PIMFA Fortnightly News Bulletin 9th August 2019

PIMFA - Building personal financial futures

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PIMFA Fortnightly News Bulletin - 9th August 2019 Welcome to the PIMFA Bulletin, our fortnightly e-newsletter delivering a snapshot of the latest news and current affairs from within PIMFA and the industry.

What is PIMFA working on?

PIMFA Brexit update Prime Minister Boris Johnson has completed his first week in office. In meetings with devolved governments in Scotland, Wales and Northern Ireland, he has reiterated his position that the UK will be leaving the EU on 31st October "come what may". The EU has not showed any willingness to abandon the backstop and renegotiate the Withdrawal Agreement. In view of this situation, the Government has stepped up its preparations for a no-deal Brexit and will continue to do so over the summer. With a parliamentary majority of just one, a divided party and several former Cabinet Ministers reportedly leading the rebellion against the PM’s Brexit approach, the likelihood of a General Election in the Autumn continues to increase.

In the current political climate, it is critical that PIMFA members are prepared for the ‘no deal’ scenario on 31st October. They should ensure that their clients are aware that a ‘no deal’ scenario is a real possibility and that they understand what this means for their business operations and contracts. Our advice to PIMFA firms

remains the same – after Brexit, passporting will cease to exist and firms wishing to access clients in the EU Member States will need to consider options including: -

Setting up an entity in each Member State where there are clients

-

Setting up a passporting subsidiary in one EU Member State for all EU clients

-

Merging or affiliating with an existing EU based firm

-

Seeking an alternative provider to the EU clients and withdrawing from the EU

private client market -

Only using mitigating factors such as a reverse solicitation in situations where

they have checked that that it will work

If you require more detail, please contact Maja Erceg.

PIMFA Membership Renewal As a small not-for-profit organisation, we try to run a cost-effective and efficient business. As such, we rely on prompt payment of membership renewals. So that we don't waste resources chasing late payments, please could we ask that you check whether your current PIMFA invoice has been paid or not?

If we can be of any help with this, please don't hesitate to contact our Membership Team.

As always, we thank you for your continued support.

PIMFA's October Training Workshops October sees the launch of our Autumn training workshop schedule. We kick things off on Monday 14th October with a ½ day interactive session on Transaction Reporting to assist member firms avoid and address the common pitfalls made in recent transaction reporting failings. Places are limited, so please book early here.

We are very aware that member firms need to deliver SM&CR Conduct Rules training by the 9th December, but have limited time or specialist training knowledge to prepare FCA compliant training course materials. We have solved this problem for you by partnering up with CityHR to deliver a cost effective, FCA compliant

‘Train the Trainer’ workshop and toolkit that takes all the hard work away from you.

For more details click here.

For a full list of training workshops please click here. For more information on these workshops, please contact learning@pimfa.co.uk.

Financial Conduct Authority (FCA) to consult on contingent charging ban Following on from previous work in this area, the FCA has decided to consult on a ban on contingent charging. The FCA has conducted extensive (although not exhaustive) data analysis in this area and have concluded that in 69% of cases, consumers are advised to transfer whilst ‘most’ of these will have been done on a contingent basis. We do have concerns about the recommendations of this consultation and have previously campaigned vigorously against a ban.

PIMFA will be responding to this consultation. Please contact Simon Harrington should you have any views or queries.

Feedback Statement on Non-Workplace Self Invested Personal Pensions (SIPPs) The Financial Conduct Authority (FCA) has published its feedback statement following its discussion paper on competition in the SIPP market. They have found that contrary to accepted wisdom, many consumers invested in SIPPs are largely disengaged and unaware of both product and price features. The FCA has proposed a number of remedies which are intended to protect consumers including; better choice, increased transparency and a reduction in ‘charge complexity’.

PIMFA will be responding to this consultation. If you have any queries, please contact Simon Harrington.

Financial Conduct Authority (FCA) Policy statement on the Retirement Outcomes Review

The FCA have published its final statement on the Retirement Outcomes Review.

This review has largely been conducted with concerns about consumer interaction with the decumulation market in mind – specifically those consumers who buy nonadvised drawdown products.

The review will see the introduction of guided investment pathways in 2020. Should you have any interest in this area or concerns around implications for you specifically, please contact Simon Harrington who would be happy to provide briefings.

