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Advisers overdoing the paperwork

Friday 7th of September 2012

Ange Lambert, a certified assessor who has marked over 250 Standard Set C assessments, spoke at the recent PAA roadshow about what and how much advisers need to do to satisfy the requirements of legislation.

And her message was that more is not always better when it comes to disclosure and other requirements around written documentation.

“The whole point of the regulations is to make advice more transparent and accessible to them [consumers]; keep it simple and relevant.”

Lambert said she had seen some “amazing fact-finders that are 10 to 15 pages long”; likely too long, she said, for clients to easily understand.

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Latest Comments
FMA outlines its latest expectations for advisers
All things said are great aspirational goals for a great financial advice industry, it mirrors what both the legislation and the code requires. However, like most things discussed it talks about what's expected not how it's done. The hardest aspect of financial advice today isn't what it is, it is how it is done. The how only comes from those that have done it, the how is only provided with examples. Guidance documents that spell out what's required along side how it it done. We’re still dealing with the same issues we started with in 2021, figuring out the how. And figuring out the how in every advice business is consuming resources that could easily be shortcut by the FMA demonstrating what they are expecting. It's not about “do it this way” its about this is the sorts of things we’re looking for. In the absence of standards and expectations, guesswork prevails. That represents significant risk to FAPs and the result is onerous overcooked advice processes for multiple advice operations and undercooked she’ll be right for single operators focused on getting the work done. Both approaches have potential for harm and as its been said earlier, leaves advisers open to explain they haven't been speeding with the authorities have pulled them over. The advice industry needs guidance on the how we know the what already.
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Who is responsible for notifying policy changes?
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FMA outlines its latest expectations for advisers
To correct errors in my previous post: "policies, templates, and controls" should read "policies, processes, systems and controls", and "is more conductive" should read "is more conducive".
2 days ago Paul Flood
FMA outlines its latest expectations for advisers
The goalposts haven't shifted, and no-one is moving the hole to the side of the green just to mess with the twilight burglars. The phrasing of the opening sentence ("having policies, templates, and controls in place is no longer enough") might suggest otherwise, but the wording is unfortunate. Having policies, templates, and controls in place was NEVER enough - it is a necessary, but not sufficient, condition of "playing by the rules" since 15th March 2021. A new player to golf might completely miss the ball on their tee shot - a swing and a miss. The wise coach/mentor/official knows that adding a stroke to the scorecard at this early stage of the player's development could have a deleterious effect. A reminder of the rule and the sanction - not applied at this early stage of development - is more conductive to continued participation. Focus on learning to hit the ball in the first instance, and move on to applying the penalty once the basics are firmly bedded in. No rule change, just a firmer application of the existing rules as the golfer matures.
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Instead of goal posts let's talk about holes. I was at a working bee at the golf club. We were doing some maintenance near one of the greens, and there was a club twilight series coming up. Just for a laugh the greenkeeper moved the hole to a particularly difficult spot, down pitch, near the edge, which rolled over a steep angle to a downhill run away from the green. Miss the hole and your off - you'd need to chip back up. Oh Steve. What I'm talking about is not "prevalence-induced", it's not a blue dot, and it's not the invention of a new risk. It's the FMA effect. I'm calling a molehill a molehill. As the supervision moves into a "mature phase" they are redefining what our safe harbour is. Until now we moved to understand what the goals were - get this qual, do these things, and you'll be fine. Now they are looking at other things, "raising standards" or changing the definition of the already-vague "good outcomes". They literally picked up the goal posts and shifted them. Moving that hole didn't change the stroke index. The rules of the game didn't change. It affected every player equally, and we all had the same goal to aim for. But moving it sure made things harder for everyone.
2 days ago agressively passive