Streamline processes: Replacement Policy Forms/Research Rationale necessary? Appendices on CD OK?
I have recently joined a new firm and these are of the requirements for the file but are they really required as they just repeat what's in the report? The suitability report is at least 50 pages long ( I know, too long) with the appendices another 150 and the current process appears a little long winded and I don't believe the advisers are very happy so I am looking to help and reach a happy medium by removing them providing the necessary research is saved to file.
Also is there any problems with placing the appendices on a CD as the amount of paperwork the client currently receives is very overwhelming and that excludes the apps I have not mentioned. A merged appendices file on pdf is also evidence of what the client has received.
Any help from your experiences in this area would be greatly appreciated.
Comments
Hi,
We trialled providing appendices on CDs a few years ago at a previous firm I worked for, and it did work for a section of clients but there were some problems and it was ultimately abandoned:
I would suggest speaking to the firm's compliance department/ consultant about it as there are probably differing views on what is acceptable and what isn't in this regard. 150 pages for appendices sounds extreme to start with but I guess if you are recommending an in house portfolio via a platform and are including KIIDs, KIDs, T&Cs, KFDs, and any other acronym that might apply(!) that can quickly mount up.
Alternative options might be to upload everything to a portal, or attach some files to emails (both of which provide better evidence of the regulatory information being provided).
Exactly what we do.
200 pages for a report sounds excessive. I know things can mount up but that would point to unneccessary information being included (eg explaining an ISA for a pension switch - I have seen this!!!)
150 pages. Is it a really big font size?
The appendicies is mainly KIIDS,Provider Key Features, T&C,Illustrations, FE Comparisons etc and this is currently being placed at the back of the report. We do have a portal being set up as we speak so that may be a consideration.
Do you use Replacement Policy Forms for your file? Is this still a requirement?
COBS 9.4.7
https://www.handbook.fca.org.uk/handbook/COBS/9/4.html
Not actually that much that MUST go into the report............?
^Yep. It's very much the 'file' that most me comprehensive, not the suitability letter itself.
There's probably extensive research showing the readers will switch off after x pages (less than 200!), so what's the point.
Some readers switch off before they even start reading it!!!
It's only years later when a CMC contacts them that they dig it out and claim ignorance
We wouldn't use replacement policy forms ourselves to justify to FCA etc as the file/report covers it all, however, we are under a network who require this form so its their requirement. Its a pain as all the info is already there but they request us to pull various items out so they can check the file quicker.
We put all non-client appendices/extra reading on a USB (had them made up with our firm name on them) and we will move soon to posting these on the client portal and hopefully doing away with USBs too.