All change (again) for disclosure requirements

The Financial Conduct Authority have published a further policy statement - this time about removing ineffective disclosure requirements.

Policy Statement 16/23 sets out the planned changes which take affect from 1st February 2017.

The FCA will allow Firms to continue to use the Combinded Initial Disclosure format - but the use of the Key Facts logo will have to be removed. The FCA have confirmed that "old stock" may be used up.

The objective of these further changes is to enable consumers to be able to make an informed decision about the services that they are subscribing to.

Within Annex C of the Policy Statement the FCA have also made a change to the Consultancy Charging and remuneration requirements.  From 27 March 2017 Firms will need to take reasonable steps to ensure that its repesentatives, when making contact with an employee with a view to giving a personal recommendation on his/her employer's group personal pension / stakeholder scheme inform the employee that :

The Firm will be providing a personal recommendation on the GPP / Group Stakeholder scheme provided to the employer

Whether the employee will be provided with a personal recommendation that is restricted to the GPP / Group Stakeholder scheme provided by the employer ir the recommendation will also cover other products

That the employee will have to pay an adviser charge (if applicable) unless the employer is paying the consultancy charge / fee


Compliant Solutions Limited - experts in helping Financial Services Businesses deal with the business challenges of Financial Conduct Authority Compliance - for help contact ian@compliantsolutions.co.uk