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To FAP or not to FAP, that is the question

There is plenty of ongoing discussion in the market around this question but should we also be asking – who owns the clients?

Thursday, October 3rd 2019, 9:10AM 15 Comments

by Jon-Paul Hale

All jokes aside, no don't go google FAP, my GP did and got a hell of a surprise!

There has been a bit of noise in the market recently, and it has raised more than a few questions. I mentioned Hon Kris Faafoi's cabinet paper in my last epistle, and I'm still seeing the same old assumptions coming though.

BNZ is pushing dealer groups to be FAPs, people are questioning dealer groups not being FAPs. Dealer groups are challenging the advice risk they might have to take on, and generally, everyone to date has missed a vital point.

Who owns the clients?

Because that my colleagues is what is going to determine – to FAP or not to FAP.

I'll draw your attention to the new legislation.

431D When financial advice service is provided

431D(1) A person (P) provides a financial advice service if, in the ordinary course of P's business:
(a) P engages one or more other persons to give regulated financial advice to P's clients on P's behalf; or
(b) P gives regulated financial advice to P's clients on P's own account.

So let's unpack this more simply.

Amit Singh calls ABC Insurance & Mortgage looking for advice on finance for his new home and insurance for his family.

ABC Insurance & Mortgage is owned by Liam Diamini, who is also an adviser in the business. He does the mortgage work, and Sophie Scholten looks after the insurance advice.

So the first point: Amit, is a client of ABC Insurance & Mortgage, which makes ABC Insurance & Mortgage a FAP. The client is the business's client and is being advised by the people in the business.

That is to say, Liam being the FAP director is also an FA. Sophie being an employee, is also an FA.

So in this simple structure, it's clear that Liam has to be a FAP and Sophie does not.

Now If we step back from that and look at the dealer group(s) above, we have a slight challenge in applying the same approach to the dealer group.

The client is not a client of the dealer group. Hmm ... No client, no service, not a financial service provider.

  • The dealer group is not engaging with Amit, Liam is.
  • The dealer group is not providing advice.
  • So there is no capture of the dealer group under the definition of financial advice provider. So they can't obtain a licence as they cannot demonstrate that they are providing advice to their own clients.

So my friends and colleagues, please tell me how a dealer group can be a FAP over your business?

The only way a dealer group can meet the definition of a FAP is to own your clients and engage you in servicing these clients.

Now certain businesses that fall into the dealer group camp are structured this way.

SHARE, for example, they are a co-op owned business, where all of the advisers own a portion of the company, and the head business owns the clients and engages the adviser to service them.

However, the majority of advisers have a problem with another business telling them how they operate. Additionally, they are not happy about anyone else owning their clients.

So, the questions are, do you want control of your business and your clients, or are you comfortable abdicating them to someone else? The former, you need to FAP, the latter not so much.

However, right from the get-go, dealer groups and aggregators have been left out of the structure consideration. I have been in meetings where this has been discussed, and there have been clear decisions made to have it this way.

So when I look at the discussion between BNZ and Newpark that I have been privy to, being a member, it leaves me scratching my head on what BNZ is trying to achieve.

Also, the spectrum of providers in the mortgage space appears to have a view that is somewhat based on shooting from the hip ...

From Newpark Home Loans which is challenging the BNZ approach to others that are thinking they will carry on, as usual, maybe import a system or two, through to the other end that is obviously unclear on what the legislation is and what the liability will be.

Newpark and the other mortgage aggregators don't fit the definition of a financial advice provider.

Their clients are adviser businesses. The clients of those adviser businesses are not dealer group clients.

To suggest that dealer groups should be FAPs is also to suggest that Strategi, QPR, Financial Advice NZ, SIFA, Liberty, IFA, and others like them should also be FAPs. I'm pretty sure the associations are not looking to licence.

Which does create a further wrinkle.

Advisers looking to their dealer group as a safe harbour while they work through licensing, or intending to stay as an FA under the dealer group, need to consider the distinct possibility that the dealer group may not be able to licence as a FAP.

The cynic in me suggests that the banks, BNZ being the first, like Southern Cross in July, are being opportunistic to controlling adviser access to the product in the market and perverting the natural structure of advice businesses and delivery of advice in New Zealand.

Discussion is good, and with the continuing debate, we further unpeel the onion that is FSLAA. We still have MBIE to tell us about disclosure, and a few other bits that need to settle out.

However, this structural requirement in the legislation means that many advisers who have been sitting waiting will need to move now. Today, right now.

Because the FA option of owning your business and being under a FAP is not as simple as the market presently suggests, be it risk, mortgage, general insurance, or investments, this issue is the same.

