Treating Customers Fairly

We believe that treating customers fairly should be at the heart of every financial adviser’s philosophy.

The FCA expects advisers to ‘treat customers fairly’.

In our view, it’s a sad reflection on financial services that the regulator has to impose something that advisers should be doing anyway.

We believe that treating customers fairly should be at the heart of every financial adviser’s philosophy. Unfortunately, that’s not true for many firms – but it is true for us. Since our foundation, we’ve built our business on treating our clients in a fair, open and honest manner.

The FCA has defined six outcomes explaining what they mean by ‘treating customers fairly’. See below to read our approach to delivering each one.

Outcome 1:

Consumers can be confident that they are dealing with Firms where the fair treatment of customers is central to the corporate culture.

Clients are made aware at the outset, both verbally and in writing as contained in the Terms of Business, that the firm is remunerated directly by the client for advice and service delivered. Fees are charged half yearly in arrears. None of our remuneration is linked to the sale of financial products thus removing any possibility of bias and ensuring that our advice is genuinely impartial.

The service standards as set out in the Terms of Business apply equally to all clients. Fees are usually based upon a percentage of assets managed. Although the amount paid to us by clients might vary because of portfolio size, the percentage does not and all clients receive the same high level of advice and service.

Our M.I (Management Information) is geared toward regular customer service and contact as evidenced by the diary system which alerts the adviser and support team to future important events such as pension contributions, maturing policies, maximising NISA contributions and so on.

Outcome 2:

Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.

Products and services are marketed to our clients to meet specific financial planning needs. Products and services are not sold to clients because as fee-based wealth managers we do not sell financial products to generate remuneration and never have.

The company does not engage in the direct marketing of financial products.’

Outcome 3:

Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

The firm is only remunerated for providing first class advice and service and therefore it is embedded in the firm’s culture that clients are kept informed regularly on all matters pertaining to their situation. Our Management Information (M.I) system demonstrates that communication is frequent and pertinent at all times and systematic diary entries ensure that important future events are not overlooked.

Outcome 4:

Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Because the client pays the adviser directly for advice and service, the firm is incentivised solely to provide suitable advice in a completely impartial manner, taking full account of the client’s circumstances.

Details held on the M.I system demonstrate a clear link between the client’s circumstances and the advice given. The duty to ‘know the client’ is evidenced by a record not only of ‘hard facts’ but the client’s motivations, concerns, time horizons and attitude to investment risk.

Outcome 5:

Consumers are provided with products that perform as Firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.

Clients are always provided with products that to the best of the adviser’s knowledge will perform according to expectation and that the associated service is of an acceptable standard. There are two ways in which this can be demonstrated: first, because the firm is wholly fee-based, there is no incentive to recommend one product or another. Second, in the majority of cases, client’s assets are held on a ‘wrap’ platform. If the service standards delivered by the platform provider were sub-standard, then this would reflect badly on the Firm and because the client is paying the Firm directly, there is a powerful incentive for the Firm to ensure that provider service is of the highest standard. In cases where products are held directly, the same logic applies.

Outcome 6:

Consumers do not face unreasonable post-sale barriers imposed by Firms to change product, switch provider, submit a claim or make a complaint.

There is no financial incentive for the Firm to change product or switch provider. The incentive to change is only ever motivated by the client’s best interests because the Firm’s best interests are so closely aligned to those of the client.

Clients do not face unreasonable post-sale barriers to submit a claim or make a complaint because there is no financial gain to the Firm to do so. On the contrary, it is in the Firm’s financial interests to respect and deal with any claim without delay in order to demonstrate to the client that they are being taken seriously and that excellent service is being provided as promised. Because of this strong relationship, even if the adviser has made a mistake, it is clear that the original motivation for sale was not financial gain and that the adviser is doing everything possible to rectify the matter for the client’s benefit.