Allergy Advice

Spending the evening in the delightful company of some former colleagues at a dinner party on the coast (watercress soup, followed by coq au vin, then a sumptuous choice of desserts that featured syllabub, bakewell tart and/or fruit pavlova, with an extensive cheeseboard to round off) I was reminded, by the combination of the presence of the gathered luminaries and the discussion turning to food allergies, that two parties at the table had once conspired in a somewhat underhand manner (that they were not proud of) to perpetuate a joke at the expense of another former colleague (not on the guest list).

While responsible for what we now know as "financial promotions" in a former life (which I seem to recall was called plain old "advertising approval" in the last century), these two reprobates had been taken aside by the Director of Compliance and asked if they wouldn't mind reducing the pressure being exerted on the margins of the rulebook by their approach to endorsing the creative campaigns of their marketing cohorts, as a missive from the regulator had pointed out that perhaps the wind was being sailed particularly close to. In the interests of managing what was suddenly identified as a risk, the well-meaning Director (a charismatic and well-regarded old cove) announced that he would have one of his compliance managers enter the approval process as a final arbiter of the content of such promotions.

Now to say that the dynamic duo were more than somewhat chagrined at having their output rubber stamped by this third party was the understatement of the decade. Not averse to, nor ignorant of the need for a process of "check the checker", our pair were less than enamoured by the choice of overseer appointed to the task, convinced as they were that no value could be added to the product by the addition of this extra link in the chain. They were convinced that the advertising material would be skimmed at best, waived through at worst, and in the delegation of this risk mitigation strategy to the particular supervisor, the strategy was ultimately flawed.

To prove their point, they undertook what was a particularly juvenile and potentially damaging exercise, and this is how a half page advert for an investment product in a national Sunday broadsheet was published. With the usual small print there was one addition; it contained the phrase "May Contain Traces of Nut". Needless to say, the promotion, along with the mischievous embellishment, was approved by the compliance manager.

Now I thought this was the most amusing thing I had ever heard on the subject of financial promotions, until I attended a recent workshop run by the regulator, where the facilitator explained that they had a desire to eradicate jargon at all costs. Their examples of what was perceived as jargon were like a glossary of pensions terminology. If someone goes on Dragon's Den with a jargon/plain English translator, I am in.

Written under trust, ceding arrangement, elect to transfer, in specie contribution, crystallisation, arrangement, protected rights, proceeds, encashment, assignment; all these gems the mainstays of the pensions oeuvre.

One thing I agreed with very strongly in the workshop was the aspiration to do away with small print in promotions. Allergy or not, it can only end in tears...

Mark Lisle is compliance manager at Rowanmoor Pensions

The views expressed in this blog are those of the individual.

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