Tags: FAP Financial Services Legislation Amendment Bill Jon-Paul Hale licensing Opinion

« Finally, a breath that suggests it's not all about the advisers and their adviceWhat is the advice risk? »

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Comments from our readers

On 4 October 2019 at 3:52 pm Tony Dench said:
Interesting article JP and it's a subject that is worthy of further consideration by advisers. SHARE offers advisers a flexible and wide range of ownership options and many SHARE advisers continue to own their own book.
On 5 October 2019 at 10:50 am JPHale said:
Thanks Tony. Yes, I quite like the share model, especially for those advisers who are looking to retire where they can do so graciously.

It is the ’ownership’ of the client that determines the FAP status, the issue is more complex than I have outlined, but it starts with the simple position of where the client's sit.

The point of the law is clients of P. That doesn't mean there is commission involved, that is who the client is engaged with.

The QFE model is the closest comparison. An adviser under a QFE would present documents that stated the client was engaging with the QFE and the adviser was doing the work. With all responsibility with the QFE. Under the new rules the FA is now also responsible.

Under the new rules for the FAP to qualify to be a FAP the client needs to have a ’contract’ with the FAP, if the dealer group [DG) doesn't have clients engaged in this way, they don't meet the criteria under the law 431D.

Also too, this means that the FAP has responsibility for the adviser conduct on all client's. Which for many DG’s is a requirement that they won't like taking on, if at all.

Then you have the issues of authorised bodies (AB) and interposed businesses (IB).

The AB (and FA under the FAP) sits under the FAP and gives advice on the FAP’s clients under the FAP’s rules of advice.

The IB is a bit different, they give advice on clients owned by a FAP but under their own advice basis.

The referring (owning) FAP may be a mortgage business and the IB an insurance business, so the advice would be the IB’s, meaning that they need to be a FAP in their own right, and the referring FAP isn't responsible for the IB. (my understanding, open to correction on this)

Either way, if the DG doesn't have clients contracted to them, they don't qualify under 431D to be a Financial Service Provider.

One of the only ways to achieve this is for the DG to have direct FA’s, adviser’s who are individuals and sole traders contracted to the DG directly. In this situation the DG has clients and is a FAP, which would then allow them to also have IB’s and AB’s under them.

However, the responsibility for the AB is still about the client's of the FAP, so while the AB may be able to be an AB, their clients still need to be contracted exclusively to the DG FAP. The AB can't take on clients and give advice to it's own client's, that would trigger a requirement for the AB to be a fully fledged FAP.

The IB is a little different under a DG FAP as they have to be a FAP in their own right. Which makes the situation quite messy as to who is responsible for what. The reality is the IB FAP is the primary FAP responsible. And this structure is more akin to the DG - RFA arrangement we have presently. The RFA becomes a FAP and the present approach continues. While the DG is not directing advice, they can provide advice systems, the DG is not required to be a FAP.

So while the Share model is a great model, it is mostly compliant with the new structure to be a FAP. Businesses that still have their own clients directly under Share need to also be a FAP as an IB where those that only service clients owned by the Share FAP can be either FA’s or AB’s

When Newpark have come to market and said they aren't a FAP, they don't own client's and they don't have a contract with clients, they barely have contracts with their adviser businesses. They have a membership, much like an industry association, so a quite different model to Share.

Which raises another point, and hole in the present rules. A business that builds and supplies advice systems and tools is not captured under the new regime as they don't give advice to clients.

The FAP is responsible for the advice to their clients, and they are also responsible for ensuring that the advice systems they employ are compliant with the advice requirements and rules under the law and code of conduct. Which also has it's challenges when a business imports the operating system and assumes that they have it right.

Which is an interesting one for me, as I could license what we do as an advice system and provide it to FAP’s with no responsibility for the advice that was generated and given from it.

Personally that concerns me as a FAP, as I'm responsible for the advice generated. Which is why I have build the advice systems internally in my business, which are compliant with the new rules, to remove this potentially significant risk.

All of this reinforces my approach to continue to build a shared ownership model in my business Willowgrove, which enables us to continue operating as we do without drastic change. It also ensures that I have visibility of the risk my advisers generate so that I am very clear on issues and have the ability to react and mitigate any developing risk in real-time.

