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1. De-Polarisation – Provider Investment – Please Contribute to this Survey
2. Additional Capital Resource Requirement for Professional Firms
3. “Mortgage Meltdown Day (MM Day)” - Mortgages off to a Flier!?
4. Loophole Denies Mortgage Customers Access to Redress
5. Do you Have a Signature or Date on your IDD?
6. Express Consents – How Long can we Rely on Them?
7. When is Money Received and Held by Mortgage Intermediaries Considered to be Client Money?
8. The ‘Elusive Non-Statutory Trust’ - Scarlet Pimpernel?
9. Time Barring of Endowment Complaints – Important Considerations
10. New Examinations
11. Introducers – A Regulatory Minefield!
12. Management Information Systems – Inaccurate Key Performance Indicators (KPI)
13. Contracting Out Letters – Contacting Your Clients
14. Business Risk Management - Planning
15. Why Were Some Dinosaurs so big?
16. FSA Mandatory Electronic Reporting & ‘XBRL’
17. Back Office Provider - Financial Planning “Projection” Tools

Ladies & Gentlemen

Please find enclosed the latest compliance and industry news.

As usual, sit back and enjoy!

Kind Regards

ATEB consultants

Which article applies to me?
Please use the following table to decide which article applies to you, if any:

Investment (IFA)	1	2	3	4	5	6	7	8	9	10	11	12	13	14	15	16	17
Directors/Partners
Compliance / A&O Function
Money Laundering Officer
Advisers & Trainees
T&C Supervisor
Pensions Transfer Specialist
Back Office
*Mortgage (inc. IFAs)	1	2	3	4	5	6	7	8	9	10	11	12	13	14	15	16	17
Director/Partner
Compliance / A&O Function
Sales Advisor
T&C Supervisor
Back Office
General Insurance	1	2	3	4	5	6	7	8	9	10	11	12	13	14	15	16	17
Director/Partner
Compliance / A&O Function
Sales Advisor
T&C Supervisor
Back Office

*Includes Mortgage arms of IFA and APF firms

1. De-Polarisation – Provider Investment – Please Contribute to This Survey

As you know, de-polarisation is looming. While we still await the final Policy Statement [Reforming Polarisation: A menu for being open with consumers] most of the changes are pretty clear.

From the date that the de-polarisation instrument (legal term) comes into force, you will have a six month window to move your business into a de-polarised environment. We will provide more detail about specific rules and requirements in due course.

The new rules allow providers to make certain investments into firms, for example, for technology and training. We have been canvassing the opinion of certain key providers over the past 6 months and there are 3 messages that are abundantly clear:

1. They are not showing their hands until de-polarisation is effective
2. There is scope for investment, but only into firms with defined business strategies
3. Economies of scale will apply i.e. smaller firms are unlikely to benefit.

We believe that it is entirely unjust for smaller firms to be ‘squeezed out’ by the bigger boys. In fact, our research shows that providers are most definitely interested in firms that can demonstrate high quality business i.e. you! The problem is of course, size. Providers will probably be perfectly happy to provide training, or discounted fund management charges, or e-commerce strategies, or hardware/software support, or direct marketing opportunities, but only if the economies of scale permit. They do, after all, have to make profits, just like everyone else.

We would be very grateful therefore if you could complete a short questionnaire by clicking on this link.

What we are trying to ascertain is whether there is sufficient interest and support across ATEB clients for us to go in batting on your behalf and whether you are prepared (with absolutely no loss of autonomy) to put your name in the hat with like minded firms in some form of affinity group.

Please give this careful consideration. This is a significant opportunity! While big is certainly not best, being an autonomous part of a bigger group is going to prove advantageous.

If you would rather discuss this in person, please ring Huw Reynolds on 07050 211920.

ATEB view:

You can’t ignore the inevitable.

Action required by you:

Complete the questionnaire or ring Huw.

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2. Additional Capital Resource Requirement for Professional Firms

The current situation for most professional firms (accountancy and solicitor practices arranging and advising on investments) is that they need to remain solvent and have an adequate amount of PI Insurance to cover the firm activities. The information is located in the investment firm’s interim prudential sourcebook IPRU (INV) section 2.3.

