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ATEB has completed a number of Section 166 Skilled Persons reviews - here are some of the lessons learnt.

MiFID II PROD rules require firms to ensure products and funds are matched to the the right 'target market' clients.

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Firms that deal with a DFM on an agent as client basis could be exposed to hidden risks.

Many providers, platforms and adviser firms are not yet properly compliant with the aggregated costs disclosure requirements.

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Firms that advise on DB transfers need a process for assessing Transfer Risk.

Many firms have not amended their status disclosure to reflect the MiFIDII definition of independence.

Section 166 Projects

ATEB undertakes Section 166 Conduct of Business Skilled Persons Reviews. We have completed numerous reviews on the FCA's behalf for projects as diverse as pensions transfers, QROPS, pension switching, debt mangement and mortgage advice.

Section 166 of the Financial Services & Markets Act concerns Skilled Persons i.e. those that have the requisite skills to undertake regulatory reviews. The majority of firms capable of undertaking S166 reviews are high street consultancies who will undoubtedly offer a good service, but at a high street consultancy price! While ATEB offers the highest quality (as can be proven) we do not charge high street consultancy prices.

Our S166 projects start with a blank page and no pre-conceived ideas. While the FCA's remit is to avoid and rectify any consumer detriment, we will work pragmatically with firms to achieve a fair outcome for all parties. 

We can also undertake in-house or other regulatory reviews on your behalf, perhaps as required by PI insurers or as initiated by the FCA following themeatic reviews. By way of example, we have conducted a number of pension switching reviews and pension transfer reviews where we worked with firms and PI insurers to agree a practical and thorough assessment of standards and to build in forward planning and risk management strategies to proactively limit the potential for future non-compliance.