Job titles such as 'relationship manager' and 'wealth manager' might be a thing of the past if the Maltese Financial Services Authority gets its way.

The Maltese Financial Services Authority has issued a consultative document that suggests changes to its 'conduct of business' (i.e. investor-protection) rules, the better to protect customers in investment services from sharp practice and opacity regarding charges.

The regulator's internal COB task force has presented the board with a proposal (number 9) a more straightforward definition of 'execution-only' services; a proposal (number 6) for a clear delineation between 'advised sales' and 'non-advised sales'; and a proposal (number 11) for mandatory 'appropriateness reports' for all firms that perform non-advisory services. The paper lays out wording for "the client fact-find for the suitability and appropriateness test" and new specimen wording for the "suitability and appropriateness tests."

Recommendation 8 suggests that statements of compliance should be mandatory and modelled on those of the UK. The MFSA describes an SOC as "a tool to increase awareness by the client/potential client of the type of service being provided. It should not act, as has been described by the [UK's] FCA, as a get out of jail free card.'"

The proposed dichotomies between 'advisory' and 'non-advisory' transactions and 'restricted' and 'independent' advice are expected to improve customers’ understanding of the types of service they will be receiving and the corresponding responsibilities attached to them. Other recommendations relate to the employees who are authorised to provide investment advice. The regulator thinks that generic terms or job titles such as financial analyst, financial advisor, financial consultant, financial planner, investment consultant, wealth manager, securities and investment officer or relationship officer are misleading as they do not clearly describe the kind of investment service that such people provide. Consequently, the recommendations propose a 'uniform designation', whatever that may turn out to be.

The consultative document is available on http://goo.gl/j22yVB. Comments must be by email to communications@mfsa.com.mt and not later than 14th March.