The insurance mediation directive introduces some changes where the firm is involved with insurance mediation activities (broadly speaking this is arranging insurance contracts and life policies i.e. Term assurance, bonds, pensions)

From 14th January for insurance mediation, relevant firms will have to comply with the prudential sourcebook (PRU) 9.2 & 9.3 which means:

(a) a minimum level of capital resource requirement

(b) a limit of indemnity that is IMD-compliant and

(c) a maximum excess in accordance with the other rules in PRU - which may mean additional capital, if the excess is above the maximum.

The firm's relevant income for these purposes is that from insurance mediation activities, not total income.

ATEB view:

None, for information only

Action required by you:

Speak with your local ATEB consultant if you are unsure how the rules impact.

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3. “Mortgage Meltdown Day (MM Day)” - Mortgages off to a Flier!?

No surprise for many of us that the first business day after the start of mortgage regulation left may advisers without the facility to offer clients an illustration. Many sourcing systems and lenders ground to a halt with apparently only two major institutions able to offer illustrations. Coincidentally, guess who is visiting one of those lenders at the moment?

One IFA arranging mortgages telephoned the FSA in desperation. When asked what they should do given the fact that illustrations were not available, the helpdesk suggested that they produce the KFI themselves!! (and they did not mean through a sourcing system) – Very worrying!!

ATEB view:

The industry has a habit of really doing things in style. Any of you sad enough to look back through the many thousands of pages of consultation and cost benefit analysis would see that getting things organised for MM-Day should not have been a problem, according to the FSA research that is. So where did it all go wrong? Well either the FSA rules and implementation process is seriously flawed or 99% of the lenders and sourcing system providers did not commence the necessary changes to their systems and controls soon enough – you decide!

Action required by you:

None, for information only

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4. Loophole Denies Mortgage Customers Access to Redress

The FSA has granted interim status to 25 firms whose authorisation applications were not completed by 31 October 2004 when the new regime for mortgages commenced.

The regulator may have been unable to complete an application because it had refused a firm authorisation or had sent a warning notice to a firm before the regime began. Granting interim authorisation status allows a firm to carry on doing mortgage business while the outcome of the disputed application is decided.

The customers of such firms will not be able to approach the Financial Services Compensation Scheme for financial redress

ATEB view:

Not sure where this sits within the FSAs statutory objective number 3 “securing the appropriate degree of protection for consumers” – you decide!

Action required by you:

None, for information only

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5. Do you Have a Signature or Date on Your IDD?

There has been confusion over this one.

FSA have now stated categorically that the format and contents of the Initial Disclosure Document (IDD) can only be amended as defined by the rules.

This means that a signature box or date cannot be added to it.

ATEB view:

No leeway.

Action required by you:

If you have this on your IDD, please remove. We do recommend however that you record the date of issue of the IDD, either in a covering letter, the material compliance checklist, or possibly in any other compliance checklist that you may get the client to sign as part of your sales process.

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6. Express Consents – How Long can we Rely on Them?

As we have explained to our clients, mortgage brokers require the client’s express consent to re-contact them after initially setting up the mortgage (in technical terms, for undertaking real time promotions for old clients). You will recall that our Mortgage Terms of Business includes an ‘express consent’ paragraph.

But what is a reasonable period of time for the express consent?

The following has been taken from the FSA’s FAQ section on mortgage regulation.

“Firms using cold calling to generate business should note that the passage of time will cancel an express request. The longer the period of time between obtaining an express request and a firm calling a consumer, the more likely it is that the firm will be unable to rely on the express request. The exact time at which an express request is cancelled in this way will be different in individual circumstances. We would normally expect express requests gained through market research and lifestyle questionnaires to be cancelled in a short time. Where a broker arranges a mortgage for a consumer and at the same time obtains an express request to outbound call, the exact time when the request will be out-of-date will again depend on the individual circumstances. Brokers commonly diarise calls to previous customers for the time shortly before special offers are due to expire, and we believe this can offer valuable customer service. To enable these calls, brokers should obtain requests that expressly permit them to call the consumer over a period of several years.

“Consumers are, of course, at liberty to withdraw their consent to receive real time promotions, irrespective of which regulatory route the firm takes to make such promotions. This can be achieved more easily where the consumer has an established relationship with a firm. It may be more difficult to withdraw an express request where this has been given to, for example, a market research agency.

