Investment Bonds and Ex-Post Disclosure
Nath
Member
Morning All
Just a quick question on this which I am sure has been done to death so apologies. One of our advisers has questioned whether Investment bonds need to fall under the aggregated annual charges disclosure that other products may fall under.
We have always included them as we include all products as good practice, however, is there a specific rule for insurance based investment products. I appreciate they may not necessarily fall under MiFID rules but my understand was the IDD rules that it does fall under were pretty much in line with the MiFID rules nowadays anyway.
COBS 16A is the nearest thing I can find to confirm this but wondered if anyone had a specific source to confirm this either way.
Regardless we will continue providing it for all as good practice but its annoying me I can't find anything specific on this.
Thanks
Nathan
Comments
I may have already answered my question with the below but would welcome others thoughts anyway:
https://www.pruadviser.co.uk/knowledge-literature/knowledge-library/frequently-asked-questions-about-mifidii-and-idd-disclosure/#
Hey Nathan! I would myself but it's often a hard distinction between over caution and overdoing it for me. I think the dangers of not doing it, outweigh the time in doing it, so I'd concur that doing it is safest all round!
Least if we're both doing it, and we don't need to, you're not alone in overdoing it!
The article you've linked is probably the best single resource on the differences.
Ultimately, if advisers don't want to be fully transparent about all non-mifid scope products then they don't have to be. But unless you're using a platform that specifically doesn't do that hard work for you, and there are a few, I don't see any reason not to disclose all costs to mifid level. There doesn't appear to be an obvious reason why avoiding the disclosure of known charges would be in the client's interest.
Thanks both, I agree in full. It wasn't that the adviser didn't want to, he just purely asked the question (which I wanted an answer to
)
Perfect! Glad we all got to the same outcome!