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Retail Distribution Review

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Retail Distribution Review House of Commons Treasury Committee Retail Distribution Review Written Evidence Volume two Only those submissions written specifically for the Committee and accepted by the Committee as evidence are included. Ordered to be published 2 February 2011 List of written evidence 120 Sean Glorioso 4 121 Simon Boyle, Independent Financial Adviser 9 122 Derek Gair, GDC Associates 12 123 Investment Management Association 16 124 Alan Lakey, Highclere Financial Services 19 125 Beverley Davison, Highclere Financial Services 24 126 Adviser Alliance 29 127 Glen McKeown, Financial and Tax Adviser 34 128 Financial Services Authority 39, 288 129 Investment and Life Assurance Group 56 130 AXA UK 59 131 Association of British Insurers 63 132 Garry Heath, Life Change Ltd 68 133 Seymour Pierce 73 134 St James’s Place Wealth Management 76 135 Justice in Financial Services 82, 268 136 Graham Franklin, First Financial IFA 88 137 Financial Services Consumer Panel 90 138 CFA UK 101 139 Association of Financial Mutuals 104 140 Standard Life 110 141 Association of Independent Financial Advisers 116 142 British Bankers’ Association 128 143 David Haxby, Independent Financial Adviser 134 144 Threesixty Services 136 145 Peter Hamilton 139 146 IFA Defence Union 143 147 Christopher Bolshaw 146 148 Zurich Financial Services 150 149 Sesame Bankhall Group 153 150 Lyn Cooke, Independent Financial Adviser 159 151 Warwick Butchart Associates Ltd 165 152 Stephen Henry, E M Gray & Co 170 153 Bharat Sisodia, Financial Planning Consultant 172 154 Principal Investment Management 174 155 Consumer Focus 175 156 Royal Bank of Scotland 178 157 APCIMS 183 158 Ian Brough, Independent Financial Adviser 188 159 Charles Stuart Financial Services Ltd 194 160 Patricia Hutchinson, Independent Financial Adviser 201 161 James Brearley & Sons Ltd 206 162 Phil Mines, Chartered Financial Planner 211 163 Ralph Whittaker 212 164 Jon Lowson, IFA Research and Reports Ltd 213 165 Mark Loydall, Cambourne Financial Planning Ltd 216 166 Which? 218 167 Building Societies Association 224 168 Arnott Guy & Co Ltd 227 169 Financial Services Practitioner Panel 228 170 Smaller Businesses Practitioner Panel 235 171 Mike Reynolds, Moneywise GB 243 172 Terence P O’Halloran, O’Halloran and Co 244 173 Care Asset Management Ltd 246 174 Simon Mansell, Temple Bar IFA 247 175 Martyn Young 249 176 Alastair Lyon 250 177 Fidelity International 252 178 D. W. Johnstone, Creative Benefit Solutions 258 179 Consumer Financial Education Body (CFEB) 260 180 Hargreaves Landsdown 265 181 Michael Forbes Bates 276 182 Paul Raseta 278 183 Concept Financial Planning 282 184 LifeafterX Ltd 283 185 Barclays 295 186 Aviva 299 187 Nikhil Chauhan 304 188 Owen Hoye, OPH Financial Consultants 305 189 Towry 310 190 Jonathan Blake, Independent Financial Adviser 314 191 Peter Falls, Financial Adviser 317 192 Mark Gosling, Castle Investments Consultants 328 193 Paul Naylor, A P Financial Services UK Ltd 331, 335 194 D Frost, Norwood Financial Services 337 195 Laurence Frazer 338 196 Mrs McCartney, Independent Financial Adviser 341 197 W H Ireland Ltd 342 198 Chris Dodd, Independent Financial Adviser 343, 347 199 Julian Ellis 344 200 A J Mathers, Mathers, Harrison & Co 348 201 J P Morgan 350 202 Angus Low 353 203 Richard Arnold Financial Management Ltd 354 4 Written evidence submitted by Sean Glorioso Reshaping Retail Financial Services to Rebuild Consumer Trust Themes Part 1. Consumer Financial Services Advice Choice Part 2. Financial Adviser Qualifications Part 3. Retail Financial Services Industry Structure Executive Summary The spirit of RDR is to recapture consumer trust in retail financial services. One of the themes is to offer consumers the choice of either accepting restricted or independent advice. The adviser will be suitably qualified to QCF level 4. The structure represented of the financial services industry distribution of retail financial services taking account of the major distributors for example Retail Banks (Bancassurance), Wealth Management Firms, Network Platforms (i.e. panel of funds), Insurance Firms, Stockbrokers and other participants will result in a restricted advice monopoly when considering the application of EU Competition Law principles to the supply of a particular product and/or service. The forgoing therefore means that RDR in principle offers no real benefit of choice given that the consumer won’t be in a position to access readily on national basis independent advice. This also therefore disenfranchises localised community Solicitors, Accountants and other Professionals including Trustees given the Trustee Act 2000. Moreover the QCF Level 4 qualification therefore under a restricted advice label won’t have much practical application given that some restricted providers won’t facilitate a full product solution thereby rendering the qualification inappropriate for a particular adviser. Changing the industry imbalance to the advantage of the consumer will only come about if serious consideration to the FSA enforcement powers to tackle poor advice is strengthened. The RDR position therefore means that the restricted advice label will become the advice monopoly that will destroy the long term prosperity of the mass affluent consumer in that the consumer will continue to suffer from poor advice given that no real choice will be available on a national basis. Part 1 . FSA RDR Stance on Consumer Advice Choice – Restricted or Rebuilding Consumer Trust through a deeper understanding of Independent and Restricted Advice. Reshaping the industry in order to deliver financial solutions to meet consumer needs. 