PIMFA/FinDatEx new version of European MiFID Template Over the last few months, PIMFA have been closely involved with FinDatEx, a new organisation aimed at producing standardised, European-wide data templates.

Together we have, through their Technical Working Group, constructed a new version of the European MiFID Template (EMT), a template for product data that fund managers produce and which contains information on the products they distribute, their characteristics, their target market and their cost.

The EMT helps considerably when it comes to complying with product governance obligations, because it often contains all that a distributor needs to know on a product. It is now being released in its third edition, with new and improved data fields which we hope will provide users with better quality data.

We are looking for feedback on this new version so that we can address any issues before it’s official release. The template will be available to comment on until FinDatEx meets again on 5 September.

To view the template, please click here.

We would be grateful for your comments and queries, which should be emailed to either Giulia Lupato or Sarah McGuffick.

Tips on getting the most out of your membership We thought that it may be useful to remind members of some top tips to ensure they are getting the maximum benefits from their PIMFA membership:

•

Please make sure your IT team have whitelisted our domains - pimfa.co.uk and

pimfa.uk – to ensure our communications are not blocked and you don’t miss out on your free member benefits such as CEO letters, Update, newsletters, useful guides, webinar and event invitations etc.

•

Check out our PIMFA Plus web area for the latest members discount on

essential services – more are being added all the time. Our latest partnership is with Insignis Cash Solutions - read more here.

If you have any questions, please email us at enquiries@pimfa.co.uk and we will be happy to help.

PIMFA Consultation Response to the EU Technical Expert Group (TEG) on EU Benchmarks & ESG Disclosures Although benchmarks are complicated financial instruments, they are intended to be used to aid consumer decision making regarding which products are labelled as being truly ‘green’ and ‘sustainable’ in line with that consumer’s personal preferences. They must be technically robust but also clear and easy to understand for consumers.

It is also important that consumers should not need to have the skills of a highly trained financial analyst to understand the benchmarks.

These considerations, amongst others, are discussed in the PIMFA Consultation Response which can be read here.

For any queries, please contact Des FitzGerald.

PIMFA's Response to Treasury Select Committee's Decarbonisation of the UK Economy & Green Finance inquiry The stance in this paper is that sustainable finance needs to be embedded across all departments and that there are plenty of alternative versions of capitalism and it’s whether the UK has the will or ability to try things differently.

Amongst other key questions, we ask;

Can HMT change its own mind-set from a polluting economy based on GDP only as a measure of success to a more sustainable one that isn’t concentrated on an accumulation model of wealth creation;

Is it really so bad if GDP doesn’t go up year after year or if the wealth we have is more fairly passed around or if profits are down because that firm is properly making long term reinvestment decisions.

To read the response in full, please click here. Any queries, please contact Des FitzGerald.

PIMFA Press Releases The latest PIMFA Press Releases: •

PIMFA letter to new Prime Minister Boris Johnson

•

Leading Cash Savings Platform Insignis Cash Solutions and PIMFA Announce Strategic Partnership

•

PIMFA: Industry must Safeguard Public Trust in Sector

•

PIMFA responds to FCA’s Action on Benefit Transfers

Read all of the PIMFA press releases here

PIMFA Consultation Responses PIMFA lobbies on behalf of our membership by utilising our members vital feedback to raise key issues across numerous key industry stakeholders from the government to regulators and beyond.

The scope and volume of regulation is a key concern and one of our key objectives is to ensure this regulation is proportionate and fair, bringing real benefits to the personal investment management and financial advice community and their clients.

Our latest consultation papers are: •

PIMFA’s Response to the BEIS’s Open Consultation on Corporate transparency and register reform

•

PIMFA’s response to the feedback on the draft technical advice on minimum requirements for the EU climate-transition benchmarks and the EU Paris-aligned benchmarks and benchmarks’ ESG disclosures

•

PIMFA’s response to DCMS’s National Data Strategy open call for evidence

•

PIMFA's response to CP19/12: Consultation on Investment Platforms Market Study remedies

Read all of PIMFA's Consultation Papers here

Credit Card Payment for PIMFA Events & Training With effect from 1st June 2019, PIMFA events and learning can only be paid for at the time of booking via credit card. There will be no option available to select to pay later on invoice. A receipt/paid invoice will be available to download for your records.

