Retail update – 40 minute briefing
Charlotte Henry (Senior Associate)
Anushka Herath (Senior Associate)
Norton Rose Fulbright LLP
4 June 2014
Agenda
1. The FCA’s review of RDR implementation: the key messages
2. Retail investment advice: inducements and conflicts of interest
3. Consumer credit reform: the latest on the new FCA regime
4. Financial promotions revisited
MiFID II and PRIIPs
July 2012: The European
Commission published a
legislative proposal for a
Regulation on KIDs for retail
investment products.
PRIIPs
2012
1 April 2014:
Political
agreement on
the proposed
Regulation
was reached.
MiFID II
During 2013: Presidency of
Council of EU published
various compromise
proposals.
Summer 2014:
Publication in the
OJ expected and
regulation will come
into force 20 days
later.
Summer 2014:
Council of EU
expected to adopt the
Regulation at first
reading.
15 April 2014: EP
adopted MiFID II
and MiFIR in
plenary session.
22 May
2014: ESMA
Consultation
Paper (CP)
and
Discussion
Paper (DP)
published.
Summer 2016: Transitional
period ends. All KIDs need to
be ready and on dedicated
KID websites.
2015
13 May 2014:
European
Council approved
both MiFID II and
MiFIR.
17 February 2014:
Presidency of the
European Council
issued draft texts
to COREPER.
COREPER
agreement with EP
on MiFID II
proposals on 19
February 2014.
Summer 2018:
ESA’s to determine
how to address
UCITS KIIDs with
PRIIPS KIDs.
Potentially Autumn 2014 start: ESMA,
EIOPA, EBA Level 2 measures
developed and finalised: delegated
acts and regulatory technical
standards. No deadline for them to be
in place yet.
2014
2013
28 January 2014:
Trialogue
meeting held on
technical details
of MiFID II
proposals
3
15 April 2014:
The European
Parliament
adopted the
proposed
Regulation at
first reading.
June 2014:
MiFID II and
MiFIR expected
to be published
in the OJ. Will
then come into
force 20 days
later.
1 August
2014:
closing
date for
responses
to the CP
and DP.
7/8 July 2014:ESMA
will hold open
hearing on the DP
and CP.
January to
December 2015:
Review of ESMA
technical advice,
preparation and
adoption of
delegated acts and
objection period for
the European
Parliament and
Council.
December 2014: ESMA
provides its technical advice
to the Commission.
2016
June/July 2016: Member
states required to
produce legislation to
transpose MiFID II.
2017
Dec 2016: MiFID II
and MiFIR applied in
member states.
2018
MiFID II / MiFIR
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KID Regulation for PRIIPs
• EU KID Regulation agreed (waiting for
publication in OJ)
• Directly applicable in the UK so no UK
implementing measures needed
Norton Rose Fulbright
Dedicated PRIIPs product
• PRIIPs:
– “packaged retail investment and insurancebacked products” including any investment
(including financial instruments under MiFID and
insurance instruments under IMD) in a
packaged / wrapped / bundled form
• 2 year transitional period before all PRIIPs
need to have a Key Information Document
(KID)
• Prescribed form for KID:
– description of product, risks, etc.
• KID needs to be translated into official
language of Member State into which they
are sold
• Whoever sells the PRIIP must provide the
KID (e.g. product providers or retail
distributors)
• Product providers fully liable for content of
KID – burden of proof reversed
• Requirement for dedicated KID websites
• Level 2 measures to flesh out detail
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PRIIPsite
Template legal tools for uploading to
client’s dedicated KID website
including:
• legal terms
• regulatory disclaimer for landing
page
• privacy policy
• cookies policy
• copyright notice
• translation service for local country
disclaimers and KIDs
The FCA’s review of RDR implementation: the key messages
Quick recap on RDR
•
Where?
 COBS 6.1A-6.1G
 COBS 6.2A
 COBS 2.3.6A
•
When?

•
Who?

