When it comes to due diligence, do you look at the product first or the client? Most advisers would probably say the client, but the way the regulator is scrutinising this area is changing fast, and advisers, especially IFAs, could find their usual approach is no longer sufficient...
The incoming Financial Conduct Authority (FCA) will be primarily focused on how customers are treated and ensuring they get a fair deal. By the regulator’s own admission, its approach to regulation will become less reactive and much more pre-emptive. One of the areas it is looking at keenly is financial promotions, those documents which form the first contact between an adviser and a product. If it remains the adviser’s only contact with a product, they leave themselves wide open to fall foul of the regulator and the Financial Ombudsman Service (FOS). Time and again, the FOS has...
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