Finally, paraplanners also have a role to play in establishing that clients have received “fair value” for the money they pay. This is big part of the Price and Value outcome and perhaps the hardest to prove to the FCA’s satisfaction.
For one thing, paraplanners should continue to perform due diligence when writing up recommendations.
If a paraplanner has doubts about the kind of investments being offered, for whatever reason, they should raise the issue with their advisers. Paraplanners can and should play a proactive role in refining what a firm offers its clients.
Further to that, the FCA is asking for evidence of fair value being supplied.
PROD and Services & Fees disclosure documents will help, but the Annual Suitability Report for each client is another big opportunity to establish value.
Add a section to your ASR template and include any input the client has benefited from, including both intangible and tangible aid. Here are a few suggestions.
1. TAX SAVINGS AND RELIEF
2. CASHFLOW PLANNING
3. GOAL SETTING
4. GENERATIONAL PLANNING
6. BLOGS AND OTHER COMMUNICATIONS
7. RISK PROFILING
Perhaps the major takeout from this paraplanner-specific take on the Consumer Duty is this: it not only matters WHAT you communicate to clients, it really matters HOW you communicate.
More than ever before, it is important to write with clarity, empathy and accountability.
Do this and you will go a long way towards helping your business meet the FCA’s 160-page call to action.