PIMFA’s response to FCA; Quarterly Consultation CP 21/5

PIMFA’s response to FCA’s CP 21/5 Quarterly Consultation, particularly Chapter 3 – Changes to the Training and Competence sourcebook. Whilst we understand and in principle support the spirit of the rule enabling professional bodies to receive information on advisers’ breaches of APER and COCON and to use the information to make an informed choice about their members’ professional standing, we have identified the issue that compliance with the proposed rule may require firms to make changes to Employment contracts and Privacy notices, both of which will require time and cost to be put in place.