Simplified advice: Pru accuses FSA of u-turn on automated tools

Author: Laura Miller
IFAonline | 22 Sep 2011 | 10:36

Categories: Charging| RDR| TCF

Topics: FSA| Prudential| RDR| Simplified advice

pc-computers

The FSA’s consultation on simplified advice contradicts warnings it has previously made on risk profiling tools and the regulator needs to clarify its position, Prudential distribution strategy director Russell Warwick said.

In a paper published last week, the FSA said the industry could develop fully automated systems as one way for consumers to access simple products using simplified advice.

The FSA has identified simplified advice as a way of making sure the wider public has access to financial guidance.

In a fully automated system, the consumer would "not at any stage in the process have the opportunity of discussion with an employee", the FSA said. The investment advice would be given solely by the system.

Warwick said the FSA's support for this method contradicts its stance on computerised risk profiling tools.

These systems - which input client data to help advisers assess clients' attitude to risk - were identified by the FSA in January as an area of concern it linked with an "unacceptable" level of failure in firms' investment selections.

Adviser firms' over-reliance on risk profiling and asset allocation tools could lead to serious customer detriment, the FSA said at the time.

"The broad conclusion of the FSA's review into risk profiling tools was that the attitude to risk process must be coupled with a structured conversation with an adviser," Warwick said.

"But in the totally-automated simplified option the FSA [outlines], this process alone is OK. We will want a lot more detail on risk mitigation."

However the FSA has fired a warning shot at product providers and other firms who plan to develop automated simplified advice processes.

"Given that the purpose of the system would be to provide advice on investments, we would expect that a fully qualified retail investment adviser would be involved in the design process from the beginning and would need to confirm that the system was fit for purpose before it entered into use," the paper stated.

Prudential favours an alternative option in the FSA paper of an automated system of advice delivered using a computer but with a non-regulated individual to guide a consumer through the process.

"Any simplified system will need to consider three key processes; meeting the compliance requirements; meeting client needs; being commercially viable," Wawrick said.

"A computer based system with a facilitator, who is not influencing advice, is the more commercially viable option, and it has the customer preference element because people don't like just sitting in front of a computer answering loads of questions.

"But it is the option the FSA say they are most concerned about. So we will need to reconcile this," he said.

The FSA is concerned a facilitator not qualified to give advice could stray into advising clients while guiding them through the simplified advice process.

 

Simplified advice...what stakeholders are saying

Stephen Gay, director-general, AIFA
The idea you can build an algorithm which can provide some guidance to customers is less the problem than the fact you would still have to ask customers to pay for it. I'm not sure somebody is going to get their credit card out and do that.

Carl Melvin, Affluent Financial Planning
Where I have a concern is if somebody telephones in, they are looking for advice, not information. They will look at a decision tree and, faced with options one and two, will ask somebody what to do. But we will not be able to [help].

Philippa Gee, Philippa Gee Wealth Management
In some ways, this is long overdue and there are plenty of people who would like to arrange their finances in that way. As long as this is seen as the easy option for some advisers, it has got to be a good thing.

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what?

Can't wait for the first fine of a computer not following TCF!

Posted by: Rob

22 Sep 2011 | 11:23
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Prudential!

It looks like the Prudential is wanting go down a simular route to the "advised" & "non Advised" mortgage process. This is great for Lenders to deal direct with the public as it basically lets them off the compliance hook. Even though, from my feedback they have still been giving advice. One of my clients who was speaking to a Lender direct had to point out to the member of staff (doing a non advised sale), that he was trying to give him advice. The problem is its in peoples nature to try to help people make a decision. This is where the Prudentials proposal wont work in practise. You'll basically have people getting advice, from someone who's not really supposed to be giving advise. Although, you cant blame Prudential for trying to get back into the direct market. It sounds like a cheap way for them to sell loads of Pensions without having to worry about complaints made from advice. Its good how they try to support IFA'S!

Posted by: DC

22 Sep 2011 | 12:11
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Pru has a very valid point

No surprise that the FSA hasn't thought through the implications of its edicts. Clearly there will be a race to the bottom in terms of charging and automated decision trees are the obvious way to go since they will create an audit trail and be consistent, thus ticking two key FSA boxes. Pru is quite right, the FSA can't have it both ways. If it wants consistency that MUST be possible to program into an algorithm (not necessarily an easy one). If the FSA DOESN'T accept automation it MUST accept inconsistency of outcome since there MUST be an element of subjection. Hopefully the illogicallity of holding two diametrically opposing views will cause the entire FSA to burst into flames and we can all watch it on youtube. If only...

Posted by: M

22 Sep 2011 | 17:49
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