•
−
−
−
−
−
Rules on advisers (and associates) and their remuneration, including referrals to discretionary investment
managers
Requirement to be paid through adviser charge for advice and ‘related services’ and not through payments from
product providers (or referral payments from discretionary managers)
Rules on product providers prohibiting payments to advisory firms, including on ‘facilitating’ adviser charge to
adviser (including through a platform)
Disclosure requirements of generic charging structure to retail clients and actual charges to be applied
Separation between cost of advice and product costs with adviser charge not being varied inappropriately
according to product or provider
Rules on qualifications, training and standards for advisors
Why?



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Impacts retail clients in the UK; IFAs and associates; product providers and associates; discretionary investment
managers; platforms; vertically integrated firms
What?
−
•
Rules in force from 30 December 2012 with sunset period for legacy business (with currently no longstop date)
provided restrictions met (eg. no changes to the investment paying permitted trail commission)
Increase transparency of what retail clients pay for advice
Prohibit commission payments / other payments in connection with advice
Increase technical standards / competencies of advisers
Quick recap on RDR 2
•
Where?
 COBS 6.1E
•
When?

•
Who?

•
−
−
−
Replaced definition of ‘fund supermarket’ with new definition of ‘platform service provider’ and ‘platform service’
Advisers and product providers responsible for policing new rules
Product providers no longer permitted to make certain third party payments (e.g. to platforms)
Product providers prohibited from paying cash rebates to retail clients (other than de minimus payments)
Platforms only to be remunerated by platform charges payable by retail clients for the platform service (and related
services)
Platform obliged to disclose platform charge and not vary it inappropriately according to product or provider
Platforms not to accept any remuneration (excluding payments from advisers or brokers) including share of an
Annual Management Charge (AMC) unless passed on to clients in units or cash (in limited circumstances)
Platforms to police product providers and the way they present their charges or pay rebates and to police other
platforms they use
Why?




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Impacts retail clients in the UK; platform service providers and associates; product providers and associates; IFAs
using platforms
What?
−
−
−
−
−
•
Rules in force from 6 April 2014 with transitional period for legacy business (for platforms only) until 5 April 2016
Extension of RDR rules to platform market
Prohibition on platforms receiving certain payments
Prohibition on platforms making certain payments
Applies to advised and non-advised business (key difference to RDR which only applies to advised business)
RDR / RDR 2 – What has the FCA been doing?
Jan 13
Jan 13
Mar 13
Jun 13
Jul 13
Jul 13
Jul 13
Jul 13
Sep 13
Sep 13
Oct 13
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• First Thematic Review: How firms are implementing the RDR
• Linda Woodall speech: must comply with ‘spirit’ of RDR
• FCA informal guidance on what retail customers can do with pre-RDR assets paying trail commission
• FCA board meeting: potential legacy commission longstop date discussed
•CP13/4: Distribution of retail investments: referrals to discretionary investment managers
•Findings from first thematic review: TR13/5 Supervising retail investment advice: how firms are implementing the RDR
•Martin Wheatley speech: concerns with calculating adviser charge on percentage basis of amount to be invested – “dealing bias”
•Second Thematic Review: Delivering independent advice and complying with disclosure standards
• GC13/5: Supervising retail investment advice: inducements and conflicts of interest
• New rules came into force banning consultancy charges in auto-enrolment schemes
• FCA Speech: cash examples needed for percentage-based adviser charging (both initial and on-going advisory services)
RDR / RDR 2 – What has the FCA been doing?
