Thank you for your patience whilst we have been adapting to the recent raft of legislative changes! We have been dealing with two of the biggest pieces of legislation to hit the UK this decade, MIFID II and GDPR. One piece of legislation requires us to collect even more information about you, whilst the latter requires us to restrict the information we hold about you! So it’s a balancing act.
MIFID II gives you even greater transparency about the charges you pay for financial products, it is also designed to increase investor protection, though with hindsight it is recognised that it does complicate matters when you are receiving financial advice on a holistic rather than a stand-alone basis.
The high-level changes that will impact on how we work with you are:
You must now receive our suitability letter setting out the documented advice and charges in advance of us agreeing any recommendation with you. Previously this could take place after a presentation meeting;
- You will be provided with a summary of actual charges paid each year for each product;
- You will be provided with a documented annual review relating to any assets that we are advising on an on-going basis to confirm on-going suitability;
- Where investment portfolios are managed for you on a discretionary basis then you will be notified within 24 hours if its value falls by more than 10% during a quarterly reporting period;
- You will no longer be able to receive information about any products available in the marketplace from us without the provision of a suitability recommendation unless you exactly match the manufacturer’s own specified “target market”, unless you qualify and have been categorised by us as a “professional investor”. This can present real difficulties where we wish to discuss some plans, such as a structured product, to diversify your portfolio. This is because the risk profile of this type of plan may differ to your own profile on a stand-alone basis, but be absolutely compatible when taken into consideration alongside your other investments. We believe that this is an unforeseen, and unwanted, consequence of the drafting of the legislation and we remain in dialogue with our external compliance consultants to minimise the impact that this is having on clients.
As you would expect, GDPR has had its own impact, and we have been busy ensuring that only those that work on your account have access to your information. The drive to protect your information does come at the price of convenience though as we are now password protecting any advice or emails containing sensitive personal information. The clear positive is that we will be able to deliver our advice reports to you faster and in a more secure manner. As with anything new, I am sure we will be learning along the way and will be making further enhancements to our service as it evolves.