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FCA prunes ineffective disclsoure communications to HNWs

Chris Hamblin, Editor, London, 17 October 2016

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In response to comments from interested parties, the United Kingdom's Financial Conduct Authority is slimming down its rules for financial firms' pre- and post-sale documents and other disclosure events.

One decision it has made - and brought to pass - is to end the requirement  for  firms that operate "with profit business" [sic] to produce ‘Consumer-Friendly Principles and Practices of Financial Management’ (pre-sale) documents. A small number of respondents to its consultative paper argued that some consumers find the document helpful and, in the absence of an alternative disclosure, that firms should continue to produce this item of disclosure. Be that as it may, the FCA has removed it. Firms still ought to consider consumers' "information needs" but they now have greater freedom to decide how to deal with them.

The regulator expects this to be of interest to insurance companies operating with-profits business, their customers, potential customers and firms providing advice on this business. Policy statement PS16/23 contains the details.

All respondents to the paper supported the FCA's proposal to remove the requirement for each AFM of a UCITS scheme or a non-UCITS retail scheme to produce a short report. It has therefore done so. The short report was a half-yearly post-sale document. It had to contain the most useful and relevant information about the fund’s performance and activities during the year or half-year under review.

Changes have come to the Initial Disclosure (IDD)/Combined Initial Disclosure Document (CIDD), templates introduced by MCOB and ICOBS disclosure rules in the mortgages and home finance conduct-of-business sourcebook and the insurance conduct-of-business sourcebook that firms can use to disclose their services and the cost of those services.

Most firms in the survey supported the regulator's proposal to remove the IDD, CIDD and SCDD templates D for insurance, home finance and investment firms from its rulebook. Some said that this should give them leeway to design their communications around the needs of their customers. In light of this feedback, the FCA has decided to proceed.

All changes will take effect on 1 February next year, except for the removal of the rules for short reports and the CFPPFM which is going to take  effect on 22 November this year.

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