Firms should be familiar with the Telephone Preference Service (TPS) and the effect of the Privacy and Electronic Communications (EC Directive) Regulations 2003.)

Firms should also bear in mind that if the nature of the contract with the consumer changes, this may affect their ability to use outbound calling.”

ATEB view:

It is reasonable therefore to have a relatively long express consent period in your terms of business where you intend to re-contact clients near the end of the offer period.

Action required by you:

Check the express consent period in your terms of business and adjust if need be.

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7. When is Money Received and Held by Mortgage Intermediaries Considered to be Client Money?

The following has been taken from the FSA’s FAQ section on mortgage regulation.

“Client money is money of any currency which, in the course of carrying on mortgage mediation activity, an intermediary receives and holds on behalf of a client, either in a bank account or in the form of cash. Client money would include, for example, money received and held in order to pay a valuation or survey fee to a valuer or surveyor. However, if an intermediary simply receives a cheque made payable to a third party valuer or surveyor, that will not be client money. Finally, money that is due and payable to an intermediary, for example, an administration or brokerage fee is not client money.”

ATEB view:

It is very important that you understand these rules. You cannot receive money payable to your firm, unless it is for your brokerage fee (or unless you have FSA permission to hold client money). Fees payable to you for survey fees are therefore not acceptable.

Action required by you:

If you believe this affects you, please discuss with your ATEB consultant.

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8. The ‘Elusive Non-Statutory Trust’ - Scarlet Pimpernel?

Apparently, when Baroness Emmuska Orczy wrote the Scarlet Pimpernel, she strongly considered calling her famous novel the ‘Elusive Non-Statutory Trust’.

Has anyone seen a non-statutory trust wording yet?

There is light at the end of the tunnel however. We have found out that the IIB, in conjunction with BIBA, submitted standard wording for a non statutory trust arrangement to the FSA. This was returned for amendment, but apparently, it will be ready 'well before January' -for general usage.

We are monitoring progress.

ATEB view:

Fingers crossed!

Action required by you:

Watch this space.

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9. Time Barring of Endowment Complaints – Important Considerations

On 1 June 2004, the FSA introduced new rules regarding time-barring on mortgage endowment complaints. The new rules require firms who intend to impose time-bars to explicitly warn endowment policyholders of the date that their right to refer a complaint to the ombudsman (FOS) expires.

Many insurers are introducing the time-bar in the re-projection letters, however some are not. This duality makes things a little awkward from the IFAs perspective.

There are a number of important things to consider:

1. What stance are providers taking, we recommend that you write to providers and ascertain this - We have a draft letter you can use for this purpose.
2. Some insurers providing this facility will assume that the IFA will ‘opt-in’ to this facility. If you do not want the time-bar imposed, then you should make arrangements with insurers.
3. For those insurers that are not imposing time-bars, what action should you take, if any?
4. Professional Indemnity. What is the view of your insurer? We know of one instance where the insurer’s underwriters are currently ‘considering’ the issue. You should contact your insurers for their view.

ATEB view:

On balance, the general view is that ‘opting-in’ is the best approach because it provides a definitive end-date for potential complaints. This is a subjective decision however and ultimately only you can make the decision. There is an argument to say that in the short term, complaints volumes will increase. This is why the PI insurers are twitchy. We strongly recommend you contact your PI insurers for their view and to let them know your intentions.

Action required by you:

Consider carefully. Inform PI insurers. Further reading: In issue 40 of the ‘Ombudsman News’ (September/October 2004), there is an article that states the current time-bar rules, the situation if a case can come within previous rules and FOS’s interpretation of rules. It can be found if you go to: http://www.financial-ombudsman.org.uk/publications/ombudsman-news/40/40_time_limit.htm and click on ‘Mortgage Endowment Complaints’

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10. New Examinations

The FPC will be replaced in January.  However those currently studying it have three more sittings available in January, April and July.

Further information can be obtained at: http://www.cii.co.uk/qualifications/financialplanning/framework_overview/pdf/framework_overview.pdf

ATEB view:

None, for information only

Action required by you:

None, for information only

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11. Introducers – A Regulatory Minefield!

