 million people living in Hong Kong, according to the World Economic Forum[2].
  2. Data Centre Operations: The running and cooling of AI systems in data centres demands substantial water resources. For example, OpenAI’s GPT-3 model requires millions of litres of fresh water for training and operation. A single user query can consume between 10 to 50 millilitres of water, depending on the hosting location[3].
  3. Corporate Impact: Major tech companies have reported surging water usage. In 2022, Google’s on-site water consumption rose by 20%, while Microsoft’s jumped by 34%, partly due to the demands of AI systems, according to OECD.AI.
  4. Energy consumption: AI requires a lot of energy, which is often generated by burning fossil fuels, a major contributor to global warming. The International Energy Agency estimates that by 2026, AI, cryptocurrency, and data centres could use 4% of the world’s annual energy.
  5. Electronic waste: Data centres that house AI servers produce electronic waste that contains hazardous chemicals like lead, mercury, and cadmium.

Navigating the Environmental Dilemma in Wealth Management

For firms committed to sustainable investing, addressing their own environmental impact is crucial. As people are looking to align their investments with their personal values, clients will expect both financial returns and a commitment to sustainability from wealth managers. Firms must consider their technology stack and operations alongside their investment portfolios.

Efforts are underway to mitigate the environmental impact of AI. Companies are exploring energy-efficient AI models, adopting renewable energy for data centres, and improving hardware recycling processes. Wealth management firms should actively evaluate these alternatives as part of their sustainability strategies.

AI presents both challenges and opportunities for the investment industry. By harnessing its potential while addressing its environmental costs, firms could position themselves as leaders in responsible innovation. The road ahead demands a thoughtful balance between leveraging AI’s transformative capabilities and honouring commitments to a sustainable future.

The Regulators Actions

The FCA is collecting more information about AI to look at the risks and opportunities AI presents to UK consumers and markets and help inform the regulatory approach in a practical way. For that all stakeholders are invited to provide their view on the future of AI and what is possible and sensible within financial services. More information on the FCA initiatives can be found here.

Maria Fritzsche – Senior Policy Adviser, PIMFA

 

[1] https://eprints.gla.ac.uk/324195/1/324195.pdf

[2] https://www.weforum.org/stories/2024/07/the-water-challenge-for-semiconductor-manufacturing-and-big-tech-what-needs-to-be-done/#:~:text=This%20burgeoning%20demand%20for%20chips,to%20an%20S%26P%20Global%20report

[3] https://oecd.ai/en/wonk/how-much-water-does-ai-consume

Financial Conduct Authority – Five year strategy March 2025

PIMFA Under 40 Forum 2025

For the past 7 years, PIMFA has run the Millennial forum of individuals from our membership. This has since become the Under 40 Leadership Committee.

Its purpose is to bring together bright minds to debate, research and consider pressing issues facing our industry. Their findings result in a report, which is published and widely circulated. You can download the 2023 report here.

At the event on February 12, The Under 40 Forum members will be presenting their findings from their work this year. The day will also welcome industry expert speakers.

This year’s group are researching the following topics, the results of their findings will be presented at the event on February 12th:

1. Does the industry focus on cost undermine value?
2. How can firms better target other demographics to improve their long term viability?
3. How do M&A affect existing and prospective client outcomes?

PIMFA Financial Crime Conference 2025

The PIMFA Financial Crime Conference is returning in 2025, ready to update attendees on everything they need to know on the evolving financial crime landscape.

Firms and their clients remain at significant risk, and the event will aim to give PIMFA members the know how to protect themselves. Attendees will get access to expert sessions from professionals across industry, including governmental, regulatory and law enforcement experts, as they discuss what the current threat landscape looks like emerging from new techniques and technologies, and what can be done to operate in a safer and more resilient environment.

As in previous years, this event is named not just at financial crime professionals and MLROs, but at anyone in a senior management or compliance function, working to ensure firm’s work is safe for clients, and one step ahead of the various threat actors acting against the financial services sector in 2025.

As you will see from our agenda, this year’s event will include contributions from the Financial Conduct Authority (FCA), the Home Office, and the National Crime Agency (NCA), among many others – book now to reserve your seat (press are not eligible for this event, and spaces are limited on a first come, first served basis).

If you are a PIMFA Member – Please ensure you are logged in to your account first before adding a ticket to your basket to access the member discounts.

PIMFA HR Briefing 2025 – HR Leaders Looking Back, Moving Forward: 2024 Summary and 2025 Kick-Off

Challenging times lie ahead for HR leaders, but so do opportunities. In the first HR Briefing of the year, the employment team at Clyde & Co. will review what you might have missed in 2024, and what you need to know to prepare for the employment law changes in 2025.

In this  HR Briefing session, Chris Holme and Shadia El Dardiry will take you through both recent and upcoming changes which are significant for HR professionals and in-house lawyers in PIMFA member firms this year.

They will look back at the key employment law developments in 2024, and will consider what these mean for financial services firms. In addition, they will provide a case law update on key decisions from last year.

There are a number of changes being introduced this year which they will take you through – as well as the practical steps you should be considering in 2025 in order to prepare for the significant upcoming employment law reforms. The webinar will also remind firms of the proposed regulatory changes on non-financial misconduct and diversity and inclusion in relation to which the FCA is publishing policy statements.

The PIMFA CASS Academy 2025

Research shows that firms continue to fall foul of time-consuming and expensive CASS audits, and even those firms with a mature understanding of the CASS rules aren’t immune to escalating CASS audit fees. The problem often isn’t with knowing the CASS rules – many strategies are well understood – but with execution and application.

The PIMFA CASS Clients Academy is a unique learning experience for member firms who, not content to keep up with CASS requirements, seek to expand their knowledge and strengthen their internal capabilities to arrest rising CASS audit fees and ensure the number of incidences and breaches reported to the FCA continues to drop.

The PIMFA CASS Clients Academy (CCA) will change the way you and your firm approach CASS. You will emerge better able to tackle your firms toughest CASS audit challenges, lead with greater CASS knowledge, and inspire assurance at all levels in your firm that your next CASS audit is a success. CCA rapidly upskills CASS Officers, Operations, Compliance, Certification Function Holders, and Custodians to manage your next CASS audit and withstand scrutiny from regulators, auditors and senior managers.

If you are a PIMFA Member- Please ensure you are logged in to your account first before adding a ticket to your basket to access the member discounts.

For further information and any questions regarding the course please contact learning@pimfa.co.uk 

 

PIMFA Associate Members Briefing 2025

Join us for the 2025 Associate Members Briefing on May 20, 2025.

We will explore topics such as regulation, operations, taxation and others and provide an opportunity to discuss with PIMFA staff specific issues important to the membership.

This event also showcases our ongoing events and publications programme providing examples of how Associates can engage with Members and maximise the value they receive from their membership.
Attendees will also benefit from networking opportunities with other industry professionals.

This event is free for PIMFA Associate Members. To book your place please go to tickets and complete the registration form. If you have any questions please email us on events@pimfa.co.uk

Please note – you must be logged in to your PIMFA account in order to see and book your tickets.