Oct 13
Nov 13
Jan 14
Jan 14
Mar 14
Mar 14
Mar 14
May 14
May 14
Jul 14
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• GC13/7: Changing customers to post-RDR unit classes
• FCA speech: concerns around use of “restricted whole of market”
• PS14/1: Distribution of retail investments: referrals to discretionary investment managers and adviser complaints reporting
• FG14/1: Supervising retail investment advice: inducements and conflicts of interest
•Thematic review: Preparedness of platform market to new platform rules – good and bad practice
•TR14/5: Feedback from Second Thematic Review - delivering independent advice – good and bad practice
•TR14/6: Feedback from Second Thematic Review (and follow up to First Thematic Review) – being clear about disclosing adviser
charges and services
•FG14/4: Changing customers to post-RDR unit classes
• PS14/7: Changes to the use of dealing commission rules
• Third Thematic Review to start: on whether the previous feedback has been embedded and distortions
RDR / RDR 2 – Summary of high level views
 Explanation of adviser charges and services
 Description of services – delivering independent advice
 Genuine service for receipt of permitted trail commission
 ‘Spirit’ of RDR
 ‘Window-dressed’ commission
 Legacy referral payments for pre-RDR referrals to discretionary managers (from 31/12/14)
 Treatment of switching to clean share / unit classes
 Referral payments from discretionary investment managers to advisers (from 31/12/14)
 Selection of discretionary investment managers when ‘independent’
 Unbundling fund charges
 Review into non-advised market (e.g. execution-only)
 Review into simplified advice
 Review into platforms’ implementation of RDR 2
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Still very much the hot topic at the FCA!
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RDR / RDR 2 – What’s coming up?
31 Dec
2014
(expected)
• Rules in relation to referrals to discretionary investment managers come into force
• Feedback from Third Thematic Review
Jan 2015
31 Dec
2015
5 Apr
2016
*Summer
2016
• (Delayed) Rules on intermediate unit-holders intended to come into force
• Transitional period for permitted payments by platform ends
• Transitional period ends for having KIDS for all PRIIPs in place and all KID websites running. Watch out for
commentary by the FCA on how the KID interacts with the RDR Intitial Disclosure Document and with describing
the ‘adviser charge’ in the KID!
• Due to MiFID 2 measures (and PRIIPs referring to MiFID 2), bring ‘structured deposits’ with RDR model
*End 2016
• Due to MiFID 2 measures, portfolio managers (including discretionary managers) unable to receive any
commission from product providers. Expect FCA consultation on this as needs to be implemented in the UK
*End 2016
* (Likely)
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Update on financial incentives
Financial incentives – development
•‘Dear CEO’ letter to product providers:
• ensure
Oct 2012
arrangements with advisers are not disguised distribution fees (for RDR purposes)
• ensure arrangements with advisers are complying with inducement rules
• Thematic Review: FCA requested a sample of firms to provide their top 5 distribution
Oct 2012 agreements
• Findings from follow-up to ‘Dear CEO’ letter:
Oct 2013
• more than ½ distribution agreements reviewed contained payments that breached objectives of RDR
• two (2) firms automatically referred to enforcement
• Guidance Consultation GC13/5: Supervising retail investment advice: inducements and
Oct 2013 conflicts of interest
Jan 2014
• Finalised Guidance FG14/1: Supervising retail investment advice: inducements and
conflicts of interest
Concerns
Type of Concern
• Providers replace commission
payments / distribution fees with
commission-like payments
• RDR ‘Out of scope’ payments but
questionable under inducements rules
and Principle 8 (conflicts of interest)
• List of payments the FCA considered
were an inducement (‘Dear CEO’
letter) still prevalent
• Concerns that payments did not
enhance quality of service to clients
• Concerns with disclosure wording to
clients in relation to inducements
Soft / formal guidance
• ‘Dear CEO’ letter – post-letter, flurry of
‘strategic partnerships’ between
product providers and advisory
firms/groups
• Thematic follow up
• One year later – FCA’s findings
following thematic review are that of
the 80 distribution agreements
reviewed, over half could breach
Principle 8 (conflicts of interest) and
the inducement rules!
• Two firms referred to enforcement
• Concerns with joint ventures between
product providers and advisory firms
• Guidance consultation started
• Finalised guidance issued
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Guidance summary
• Both actual and potential conflicts need to be managed – a potential conflict
includes where a firm could receive a benefit but has yet to do so
• Clarified extent of the existing guidance on ‘permitted’ non-monetary benefits.