5 Independent Part 1. A. FSA - RDR Definition: The Restricted Advice Choice Label 1.1 Restricted advice by far is the most predominate in market share. 1.2 Restricted advice equals a selected panel of products to provide solutions to consumer needs. 1.3 Restricted advice totals poor consumer outcomes given that it effectively sets up advantage for the distribution channel and adviser rather than to the advantage of the consumer. 1.4 Restricted advice does not provide financial needs solutions it pushes products on the consumer. 1.5 By way of example in answer to 1.4, Bancassurance sets out a single product that moulds to needs rather than tailor to specific consumer need. In some instances this is beneficial given that a particular product may benefit that particular consumer need but by in large each consumer need given their unique circumstance requires a combination or single product that predominantly falls outside the scope of the restricted panel of products. Part 1. B . FSA - RDR Definition: The Independent Advice Choice Label 1.1 Independent adviser choice provides a wider scope to meet consumer needs given that it’s a whole of market choice. 1.2 The FSA register of dual qualified advisers i.e. those that are classified as stockbrokers as well as financial advisers and/or any research evidence available to the Committee will show that the Independent Adviser market share is a tiny fraction of the restricted adviser market share. 1.3 Independent advice acts as a far more positive consumer outcome given that it has the ability to serve each individual consumer need. The spectrum of whole of market products offers a wider and deeper product suit to meet the unique consumer needs. 1.4 The Independent advice label is the only single vehicle that can support Trustee responsibilities under the Trustee Act 2000. 1.5 Independent advice captures a larger consumer audience of needs than the restricted advice label. 1.6 Likewise the independent advice provided is a far more robust method of delivering financial advice given that it provides solutions to needs to a greater audience and it does not push product on a need that does not require the same. 1.7 The difficulty however in seeing growth in the Independent advice label to cater for a wider consumer audience lays in the industry structures particularly given the 6 market share that Retail Banks (Bancassurance), Wealth Management, Insurance firms , Networks (panel of funds) control. Facts that the FSA can readily provide the committee. 1.8 The North American retail financial services sector is far more robust in delivering independent financial advice solutions to consumer needs examples may include some of Americas best known and largest financial services firms Wells Fargo, Edward Jones, and Merrill Lynch and in Europe AWD Holdings AG. 1.9 The Independent advice label will provide greater Long term Financial Stability to the Consumer and British Savings Market. 1.10 Further the interdependence of fairness and trust with the consumer will increase in ratio as the advice provided will serve the consumer need thereby forging stronger relationships of trust between adviser and consumer over the long term. 1.11 Further the mass affluent consumer will have greater scope to access financial solutions that meets their needs rather than product solutions that do not meet the consumer need. Part 2. Financial Adviser Qualifications 2.1 FSA QCF Level 4 main outcome objectives; 2.1.1 Increase Professional Financial Adviser Standards 2.1.2 To achieve a more positive consumer perception outcome for Financial Advisers 2.2 An adviser qualification plays only a small part in the relationship wheel of trust between adviser and consumer. 2.3 The QFC Level 4 will achieve greater financial adviser literacy will it though create a better landscape of financial services delivery in that more consumers benefit from solutions that meet their needs rather than match the restricted provider’s sales volume targets. 2.4 The adoption of QFC level 4 will not deliver better financial services delivery to the mass affluent given that a great proportion of the retail financial services distribution platforms i.e. the Bancassurance models, other restricted providers will only seek to reduce the product options available to consumers thereby rendering a QFC level 4 qualification nonsensical for those advisers and therefore disenfranchising the mass affluent. 2.5 Smaller firms operating as pre RDR label classification of independent i.e.
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