1. Investment Advice Process Flashcards
A. Investment advice process (pages 2 and 3)
Involves balancing the emotional and financial needs of the client against the expected or unexpected performance of the various available investments.
Taking a structured and disciplined approach to the investment advice process is essential to delivering consistent client outcomes and fulfilling regulatory requirements.
Overall objective is to compile and obtain the client’s agreement to a portfolio designed to meet their key requirements as closely as possible.
The aim is that each client gets the same service and outcome leading to solid long-term relationships.
A. Investment advice process (pages 2 & 3)
- ESTABLISHING and defining the relationship between client and adviser
- GATHERING client data and determining goals, expectations and any ethical issues
- ANALYSING and evaluating the client’s financial status
- CREATING a risk profile in agreement with the client
- FORMULATING the investment strategy for asset allocation
- SELECTING investment, funds and products
- SELECTING a choice of wrappers
- PRESENTING and implementing recommendations
- MONITORING the portfolio, and when appropriate, rebalancing and switching out underperforming funds
B. Establishing the client relationship (page 3)
At the start of a client relationship the adviser will be looking to establish a rapport with the client.
This will enable the information required to be obtained.
This will also help set the basis for their ongoing relationship where the goal of the adviser is to obtain TRUSTED ADVISER STATUS in the eyes of the client.
B1. Regulatory requirements (page 3)
At the start of the relationship, the adviser should provide the client with information about the:
- Scope of the services that are offered
- Cost of any work that will be carried out
Regulatory requirements are contained in the FCA Conduct of Business Sourcebook (COBS)
B1A. Client categorisation rules (pages 3 & 4)
Firm’s are required to categorise clients if it is carrying on designated investment business.
This includes potential clients and people acting as an agent for another person.
Clients may be categorised as:
- RETAIL CLIENT (most clients fall into this category, as do Public and Local Authorities)
- PROFESSIONAL CLIENT
- ELIGIBLE COUNTERPARTY
B1A. Client categorisation rules (pages 3 & 4)
THERE ARE TWO TYPES OF PROFESSIONAL CLIENT
- PER SE PROFESSIONAL. These are clients treated automatically as professional clients such as:
- Other authorised firms (investment firm, insurance company)
- ‘Large undertakings’
- National or regional governments
- Institutional investors
- ELECTIVE PROFESSIONAL CLIENTS. Are retail clients who have chosen to ‘opt out’ to be treated as a professional client. To be able to do so, they have to meet certain quantitative and qualitative criteria.
B1A. Client categorisation rules (pages 3 & 4)
CONTINUED
New clients must be notified of how the firm has classified them.
A firm must advise them of their right to request re-classification (and changes in any protections) before any services are provided.
Firms must have appropriate written internal policies and procedures to categorise their clients:
- Required to make a record of any form or notice provided to clients and each agreement entered with them
B1B. Information about the firm, its services and charges (page 4)
Firms must provide the following appropriate information in a durable medium or on their website in a manner that the client can understand:
- the FIRM and ITS SERVICES
- INVESTMENTS and INVESTMENT STRATEGIES it proposes to use (including guidance and warnings)
- EXECUTION VENUES it will use (this is where a stock exchange trade is executed - so details which exchange is used)
- COSTS and ASSOCIATED CHARGES
This information should:
- Allow the client to reasonable understand the nature and risks of the service
- Mention the types of investment involved
- Be provided in good time before the provision of investment services
B1C. General information (page 5)
Firm’s must provide a retail client with general information such as:
- Name, address, contact details of the firm
- Confirmation that the firm is authorised
- Languages in which the client may communicate
- Methods of communication allowed with the firm
- Nature, frequency and timing of the reports on the performance of the services provided by the firm
- Firm’s conflicts of interest policy
B1C. General information (page 5)
CONTINUED
Firms providing an advisory service must tell their clients:
- Nature and type of advice they will provide
- Whether or not the advice will be independent
- Whether the advice is restricted or whole of market
- Whether the service will include a periodic assessment of suitability (review) and if so, details of how and when (frequency) this will be conducted
B1D. Information relating to managing investments (page 5)
Firms proposing to manage investments for a retail client must provide the following information:
- Method and frequency of valuation of the portfolio
- Details of any delegation of the management
- Specification of any benchmark used to compare
- Types of investment that may be included
- Types of transaction that may be carried out
- Client’s investment objectives and level of risk
B1D. Information relating to managing investments (page 5)
CONTINUED
A benchmark must be used so that the client can compare their portfolio to something.