Firms taking any overly broad interpretation of the guidance in COBS 2.3.15G
• Clarified types of benefits not considered to give rise to conflicts:
–
–
–
–
where the benefit is reasonable and proportionate
is of a limited scale and nature
is not relied on by the advisory firm to continue to service its customers
would not reasonably result in channeling of business to the provider
• Where the conflicts cannot be managed, the arrangements must be terminated
• A provider’s selection for an advice panel (independent or restricted) should not
be linked to their willingness to also purchase support services from the
advisory firm or provide other benefits to the advisory firm
• Exclusive distribution arrangements need to be approached with care
• The table contained in COBS 2.3.15G (as amended by the Finalised Guidance –
see handout) is not a definitive list of permitted non-monetary benefits and
should not be read as such
Guidance summary
• If firms in doubt whether payments comply with COBS 2.3, assume they do not
and not make them or accept them
• Payments should not result in advisory firms recovering more than their
‘reasonable’ costs
– likely to mean actual costs or market rates
– likely not to include any element of profit
• Both providers and advisers have an obligation on ensuring payments and
benefits do not create conflicts or amount to inducements
– providers should conduct an audit of costs incurred by an advisory firm
• Greater the amount of provider payments, the more likely the rules are breached
• COBS inducements rules apply to vertically integrated firms
• Guidance applies to payments to unregulated third parties in the same group
as the advisory firm (where the regulated advisory firm ultimately benefits
financially)
• Guidance applies to payments to unregulated third parties not in the same
group as the advisory firm, where the third party provides support services to the
advisory firm in return for a fee and supplies marketing support to the provider in
return for a payment
Examples of poor practice
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Longer term, multi-year agreements
Linking profits to increased sales
The FCA mentioned 5 years in its
thematic review findings
Advisory firms making profits (over and
above normal market rates) for
providing services to providers and
which are linked (directly or indirectly) to
distribution of the provider’s products
Linked services and payments
Dual-hatted staff
Agreements where providers can
negotiate reduced payments in return
for reduced services from the advisory
firm which is linked to the provider
losing its place on the advisory panel or
to a material reduction in sales of their
products
Advisory firm staff having dual roles –
providing information and guidance to
advisors on the benefits and features of
products while also being responsible
for the negotiation and provision of
services to providers
Examples of good practice on systems and controls
Due diligence and negotiation
Controls
Carrying out a detailed analysis of
advisory firms’ offered services before
entering into agreements with them
Adherence to these policies overseen
by relevant executive committees (with
independent challenge from risk and
compliance), with breaches recorded
and escalated in accordance with the
firm’s established processes
Negotiating distribution agreements
separately from securing panel
placement
Systems
Oversight
Written policies on distributor spending
(to provide an effective governance
framework)
Boards actively engaged in the process
for entering into agreements and they
(or a delegated committee) had
approved the contractual arrangements
Controls to ensure that benefits from
providers did not affect personal
recommendations
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Next steps
• FCA wanted firms to be compliant within 3 months of guidance – so by end of April
• Supervisory work will follow to check whether firms have acted on the guidance and, if
problems persist, FCA will consider further action
• As obligation is on both providers and advisory firms to ensure compliance with the rules
and guidance, any enforcement action may include both the provider and the advisory firm
•
Firms should therefore:
 review their current distribution agreements and arrangements and consider each
benefit / payment on a standalone basis and be able to justify it
 review how payments/benefits are disclosed to clients
 update systems and controls
• Watch out for MIFID II – re-addressing inducements and conflicts – further discussion on
what constitutes ‘minor non-monetary benefits’
“The rules on inducements and conflicts of interest are not new. However our review made it clear there
were certain practices that did not stand up to scrutiny. In the guidance published today we are helping
firms better understand our expectations. Now it is for firms to make sure any payments are legitimate,
are in consumers’ interest and that potential conflicts are well managed.”