Introducing used to be easy, mind you, so did a lot of things. I remember the days, not so long ago, when armed with a shilling and thrupence, ……………. ……. let’s not go there!

The introduction of mortgage and general insurance regulation and the impending implementation of the Insurance Mediation Directive, have brought with them more stringent rules for introducing business. A great deal of what may have in the past been outside the scope of regulation may well now be a regulated activity.

Whether you receive introductions from or introduce to, there are a number of issues that you need to consider:

1. Is the introducer or firm you are introducing to, suitably authorised?
2. What activities does the introducer undertake? - They may well fall under regulated activity – for general insurance brokers an example could be property managing agents.
3. How must the introduction be made (procedure)?
4. What information can be passed on?
5. What exclusions to the FSMA can be used to avoid the need for regulation?
6. Do you have written introducer agreements?

We are currently analysing different introducer scenarios as they apply to our clients. Indeed, many of you will already have been through this process with your consultant. When the analysis is fully complete however, we will issue further information.

ATEB view:

You have an obligation to ensure that introduced business is correctly controlled. This is something that cannot be ignored.

Action required by you:

If you have not already done so, discuss any introducing arrangements you may have with your ATEB consultant.

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12. Management Information Systems – Inaccurate Key Performance Indicators (KPI)

You will have heard us discussing the new FSA Reporting requirements that come into effect next year, affectionately known as RMAR (Retail Mediation Activities Report).

You need to start thinking about the contents of this report, because it is going to make your life (and ours I hasten to add) a lot more bearable if you can produce the data and statistics required by the report quickly and in a suitable format. We introduced RMAR to you in our July 2004 newsletter, but to give you a further flavour, the sort of data that will be required by the FSA, twice a year, will be:

• Balance Sheet
• Profit & Loss
• Client Money details
• Regulatory Capital
• PI information
• Company Structure
• T&C information
• Business Sources
• Appointed Representative details
• Persistency
• Premium details
• Company spreads
• Etc

This is not a comprehensive list; although the complexity of the report will be dependant on the size and structure of the firm, no one is going to get off lightly!

We would have to say that, as a general rule, the production of KPI data by firms is laborious, infrequent and often inaccurate. They can be produced, but not easily. If you consider the FSA System & Control (SYSC) rule that states that “the business and affairs of the firm can be adequately monitored and controlled by the directors, relevant senior managers and governing body of the firm”, then the availability of good management information definitely helps to demonstrate adherence to this rule.

ATEB view:

Some work in this area is inevitable!

Action required by you:

Please consider the above. If you use a good back office computer system, then investigate what KPI information can be produced. Discuss the financial reporting requirements with your ATEB consultant to check if your current management accounts or financial reporting is consistent with the FSA requirements.

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13. Contracting Out Letters – contacting your clients

This topic was covered in our October 2004 newsletter.

Many of you have decided to be proactive in this respect and to contact your clients on the back of the information being issued by the ABI.

To assist you in this matter, we have drafted example client contact letters. Please note that these are only starters and you will need to amend accordingly to meet your requirements and reflect your intentions. They are quite detailed, so you will need to tailor to your requirements. As always, ATEB cannot accept responsibility for any actions taken or arising from the issue of the letters – all we’re trying to do is give you a ‘leg up’!

One final important consideration. In the article in this newsletter about time-barring on endowment complaint, we raise the possible concern of PI insurers. This is also a consideration in this respect and you should gain the consent of your insurers before issuing any letters.

ATEB view:

We cannot make this decision for you. Whether or not you issue letters will be a subjective decision based on your firm’s circumstances.

Action required by you:

Consider the above. Discuss with your ATEB consultant as necessary. If deciding to issue, contact your PII.

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14. Business Risk Management - Planning

Risk Management Plan: If you were a large firm the FSA may have asked you for a Business Risk Management Plan as part of the authorisation process as an insurance broker or mortgage broker.  All new IFA firms, whether large or small, are asked in the authorisation process to state how they manage risks to their business.   Even as a small firm they still expect you to consider the risks to your business and plan actions where appropriate.   In fact, a small firm, because it is small, may not be able to recover as easily as a large firm from events that affect it.

