Following the FCA’s release of its findings into its recent ongoing advice review, TCC’s Chief Product and Commercial Officer Garry Evans catches up with our Technical Director David Boyhan – who specialises in wealth management to unpack all the detail.

In the second instalment of five-part mini-series, Garry asks David what firms should be doing about clients who are not engaging with them. Watch part two now to learn more or read the transcript below.

Watch part two:

Garry:The 2% of clients that weren’t invited for a review will require some sort of standard remediation and redress approach. But for the 15% of clients that either declined or didn’t respond to the offer of review, what should firms be thinking about doing for them?

David:

Yes, that’s a great question Garry. And I think the first thing is to reiterate the point you’ve made there about the 2% of clients who weren’t invited to engage in the process. The FCA gas been quite clear that they would expect those clients to be paid some sort of redress.

But in relation to your question about clients who have not been engaging, the first thing that firms need to do is to go back to 2018. The FCA is being very clear that firms need to go back and check their data going back to January 2018. Now firms need to be looking at those clients and seeing whether they’ve been paying for a service and not receiving an ongoing review service. Maybe they haven’t been receiving an annual review meeting for a number of years. And then they might potentially consider paying redress to some of those clients. If there’s been one or two missed reviews, it’s less likely that redress would be required. But firms really need to go back to 2018, see which clients were paying for a service and what sort of service those clients were paying for.

And then obviously if clients aren’t engaging, there needs to be a disengagement process as well. This isn’t as straightforward as some people think it is because you need to take into account areas such as vulnerability and how many chases you’re going to make before you potentially cut a client off. So, I think there’s two things that really need to be done with those cohorts Garry: the first is identifying all the data back to 2018 and then making a decision as to whether or not redress may be payable to some of them.

Garry: Makes a lot of sense, thanks David. 

Watch the full Q&A video now:

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