Unlock ability for firms to provide better quality, more personalised financial guidance and simplified advice to consumers
The purpose of the TISA Financial Guidance and Simplified Advice Working Group is to work with a group of leading financial services firms who are collectively of the view that the current definition of financial guidance remains ambiguous and this is causing consumer detriment.
Key issues include:-
FCA has committed to considering the proposals as part of their future planned activities to recraft MiFID regulations to better suit the UK retail investment landscape, and has requested TISA’s input into their longer-term plans to rewrite MiFID (now it is UK law). This is an excellent once-in -a-decade opportunity for TISA and our members to shape the regulatory landscape for investment products, to ensure the needs of UK society are better met. This will be a future focus of this Working Group.
Engagement and input into Labour Party Financial Services policy review process.
Significant engagement taken place with FCA and HMT on Consumer Body challenges on the Regulated Financial Guidance policy proposal.
FCA-HMT Joint Advice-Guidance Policy paper released, whereby the FCA and HMT are consulting on 1) making clarifications in the PERG on the boundary between advice & guidance; 2) a Targeted Support regime (that will allow firms to take personal circumstances of customers into account to be able to issue ‘people like you’ style courses of action and product suggestions); and 3) a simplified advice regime. The Targeted Support regime announcement represents a significant “policy win” for TISA. TISA has had significant engagement with the FCA on the policy Paper and TISA’s official response is available here
TISA attended a HMT-FCA roundtable recently, hosted by the EST – Minister Andrew Griffith. It was announced that the FCA & HMT will be jointly issuing a Policy Paper setting out three core proposals: 1) Examples of permitted guidance; 2) a new ’People like You’ support framework; and 3) a revised Core Investment Advice regime (taking into account feedback received on the earlier DP to make the regime more commercially viable).
TISA secured a number of key meetings with Treasury Select Committee MPs. Ex-City Minister Harriett Baldwin MP requested TISA draft an amendment to the Financial Services & Markets Bill 2022 (currently going through Parliament) covering the TISA policy ask. She made a highly supportive speech in the House of Commons for the policy change, mentioning TISA, and alerted the House to the TISA amendment. TISA has submitted its written evidence to the Public Bill Committee for the FS&M Bill 22.
TISA has continued engagement with other trade bodies on our proposals, to help ensure the industry remains consistent and speaks with one voice. A joint letter (to be signed by IA, ABI, PIMFA and the AIC) should be approved imminently which will be calling on HMT to consult on changing the Advice-Guidance boundary.
TISA has actively participated in the FCA-HMT Advice Guidance Boundary Review Industry Working Group. TISA’s Regulated Financial Guidance proposal is front-and-centre of the solutions being considered by FCA-HMT (together with the extension of Investment Pathways to other wrappers and Simplified Advice). Encouragingly, FCA have been working towards releasing a Discussion Paper.
The FCA released an announcement in relation to their Core Investment Advice CP proposals saying they will roll the development of the proposals into the broader Advice-Guidance boundary review work underway. The FCA’s decision aligned with the recommendation TISA made in our engagement with them and our CP response.
Meeting held with TISA Consumer Panel to solicit feedback on their views/ideas for improving UK household access to advice & guidance. The Panel remain concerned about the industry using a new guidance permission to sell inappropriate products to consumers.
The Financial Guidance and Simplified Advice Working Group meets monthly. The core group consists of seven member firms working collectively to address the issues. In addition, there is a wider group of a further 15 organisations that are making contributions to the core group and are supportive of the need to address the key issues. The group also receives updates at each meeting on other relevant TISA initiatives.
A J Bell Securities Limited
Aegon UK PLC
Ashurst Risk Advisory LLP
Aviva UK Insurance
Baringa Partners LLP
Blackrock Investment Management (UK) Limited
Broadridge Financial Solutions, Inc
CMC Markets Investments Limited
GBST Wealth Management
L & G plc
Lloyds Banking Group
RBC Brewin Dolphin
Scottish Widows Plc
St James’s Place Wealth Management
Standard Life PLC
Vanguard Asset Management Ltd
Strategic Policy Director leads on this work at TISA