But then most looking in would only see we have a snazzy report tool. The problems that come from FAP licensing are far greater than the report tools, they come from the whole operating system of the business. One we have covered and are comfortable rolling with, with the right advisers who are focused on the best outcomes for their clients.
On 5 October 2019 at 1:57 pm Doggy said:
Oops. The only conclusion is the legislation never intended to licence dealer groups in the first place...
On 7 October 2019 at 7:55 am Backstage said:
It was reasonably obvious the FMA did not really understand where these groups fit in the value chain. Had they known its my view their culture and conduct would have been reviewed. The question going forward is do they fit and if so where? Put mortgages aside. In the risk space (Share aside) any actual aggregator, now politely named dealer group, will struggle to demonstrate tangible value that and insurer is not already providing.
On 7 October 2019 at 10:42 am Ron Flood said:
If dealer groups were recognized, and could become FAP's, I would expect there would be a major shift in the way they operated. It is one thing to receive over ride commissions on an advisors production. It is another to be liable for the advice they give.
I would expect there will be some culling over time.
On 7 October 2019 at 11:49 am The Oracle said:
Clear as mud!!!
On 7 October 2019 at 2:51 pm JPHale said:
@Backstage the review of advice legislation was just that advice legislation. The dealer groups did not figure in the discussion because they don't give advice. Or don't in the more clinical obvious way, I get the influence that does flow through, but that is also for advisers to ensure they manage too.

My own questions along the way had a very clear answer, aggregators and dealer groups were not in the scope of the review. As @Doggy has said, Thus my comments about them being considered more akin to an industry association.

Share is an example of a hybrid co-op business that fits in several categories. Which also means the advice liability isn't any less, frankly higher.

And @Ron's point about a major shift in how they operate, very much so. Though override wise there is still more to come on that. The FMA seems to be quiet on the subject and largely isn't concerned and insurers are yet to be clear on what they are doing.

What is clear, if the dealer group operations are going to continue, they are going to have to look at what they do and what their value proposition is.

To my mind, dealer groups that bring advisers together, assist with acquiring business services and better agency terms, and generally approaches the industry as a place to be, celebrate and be part of are going in the right direction for me.

This is a hard industry with the day to day grind, we need psychological support as much as we need the $ and c's, and this seems to have got lost in more recent years.
On 7 October 2019 at 5:58 pm Tony Vidler said:
I do not disagree with JP's arguments, but would suggest that in addition to his arguments there are 2 concepts upon which the regulators, and in turn institutions, have not fully grasped the implications of. Or don't want to. They are:
1. This misconception that anyone "owns clients", and the associated implication that to be a licence holder (or FAP) and responsible for advice one has to "own clients".
2. The restrictions upon who or what can be a "Financial Service Provider" (FSP)

Many integral parts of the distribution system do not meet the legal criteria to become an FSP. I for instance run a network of about 35 advisers which has never tried to be a dealer group or similar, but the entity which holds agency agreements, adviser agreements, commission sharing arrangements, exclusive IP and so forth is not in itself an FSP. Despite attempting to convince the Companies Office of the merits of registering that entity as an FSP, registration was refused. It simply didn't, and still doesn't, meet the definition prescribed in law for a Financial Service Provider.

Any dealer group or aggregator in the market which does not directly provide a financial service themself will get the same response currently.

So problem one is the inability legally for distribution businesses which manage advice channels (in a variety of ways and with varying degrees of responsibility at present) to register as FSP's. They simply cannot meet the first hurdle which is required to become a FAP. Therefore no matter how much the institutions may wish aggregators or dealer groups to provide a convenient cut-out in the good conduct liability chain, they simply cannot do so currently.

Further compounding the confusion is the prevailing view that somehow the party which shall be responsible for the advice given to a client has to have some form of ownership of that client. The very use of the term "ownership" is in itself misleading, as at best all that can be claimed in financial services distribution is the ownership of a contractual right to an ongoing income stream associated with a product sale, or with the prior agreement of a consumer to receive an ongoing service. Nobody owns other humans anymore in case nobody noticed.

No client is owned in either scenario there. Nor is there necessarily even an ongoing commitment agreed to by either the client or the adviser to continue delivering further financial advice. There may be an agreement for service; but an agreed service does not have to be the same as the definition of a "financial service" and nor is it necessarily advice either. So it is entirely conceivable that a financial adviser and a consumer can have a contract for ongoing professional service which does not include the delivery of further financial advice or financial services.

Equally, it is entirely conceivable that a consumer and a financial adviser can interact and decide not to enter into terms of engagement with each other. During that interaction there is every possibility that recommendations, opinion or guidance to do (or not do) something were provided other words a financial service or financial advice can be delivered to consumers who are not, and never will be, clients at all. I am sure that the intent of the regulator is that advisers will be held accountable for such advice, whether the consumer turned into a client of the advisers (by anyone's definition) or not.

