Press Release

PIMFA responds to “Confusing” FCA Financial Resources Consultation Paper

Wednesday 11th September 2019


PIMFA, the trade association for investment managers and financial advisers, responded to the Financial Conduct Authority’s (FCA’s) ‘Our Framework: Assessing Adequate Financial Resources’ consultation paper (CP19/20), calling it “confusing”, and set out their own observations on a number of issues regarding the content of the paper.

In respect of personal investment firms, of which most would be advisers, the consultation paper identifies practices firms should adopt but confusingly states that it does not impose specific obligations on firms.

Ian Cornwall Director of Regulation at PIMFA said;

“The FCA needs to give further clarification regarding this consultation paper – feedback from our member firms has indicated that there is confusion about the status of this document. We are questioning whether or not FCA are placing new obligations on Personal Investment Firms which have not been subject to a proper consultation process. It is very difficult to get a ‘sense’ of FCA’s expectations from the consultation paper in respect of a small Personal Investment Firm.

There is no supporting material that we are aware of on the FCA’s website, which could help small Personal Investment Firms prepare and maintain documentation which would enable them to readily address the points covered in a review. Firms should not have to spend time and money seeking to guess FCA’s supervisory expectations.

The FCA needs to consider what further material it can provide to assist firms, particularly small Personal Investment Firms, in meeting their expectations.”

Read the full consultation response here.




Notes for Editors

About PIMFA – the Personal Investment Management & Financial Advice Association

  • PIMFA is the leading trade association for firms that provide investment management and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.
  • 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.
  • PIMFAleads 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 going back for 28 years – read more.
  • Further information can be found at
  • To become a member of PIMFA for access to training, benefits and discounts, please visit or contact us directly at


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