One major item is the storing of duplicate records off site and daily computer back-ups.  These will become particularly important in the event of a major disaster, such a serious fire on the premises. 

Disaster Recovery Plan: The FSA also expect you to get back into business as soon as possible in the event of a major catastrophe (usually fire on premises). Again, you are probably keen to do this yourself should such an event occur.

Both these plans should be made available to staff for reference (hopefully they will not have to activate the contents!). It sounds obvious but they should also be held off the premises!

ATEB view:

The FSA are concerned that you stay in business and continue to serve your clients.  However, consider this exercise from the point of view that it is in your interests and your clients’ interests for you to consider these risks and be prepared for them.

Action required by you:

If you feel this is an area where you are falling short, feel free to discuss with ATEB. We can help in these areas as we have pro-forma plans for you to create and implement.

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15. Why Were Some Dinosaurs so big?

The presenter on an interesting item on a Radio 4 programme the other day posed this question of an expert.  The simple answer is “for protection”. The bigger you are the less likely you are to get into bother on the vicious plains of the pre-historic world.

However the ‘Laws of Evolution’ do not seem to work with large financial firms. It appears that the FSA applies its rules to large and small alike and does not assume a large or famous firm is compliant.  A while ago they fined the investment arm of a large accountancy firm, Deloitte & Touche Wealth Management Ltd, £750,000 for inadequate training of its advising staff. Apparently the FSA judged that they had not trained their staff sufficiently in the obtaining and recording of information relating to advice given.

Whilst ATEB consulting is not in the business of frightening firms into spending money on compliance, it is worth noting how seriously the FSA take adequate training of all staff. They have been saying that training is a cornerstone of good compliance and customer care and now they have put their money where their mouth is (or in this case someone else’s money!!).

The FSA have always made it clear that they do not see training as just another tick box exercise. They also seem to really understand what training is about. The principle is that each firm provides training appropriate to the needs of both the firm and of the individuals. The old days of photocopying someone else’s CPD record is long gone (we hope!!). Now we need to go through what we trainers call the ‘Development Cycle’:

Stage 1   Identify ‘Training Needs’ of the group and of the individual

This involves finding out what the person should know (knowledge) and be able to do (skills). Take away what they currently know and are able to do and what’s left are training needs.

Stage 2   Plan training

Having established the training needs then identify the best and most efficient method of learning and allocate individual responsibilities.

Stage 3   Implement training

Follow the plan and experience something new or revisit old areas.

Stage 4   Review that learning has been transferred

By ‘transferred’ we mean “has the original training need been corrected back in the workplace?”   This can be done sometime after the training, but usually means going back to the original source of the need, the observed visit, the file checks, KPI’s, exam, implementing the new procedure or selling the new product.

ATEB view:

It is this process (and it needn’t be complicated) that the FSA expect to see both enshrined in your T&C plan and in practice (as evidenced by good records of course). N.B.  Don’t forget that the FSA are interested in the competence of non-advising staff as well, in fact everybody who is involved in the process.

Action required by you:

Contact ATEB if you would like further guidance on how this article might apply to your firm. If you are a General insurance broker or Mortgage broker then in your application for authorisation, one of the promises you made was to have a Training and Competence Plan in place by the authorisation date. Please contact us if you need any help.

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16. FSA Mandatory Electronic Reporting & ‘XBRL’

As you will be well aware by now the FSA reporting requirements are in the process of moving to MER (Mandatory Electronic Reporting).  Firms should now be asking themselves if they are ready to meet these requirements.  Have you ever found yourself facing one of the following problems:

Whilst shopping online you have selected the items you wish to purchase and proceed to the checkout.  You fill out your credit card details and click on submit.  After waiting a few minutes it soon becomes clear the website isn't going to up date or you get a page error.  What has happened to your order?  If you don't receive an order confirmation via email you usually have to then go back to the website and fill your basket again.

You fill out a form on the internet (e.g. survey or shopping) and then you are distracted and leave the form open to return to it later.  When you return to your PC you continue to fill out the form and then click submit.  An error is then returned informing you the website cannot be found and you have to fill in the data again.