So we have a situation where it is entirely likely that advisers will be responsible legally for advice provided to consumers who never became clients. That should kill off the stupid "client ownership" concept then..unless advisers can have a "get out of jail free card" if the consumer decides not to engage, but just took up the "free first hour consultation"?.

Similarly, a FAP can operate quite successfully on a commercial basis without ever "owning a client", or indeed ever directly interacting with a consumer itself.

To pick up on the examples cited here previously; why can't Newpark be a FAP and manage quality control, compliance and best practice standards delivery and enforcement for a multitude of competently qualified Financial Advisers? Why would Newpark have to be engaging directly with consumers itself to be able to manage the standards of its advisers? Of course I use Newpark as an example, and we can substitute at least a dozen other entities in lieu with the principle remaining the same.

There is no logical reason I can think of that suggests Newpark must have consumers it provides advice to directly in order to competently and professionally do its work as a FAP.

I believe that the current confusion (I'll call it that to be kind) around distribution groups needing to become FAP's is rooted in misunderstanding by policymakers of the support services valued and expected by financial advisers. Those support services which come via a variety of distribution models are highly valued by a massive proportion of the distribution population and assist greatly in elevating education and behavioural standards, business eficiencies, cost management, and morale. They are necessary, and they are good for the industry.

Compounding the misunderstanding of the relevance of these distribution management groups though is further confusion around the responsibilities for conduct and good customer outcomes at present. That is understandable - it is early days after all and muchg of it is still being worked out.

While it may be understandable it is also not acceptable that institutions can insist that the industry must find a way to achieve a structural status that the law does not currently permit. If that is the legal advice they are getting, they need to find better lawyers. Or the regulator or policymakers need to set the institutional thinking on the right path.

The real keys to getting this right for the market as a whole is for the industry to understand that the responsibility of the FAP will be primarily to ensure that good conduct and good behaviour are supported by good standards and good competency frameworks for the practitioners they are responsible for....whether they are interacting with clients of the FAP, clients of the Financial Adviser (which is a permitted structure), or consumers who decided not to become anyone's client.

Client ownership is not an appropriate determinant of responsibility. If that line of thinking continues then there is a very real prospect of incredible structural disruption throughout the industry.

Of course, it should be said that if institutions and policy makers really want control of distribution to be placed in the hands of the dealer groups, aggregators, et al, then a simple change to eligibility for FSP registration should achieve it. After that we could, presumably, look forward to emulating the Australian experience where some 92% of distribution was controlled by institutions within just a few years of financial services reform.

That worked out really well for consumers, regulators, institutions and advisers, didn't it?
On 7 October 2019 at 9:18 pm JPHale said:
Thank you Tony for your valuable input into the discussion. And I agree entirely on the ownership comments.

Idid use the term for a broader colloquial/conceptual understanding. And yes, in the context of a FAP or financial advice service I am meaning a contract of advice with a consumer/client.

And yes, under nature and scope there could be no ongoing client relationship due to the advice given, but responsibility for the adviser continues.

The law is quite clear that advice is given when a financial services product is advised to be held, disposed of or acquired. Which also brings the rest of the client's portfolio into scope if it is not scoped out.

I.e. You're talking IP but don't ask about the existing life or trauma and don't scope it out, the hold advice on the existing cover is potentially implied on the critical review of the regulator looking back when the client complains things didn't go to plan. If you recall the AMP-Sovereign transfer in Christchurch circa 2008, where non-disclosure resulted in the bloke turning up on our boxes. That case was poor replacement, but the alternative could have been true, he got $10k from his AMP policy but is left with the $390k mortgage because the advice wasn't given to increase over in an appropriate way.

It is these scenarios that people have not thought about in the way they presently do business, and they need to apply this more extreme test of what they do to better understand how the regime is going to impact.

I agree, Ownership is an outdated concept in our industry, the insurance company owns the client based on the contract they have directly with the client. And the agency agreement the adviser has, vests certain rights to the adviser, primarily marketing, information access, and income rights.

Which can change with the application of a change of servicing adviser with many agreements.

This too has recently been clearer with the servicing of certain company’s products, renewals (now servicing) now following the servicing adviser, changing what has been an over 20 year approach to vesting renewal with the originator,

I’d like to think that the decisions not to emulate licensing of dealer groups was to avoid a repeat of Aussie. Not a comment I have heard directly, but I have had the comments made to me that dealer groups we're not part of the advice picture. They may be coincidental in alignment, hard to tell with the deeply nuanced impacts the new legislation is going to have on us all.

Thanks again for the technical expansion and addition to the discussion.
On 8 October 2019 at 4:58 am Tony Vidler said:
you're welcome JP - it is an issue affecting everyone and requires further consideration by policymakers given the stance being taken by institutions.

