The culture and leadership of an advice business looms central to Principle 12, which was introduced as part of Consumer Duty. Creating repeatable processes ensures you do not have renegades within your business who might undermine your compliance. In this article, Emma shows you how to start documenting these.

Investment Pathways have two fundamental issues for your business that you may not have been aware of. FCA policy statement PS19/21 introduced the requirement for drawdown providers to offer non-advised consumers Investment Pathways. Consumers entering drawdown, or transferring assets already in drawdown, without taking advice, must be presented with four options on how they might want to use their drawdown pot. Reading that, you might think Investment Pathways are nothing to do with you or your advice firm and think no more about it. Unfortunately, you would be wrong. Although Investment Pathways apply to non-advised consumers, an adviser will need to consider the Investment Pathways a provider has in place when assessing suitability. COBS 9.3.3A now states: ‘When a firm is making a personal recommendation to a retail client about the investment of funds in the client’s capped drawdown pension fund, or flexi-access drawdown pension fund, its suitability assessment under COBS 9.2.1R(1)(a) should include consideration of pathway investments.’ What does this mean for your advice process? To understand this, let us look at what Investment Pathways are. Read more