Since our initial launch, we’ve grown to support many clients. In light of the latest guidance and policy statement PS20/6 we are planning to record new videos with the same content and structure but with some slight tweaks to incorporate the changes to bring a new and fresher look to the recordings.
What changes have we made?
Some of the changes are planned for later in the year but in the meantime we have removed reference to our Cashflow Calculator and your clients can no longer use this to generate their own cashflow figures.
We have removed this as providing cash flow analysis as part of the Triage process (and before full advice) is contrary to the new FCA guidance on triage, which states that this must be a generic and impartial educational service.
Triage guidance set out in PS18/20 states:
“The purpose of triage is to give the customer sufficient information about safeguarded and flexible benefits to enable them to decide whether to take advice on the transfer or conversion of their pension benefits.”
“We consider that triage should be educational and provide generic, balanced information on the advantages and disadvantages of a pension transfer. If an adviser makes a reference about how a client’s personal circumstances may influence advice to transfer, then it is likely that they are providing advice”
The key issue is that cash flow is not generic information, it relates specifically to the customer’s circumstances and therefore could mistakenly be interpreted as advice. The FCA reiterates this guidance in PS20/6 (2.51), reminding firms that impartiality is paramount in this process in order that the ‘advice boundary’ is not crossed.To ensure the flow of videos is not interrupted and to maintain the client experience we have added a holding message to the Cashflow module.