Clive Adamson, FCA, 16/1/2014
Consumer Credit Reform
Consumer Credit Reform
Transfer to the FCA: redressing the balance
• Transfer of consumer credit regulation from the OFT partly borne
out of political and public pressure around perceived historic
failings
– payday lenders
– debt collection
– debt management
• FCA has stated that ‘the consumer credit market is not functioning
as well as it should’ and that there is ‘considerable unaddressed
detriment’ in the market
• Wider set of powers available to the FCA and a more principlesbased approach will mark the beginning of a new style of
regulation for consumer credit firms
– the pressure of public expectation
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Consumer Credit Reform: legal framework
• ‘Lift and shift’ approach
– New suite of ‘credit-related regulated activities’ in RAO
– New regulated activity of ‘operating an electronic platform in relation to
lending’
– Lifting across existing requirements from the CCA to the FCA Rulebook
– Pre-contractual requirements e.g. adequate disclosure and pre-contract
information
– Post-contractual requirements e.g. continuing assessment of creditworthiness
• Shifting across OFT guidance into FCA rules and guidance
• Continuing requirements in CCA e.g. form and content
requirements
• New sourcebook for conduct of business of credit businesses
(CONC)
• Financial promotions
• Prudential requirements for debt management firms
• Conduct of business
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Consumer Credit Reform: regulatory framework
• Interim Permission
– All firms needed to have applied for Interim Permission
– 49,405 firms transferred on 1 April 2014
– Interim period of 2 years within which all firms must apply for full authorisation
• Recognition that transitioning to the FCA regime may be
burdensome and costly
– Distinction between ‘full permission’ and ‘limited permission’ and ‘higher risk’
and ‘lower risk’ activities
– Higher risk activities e.g. peer to peer lending, payday lending
– Lower risk activities e.g. credit broking as a secondary activity, consumer hire
– Distinction will impact on:
– application process for authorisation (modified Threshold Conditions)
– authorisation and on-going fees
– reporting requirements
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Consumer Credit Reform: regulatory framework
• Focus on behavioural economics: method of providing insight into
consumer choices, attitudes and outcomes
– Research into how consumers use credit throughout their lives
– Lack of incentive to shop around, look for alternatives or switch accounts
– Impact on FCA approach to protecting consumers
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Consumer Credit Reform: a new style of supervision
• Principles-based
– A significant cultural shift for firms
– The transfer to the FCA will overlay
the prescriptive CCA regime with a
less rigid outcomes focused
approach
– Technical compliance with the
requirements is not enough – firms
will need to ensure that their systems
and controls uphold the spirit of the
wider principles set out in the FCA
Handbook and FCA guidance
– Treating customers fairly (TCF) is
critical
– Investing time in understanding and
implementing the principles
throughout the business is key
– Firms will need to navigate a number
of unfamiliar rulebooks and
principles
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Consumer Credit Reform: a new style of supervision
Proportionate but extensive
• Likely to be more extensive and
robust than OFT supervision, but
proportionate
• The level of supervision will be
tailored to the firm’s risk category,
which will be determined by the risks
its activities are deemed to pose to
customers and other factors such as
its size and number of customers
• The FCA will look to see that relevant
principles are embedded throughout
the firm’s business model and the life
cycle of a product
• In particular, it will assess the extent
to which firms embed TCF across
their governance and culture, product
design, sales and distribution
processes and post sales services
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Stages of a product life cycle
Consumer Credit Reform: a new style of supervision
Proportionate but extensive
• Firms will typically be assessed on a two-yearly basis, although
smaller firms will be assessed every four years
• Hybrid supervisory approach
– Firm-specific visits to largest firms in certain sub-sectors of the market
– Event-driven work across all sub-sectors
– Targeted thematic work
• FCA has already announced visits within the following areas will
be taking place:
– Credit card issuers
– Payday lenders
– Pawnbrokers
– Debt management
– Debt collection
– Home-collected credit
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Consumer Credit Reform: enforcement
• A more active and assertive
regulator
• The focus is likely to fall on
mainstream consumer credit
firms, not just payday lenders
• Whilst retrospective
enforcement of the new rules is
not on the cards, the FCA will
be able to investigate conduct
pre-1 April 2014 and apply the
sanctions in force at that time
• Enforcement action is based on
principles – not just compliance
with the rules
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Non-compliance is
not an option at
any time.
Financial Promotions Revisited
What are financial promotions?
•
•
•
•
•
•
•
•
•
Press releases
Factsheets
Websites
Oral statements
Letters and emails to clients
Customer agreements
Response to queries
Marketing communications
Social media – Facebook, Twitter, LinkedIn, blogs
Why is the regime important?