For what it is worth, my feeling is that a year or so ago a fair proportion of the major stakeholders in the industry probably felt that a smaller number of FAP's effectively holding responsibility for a large number of advisers of varying competency standards was probably a good thing. The Royal Commission highlighted the dangers of that and I sense there was a distinct shift in policymakers thinking following that, but which has not necessarily flowed through to other stakeholders as yet. There IS time for it to do so, however the clarity on legal structure requirements in the new regime HAS to come from the policymakers rather than the people on the streets.
On 8 October 2019 at 8:41 am Tony Vidler said:
you're welcome JP - it is an issue affecting everyone and requires further consideration by policymakers given the stance being taken by institutions.

For what it is worth, my feeling is that a year or so ago a fair proportion of the major stakeholders in the industry probably felt that a smaller number of FAP's effectively holding responsibility for a large number of advisers of varying competency standards was probably a good thing. The Royal Commission highlighted the dangers of that and I sense there was a distinct shift in policymakers thinking following that, but which has not necessarily flowed through to other stakeholders as yet. There IS time for it to do so, however the clarity on legal structure requirements in the new regime HAS to come from the policymakers rather than the people on the streets.
On 8 October 2019 at 11:22 am w k said:
the frustration for everyone here is that the situation is no different from assembling a bunch of brain surgeons to overhaul a car engine.

On 8 October 2019 at 5:26 pm JPHale said:
@ w k, yup, Welcome to the human condition to take a simple concept and make it complex
On 9 October 2019 at 10:42 am w k said:
@jphale, that's how some justified their existence. suppose it's how some jobs are created. pretty much like changing the light bulb is no longer a one man job. you need at least 4 men to hold on to you, turn you clockwise to take the blown bulb out and then turn you anti-clockwise to put the new one on. not forgetting the 5th man to hand you the new bulb.
On 12 October 2019 at 1:49 pm JPHale said:
Two points of clarification for those hard of comprehension (background discussions)

I haven't said dealer groups cannot register as a FAP, what I have said is by the rules in the new legislation the majority of dealer groups, in their present form, do not meet the criteria to be able to license as a FAP.

Secondly, the majority of advisers expecting to be under a FAP and ’own’ the client relationship are also going to be challenged.

The client advice relationship under FSLAA is one between the client and the FAP, not the FA or the Authorised Body. (from here on when I say FA it mean either interchangeably)

This distinction may not appear significant to dealer groups or providers, however it is a significant point for advisers as it speaks to their brand.

There are three pillars in this discussion, the legal one, which I have raised, the commercial one (contracts) and the business one (trading environment)

The issue for advisers is you will need to be clear with the client who the advice is being provided by. Under the law it is the FAP, the FA is contracted to deliver it for the FAP, but it ultimately comes from the FAP.

Which means if Newpark did have a FAP and I joined and operated under it, I would have to be clear to the client that the advice was being provided by me on behalf of Newpark.

I’ll let that sink in...

When the products in the market are the same for all advisers, the premiums, terms and conditions, and the rest that goes with the products we access, the key market difference we have is ourselves and our own brands.

If we didn't have that distinction, it wouldn't matter which adviser you went to, theoretically on the providers premise, we are all the same.

We know this is not the case and for providers to be thinking we can be herded under dealer groups is significantly short sighted and somewhat insulting to put us into the category of sales people that need supervision to take that thinking to the more extreme when this is about structured regulated advice provided by advisers.

Sure there will be aspects where people are no more than salespeople, I get that, however, that's also an area that is going to have quite a different focus too. Sales targets out, sorta means less focus on sales and more focus on advice that results in ’sales’.

I do agree dealer groups have a place in the market, and there are going to be a lot of advisers who need help. No doubt about that. However, let's not get ahead of ourselves bastardising the new regime to maintain the status quo before we have even got to the starting line.

The Government, FMA, and RBNZ have all signalled they won't put up with the status quo too.

I also appreciate that there is significant money involved, and potentially at stake, the providers need income in the form of new business, just like we do too.

Where there is significant risk that advisers won’t be ready, there are reactions from providers in the market that also happen without the necessary background understanding by the people.

It's called market protectionism and control, we are about to see the biggest change in financial services most have seen, and for some it will be a rough ride.

However, while everyone will struggle to have patience, the majority of advisers are dealing with the reality, they need to get the next 90days trading behind them before Christmas.

Then when things calm down, they'll address the new regime after the break. Which means there is a reasonable chance that very little in the transitional licensing space with advisers will happen before February.

So advisers, don't panic and carry on as you were. Everyone else will make enough noise to cover our silence ;)

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