Paying by credit card at the time of booking will ensure your booking is complete and your place reserved immediately. The change in this process will also

significantly reduce the time spent on debt collection which will enable better use of PIMFA resources.

What's coming up in PIMFA? Women in Wealth Forum 8th October 2019 Fidelity International CPD: 3 hrs Our final PIMFA ‘Women in Wealth’ event for 2019 brings together colleagues from across the industry for peer-to-peer debate, networking and inspiration.

Speakers will include top female professionals from our industry and its key stakeholders to share insights and experience, as well as a practical element of takeaways suitable for both men and women on individuality within your organisation.

Speakers: •

Stuart Cummins, Managing Director and Executive Head, Needbank Private Wealth •

Liz Field, Chief Executive, PIMFA

•

Mark Freed, Chief Executive, E2W •

Anita Rolls, Consultant

Sign Up

PIMFA Annual Summit 2019 16th October 2019 etc. venues County Hall Riverside Building, Belvedere Rd, Lambeth London SE1 7PB

CPD: 6 hrs Our flagship conference provides delegates with the opportunity to investigate and gain a comprehensive understanding of the issues that impact upon the investment management and financial advice sector, providing an exceptional opportunity to debate, gain insight and network.

Speakers:

• Katy Balls, Political Correspondent, The Spectator • Torsten Bell, CEO, Resolution Foundation • Stephen Bush, Political Editor, New Statesman • Julia Dreblow, Founding Director, Fund EcoMarket • Debbie Gupta, Director - Life Insurance & Financial Advice, Financial Conduct Authority (FCA) • Dr. Rebecca Harding, Chief Executive, Coriolis Technologies • Holly Mackay, Founder & CEO, Boring Money • Daisy McAndrew. Former Economics Editor and Chief Political Correspondent, ITV News • Rt Hon. Jim Murphy, Managing Director, Arden Strategies

Sign Up

What's happening in our industry Latest news from the Financial Conduct Authority (FCA) FCA acts to protect consumers transferring out of defined benefit pension schemes The proposed ban on contingent charging is designed to protect customers from the conflicts of interest which arise where a financial adviser only gets paid if a transfer goes ahead. The FCA have carefully considered the available evidence on

the impact of banning contingent charging, including how they can maintain access to advice for those groups of consumers who would benefit from a transfer.

Therefore, the proposed ban would apply unless consumers have specific circumstances that mean a transfer is likely to be in their best interests.

The package includes a proposed ban on contingent charging for pension transfer advice, an update on the work the FCA has been doing on non-workplace pensions and the final policy statement for the Retirement Outcomes Review.

FCA Policy Statement - Optimising the SM&CR The FCA recently published final rules on the extension of the Senior Managers and Certification Regime (SM&CR) to FCA solo-regulated firms, including claims management companies. In January 2019, in CP 19/4, they consulted on changes to optimise the SM&CR. This Policy Statement summarises the feedback they received to Consultation Paper 19/4, their response to the feedback and sets out their final rules. These rules are relevant to all SM&CR firms, including CMCs.

In general, the FCA have implemented the proposed changes to the SM&CR as consulted on, which include: •

confirming that the Head of Legal function is excluded from the requirement to

be approved as a Senior Manager •

clarifying the requirements and scope of the Certification Regime

•

extending Senior Manager Conduct Rule 4 (SC4) to non-approved Executive

Directors at Limited Scope firms

To read the policy statement, please click here.

Further details of Independent Investigation into London Capital and Finance announced Dame Elizabeth Gloster, has made a first announcement of how she will conduct the investigation into the relevant events relating to the regulation of London Capital & Finance plc (LC&F).

She aims to engage with bondholders, professional organisations and other

interested parties in an organised and structured way so that she can address the issues which are relevant to her investigation.

Once she has her full independent support team in place, she and members of her team will be in touch with bondholders’ groups, bondholders and others to discuss the most useful ways in which her investigation can engage with them and take forward their offers of assistance and provision of information.

Individuals impacted by the failure of LC&F will also be able to send any relevant information via email. The email address is IndependentInvestigation.LondonCapitalFinance@fca.org.uk and will only be accessed by Dame Elizabeth and her independent team.

Latest Industry Events View all the latest industry events on our website here If your firm has an event which you would like to post on this area, please click here to submit it.

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