These are common problems associated with online forms which occur for a number of reasons, which means filling out forms via a web browser can be a very unreliable process.  The FSA website will allow users to save information they have entered before submitting it online.  This will give you the chance to return to it later before submission but this still does not solve the problem of losing information.  If you fill out a form on their website and then choose to save it, you are submitting the data in the same way as mentioned before and the data could potentially be lost. Look at the following real life scenario:

One of our Mortgage clients was applying to the FSA for Mortgage Permissions using the online facility.  All of the necessary information was entered into the website and saved online.  When it was time to send the information to the FSA the client logged into the website and accessed all their saved data.  They then submitted the saved data and thought the information had been sent.  The on line data was re-examined some days later only to find that not only had the information not been sent but also much of the data had been lost. Thankfully ATEB intercepted this before it was too late.

The FSA is making online reporting available through two methods; via their website or via XBRL (eXtensible Business Reporting Language).  As previously discussed the website method is not going to be the preferred choice due to the inherent problems of submitting forms via websites.  The second method XBRL is allowing submissions using an international computer standard.  This will allow users to create their reports offline before submitting them.  The best way of visualising the concept of XBRL is to think of it as a barcode which a computer can create using your data and then pass to another computer which can understand it.

To be able to submit forms in XBRL you will need third party computer software, which is going to take your data and convert it for you.  There are a few software firms keen to introduce this (and some already implemented). It is anticipated that the FSA will not provide software capable of supporting XBRL for electronic reporting.

ATEB view:

Firms should be aware of the problems associated with Online website Electronic Reporting. It is going to be important to watch out for who is going to support XBRL in the future.

Action required by you:

Look out for software, which could make your life easier when it comes to electronic, reporting.  If in doubt contact your ATEB consultant and they can point you in the right direction.

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17. Back Office Provider - Financial Planning “Projection” Tools

Great idea, be careful!

Background:

A back office system allows projected summaries of benefits at retirement. The assumptions used are fund growth, earnings, inflation and a facility to include a reduction in yield figure. As part of its annual review process, an IFA firm intends sending 'summary projections to retirement', for clients who have diversified investment portfolios. The summaries include figures for a number of providers, which are then totalled on a single page. So, in essence, we have an easy to understand estimated summary of what the client might get and, in addition, highlighting any shortfall, at retirement.

Great news then, just what the FSA are looking for, proactive retirement awareness planning and simple communication and thankfully no need for a small rainforest this time…..Yes???

Wrong! …..If only life within financial services was that simple…

Interestingly, when we emailed a question to the back office provider and the FSA to determine what we could and couldn’t do, we got three replies (One from the back office provider and two from the FSA). Incidentally, the two answers from the FSA were different.

In summary, the back office provider explained that they had discussed it with the FSA and that the FSA were comfortable with the facility being used providing that where a recommendation was made, an official quote was used and that any projections used only certain specified assumptions.

The first reply from the FSA explained that they couldn’t help and that we should take legal guidance, the second reply suggested, “Firms must take account of the standards of projections especially as they provide constraints to the optimism that may be assumed” and that projections should comply with FSA rules.

ATEB view:

FSA have gone on record as saying "Less is better" but they tend not to be too specific as to what they mean. The truth is that in order to apply this principle you consequently “bust rules” which of course leads to problems with clients as well as the Regulator, so for the moment you can’t win.

Action required by you:

Firms should only rely on official quotations which meet the detailed requirements as set out in section 6.6 Conduct of Business Sourcebook when making a recommendation. As ever, do not rely on this newsletter article, we suggest that if you are using this facility then you seek individual written guidance from both your back office provider and the FSA.

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Important Note:

The ATEB Newsletter is intended to provide general guidance on areas of compliance and T&C; however it is not a replacement for the main Rules and Guidance contained within the FSA Handbook. We welcome all feedback. If you have any feedback or questions relating to any articles then please direct them to your local ATEB consultant or the newsletter editor Steve Bailey email steve@atebconsulting.co.uk Unless you have consulted specifically (as part of a regular visit) with ATEB on a particular issue then ATEB Consulting accept no liability for any actions taken based on the information contained solely within the newsletter.

Contact Us:

ATEB Consulting
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Northumberland
NE22 6AX

T: (01670) 822984
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