• Formal attestations from senior management for repeated
breaches
• Reputational risk
• Censure
• Fine
• Compensation to investors
• Cancellation of authorisation
Where is the FCA going on financial promotions?
The power to ban financial promotions
• Specific new power to ban or amend misleading financial
promotions (section 137S FSMA)
• Enabling the FCA to remove promotions immediately from the
market without having to go through the enforcement process
• Power against a specific promotion, not against the firm as a
whole
• Formal disciplinary powers still available to the FCA
• Helping to raise standards in new products and new channels e.g.
social media
• Three step process:
– A ‘direction’ is given to the firm to remove the promotion (or one approved on
behalf of an unauthorised person) setting out the reasons for banning it
– Firms may make representations to the FCA
– FCA decides whether to confirm, amend or revoke the direction, publishing a
copy of the promotion and the direction if confirmed
34
How can a firm deliver compliant financial promotions?
• ‘Clear, fair and not misleading’:
the backbone to the FCA’s
approach
• Importance of culture
• Changing the way you manage
your business
• Changing the commercial
culture
• Taking staff with you
• Senior managers taking the
financial promotions regime
seriously
• Rethinking the approach to
financial promotions
• It's not just compliance
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Good practice – bad practice
• The FCA likes:
– Compliance and marketing departments are both involved in the development
of promotions
– Marketing staff undertake training on the key requirements of financial
promotion compliance
– Marketing staff are involved in the financial promotion sign-off process and
these sign-offs are monitored by risk or compliance staff
– Consumer research to test and evidence customer understanding of a
promotion
– Effective systems and controls
• The FCA doesn’t like:
– Senior management lack of engagement
– Inadequate systems to ensure compliance
– Failure to follow compliance procedures or assess compliance – maintaining
the compliance manual
– Record keeping
– Poor training of staff
– Firms who don’t take the regulatory regime seriously
36
Linkage between TCF and financial promotions
• Product life cycle a central tenet of Treating Customers Fairly
(TCF) principles
– Product life cycle considerations should be integral to designing new products
and re-evaluating existing ones
– Are products designed to treat customers fairly and to prevent consumer
detriment?
– Link with financial promotions – the gateway between firm and customer
– Does the customer receive the information they need to make an informed
choice?
– Objective and fair assessments of material
37
Recent areas of focus
• Consumer credit
– New suite of requirements in CONC 3
– Bringing across Advertising Regs into a new arena
– May 2014: 1 in 5 credit advertisements failed to meet the FCA’s requirements
– Encouraging customers to hit ‘apply’ before accessing important information
• Annuity comparison websites
– Good practice of presenting alternative options to annuity policies
– Poor practice of failing to mention important information e.g. how does
purchasing an annuity fit into a consumer’s overall financial circumstances and
retirement plans?
• Premium rate telephone numbers
– FCA consultation on ensuring standardised charges are capped at cost of a
basic rate call
• Marketing and complex Ts&Cs
– FCA looking at whether complex Ts&Cs are compounded by marketing material
or product labelling making it difficult to understand the complexity of a product
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Current themes in enforcement
• Failure to pay due regard to
information needs of clients in
telephone sales:
– £30 million fine and consumer
redress for the misselling of
insurance policies
– failure to explain exceptions to
policies, coverage
– failure to compare the customer’s
existing cover against the new
product
– customers purchasing inappropriate
insurance cover that they did not
need or were not eligible for
• Size of the fine represented systemic
failings in the firm
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• Inferences that services are
‘bespoke’, ‘tailored’ or
‘personalised’ when they are not
• Amendments to marketing
materials without a holistic
assessment of their overall
compliance
• Failure to produce balanced
promotions which emphasise
negative as well as positive
features of a product
• Failure to monitor promotion of
UCIS to ineligible consumers
“Powerful messages are left by
advertising, and from a perspective
of consumer protection and fair
competition between firms, it is
important that consumers’
expectations are met by reality,
which is why all financial promotions
must be stand-alone compliant”
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