- The benchmark must be meaningful
- It must provide an appropriate indication to the client of what performance could have been achieved based on their investment objectives and types of investment included in the portfolio
B1D. Information relating to managing investments (page 5)
CONTINUED
Information on instruments and investment strategies must include:
- Appropriate risk warnings (including how the client may exit the strategy and any associated risks)
- Functioning and performance of such instruments in different market conditions
- Additional disclosures where an instrument is comprised of two or more instruments or services
B1E. Information on safeguarding investments and money (pages 5 & 6)
Where a firm holds client money or investments, it must provide details of how they will be held and protected:
- Summary of the steps the firm has taken to protect client assets (including relevant compensation schemes)
- Terms of any charge or right of ‘set-off’
- Whether the assets may be held by a third-party on behalf of the firm
- Where the investments cannot be separately designated in the country in which they are held by a third party
B1F. Disclosure of costs and charges (page 6)
Firms must provide retail clients with information on the costs and charges they will incur such as:
- Total price to be paid
- Commissions charged by the firm
- Basis on which they will be calculated (if they cannot be disclosed at the time)
- What currency the costs/charges are in and the relevant conversion rate/cost
- What other costs could be incurred
- How the costs are to be paid
- Information about compensation schemes
B1F. Disclosure of costs and charges (page 6)
CONTINUED
Where a firm provides investment services, costs and charges information must be provided to both RETAIL and PROFESSIONAL clients:
- Covering investment and advice services (and how these will be paid for)
- Separately identifying third party payments
- Including an illustration where a service is given showing cumulative effect of costs on return)
- Costs information must be aggregated to show overall cost to the client
B1G. Client agreements (page 6)
Main purpose of client agreements is to ensure clients have a understanding of:
- Reporting on investments
- Frequency of reviewing circumstances and plans
The disclosure of the above is usually made using an initial disclosure document.
There is an obligation to enter into a written basic agreement with professional as well as retail clients.
B1H. Data protection (page 7)
The Date Protection Act 2018 implemented the EU-wide GDPR and include:
- the right of individuals to have their personal data erased and to transfer it from one organisation to another (data portability)
- mandatory requirement to report a breach within 72 hours of it becoming known
- to inform the individual concerned ‘without undue delay’ if their rights are likely to be at risk
- introduction of a Data Protection Officer (DPO)
- tougher fines for non-compliance
- application of the GDPR to firms outside the EU processing information on EU-citizens
B1H. Data protection (page 7)
CONTINUED
The Information Commissioner’s Office expects firms to undertake a risk assessment based on:
- the personal information held
- how the personal information is used
- how valuable, sensitive or confidential the personal information is
- what damage or distress could be caused to individuals if there was a security breach
B2. Trusted adviser status (pages 7 & 8)
In today’s market, restoring trust and acting ethically is at the forefront for regulators, industry bodies and firms.
Trust comprises of three components:
- Trust in technical competence and know-how
- Trust in ethical conduct and character
- Trust in empathic skills and maturity
B2. Trusted adviser status (pages 7 & 8)
CONTINUED
Gaining trust requires three basic skills:
- Earning trust
- Giving advice effectively
- Building relationships
B3. Relationship phases (page 8)
Relationships tend to move through phases as trust is built:
- Working relationship started by a task being performed using expert knowledge
- Client recognises that the adviser has capabilities beyond their perceived areas of expertise (can solve general queries too)
- Adviser becomes a valued resource
- Trusted adviser status is at the apex of the client-adviser relationship
C. Aims and objectives (page 8)
Gathering detailed information about a client’s personal and financial circumstances is used to identify their:
- aims
- expectations
- attitudes
C1. Regulatory requirements (pages 8 & 9)
The FCA requires advisers to have enough personal and financial information about a client to be able to give suitable advice, in particular, whether a client:
- can afford the recommended investment / product
- understands the risks involved in the investments
- understands how the recommendations meet their aims and needs
C2. Fact-find (pages 9 & 10)
Information collected in the fact-finding stages:
- personal information
- needs and objectives
- assets and liabilities
- income and expenditure
- priorities
- attitude to risk / capacity for loss
C2. Fact-find (pages 9 & 10)
CONTINUED
Hard-facts: Age and income
Soft-facts: Ethical and family values, attitude to risk
Factfinding helps to identify:
- a client’s true investment aims / what they want to achieve
- the level of risk they are comfortable with
- how much they wish to invest and for how long
- ethical beliefs, responsible investing etc
C3. Determining goals and expectations (pages 10 & 11)
An experienced adviser will usually do this via open questions before embarking on a detailed fact-find at outset.
Open questions allow a client to speak about their experiences (which will have shaped how they feel about money).
Questions about financial satisfaction can add further detail; this is because satisfaction is personal.
Advisers should also try to elicit what principles matter to a client (i.e. they may have strong views about where / where not to invest their money).
It is also important to identify what life stage the client has reached.
C4. Assessing aims and objectives (pages 11 & 12)
Client’s initial statement about aims and objectives should not be taken at ace value.
- some aims are unrealistic
- some aims are mutually incompatible
- some aims may cause conflicts between spouses
Clients often change their views and priorities as they learn more about financial issues.
C4. Assessing aims and objectives (pages 11 & 12)
CONTINUED
Client’s objectives need to be clear, unambiguous and achievable. SMART should be used as below:
- Specific (want to retire at age 65)
- Measurable (want a retirement income of £20,000)
- Action-related (make a lump sum contribution)
- Realistic (we can afford to make this contribution)
- Time-related (pop worth £50,000 in ten years)