Legado (joinlegado.com)’s Post

Last week the FCA, ICO and TPR released their statement for ensuring data protection and effective communications to consumers in relation to retail investments and pensions. It speaks to the way investment firms and pension schemes must take action to ensure that they are connecting their customers/members with relevant information, in the right formats, at the right time, and how that information must be balanced against the marketing preferences of those consumers. This comes at a time where financial institutions are working to bring down the cost of servicing customer communications workflows, and where the legacy systems to do so are typically fragmented, complex, and costly. So how do financial institutions meet the expectations of the FCA and ICO whilst simplifiyng their communications processes and cutting down cost? They use Legado, of course. Our interactive hub lets you distribute and manage communications and document workflows with customers, at scale, with total control over which customers segments will receive specific interactions - whether it’s their marketing preference, their product types, or their vulnerability flags - all manageable within a single channel. Compliant, efficient, simple. Learn more about the ICO's statement at: https://loom.ly/Vqw-Svo

The FCA published an interim update of the Regulatory Initiatives Grid yesterday. It certainly looks like a busy Q4 2024 and Q1 2025! Between the updated regulatory grid and the portfolio letter shared last week for advisers and intermediaries, it is clear that the FCA is focused on good consumer outcomes and that it may be concerned about certain practices. Good quality advice on pensions and investments seems to be a key area, in my view. Here is why:  - In its portfolio letter, the FCA refers to ongoing work on ongoing advice services, with an update due to be published this year with findings and next steps of the review - The FCA also remains focused on retirement income advice to determine the scale of any potential customer harm and intends to provide an update on previous findings in Q1 2025.  follow up on previous findings - Later this year, the FCA intends to publish its currently-internally used Investment Advice Assessment Tool, a concept similar to the Defined Benefit and Retirement income tools previously published.  - A consultation paper on targeted support (as part of the Advice Guidance Boundary review) is likely to build on previous findings in the sector and Consumer Duty expectations (Q4 2024).  - The reviews of prudential regimes for Personal Investment Firms (Q1 2025), the MIFIDPRU definition of capital (Q1 2025), and an update from CP 23/24 on potential early requirements to hold capital for redress (Q4 2024) speak to a regulator who appears keen to ensure firms hold the adequate amount of (liquid) capital.  - The industry wide consultation paper on identifying consumer harm, and proactively conducting redress exercises is due to be published in Q1 2025; this is likely to capture financial adviser firms as well.  - The planned thematic work on how good outcomes are delivered for vulnerable customers is due to take place in Q1 2025. Definitely a lot there! If you have any questions or would like to discuss any of this, please do reach out to James Hawkins Tom Bramhill Sonia Styles Paulina Petraityte or myself. #FCA #RegulatoryInitiativesGrid #Financialadvice #retirementadvice #ongoingadvisercharges #redress #regulatorycapital #vulnerablecustomer

RMDs are likely to play an important role in your finances in retirement. Building a thoughtful retirement income plan can help you use RMDs in the most effective way, and help you reach your important financial goals. Check out Fidelity Investments RMD viewpoints below:

Oh🚨 Dear FCA, I recently noted your ‘Dear CEO’ letter to SIPP providers outlining your expectations for their operations. While this is a step forward, there’s a critical issue that needs your urgent attention: the excessive FX spreads SIPP providers are charging clients, costing individuals thousands of pounds annually. 💸 This isn’t limited to a single provider—it’s a systemic issue. From my personal experience with Interactive Investor, Hargreaves Lansdown, AJ Bell, and Charles Stanley, this practice is widespread. Here’s how it works: 📉 When buying foreign shares in a SIPP, providers apply inflated FX rates, far removed from the market. For instance, if I were to purchase £10,000 worth of Microsoft shares, and GBP/USD was trading at 1.2750/1.2751, these providers might fill the order at 1.2550. That’s a 200-pip difference, pocketing £154 directly from my pension. By contrast, FX/CFD brokers adhering to Best Execution would process the trade at the market rate (1.2750). But SIPP providers remain exempt from these rules for FX portions of share trades—creating a loophole that effectively enables daylight robbery. 😡 Under principles like #ConsumerDuty and #TreatingCustomersFairly, I would have expected this to be addressed. SIPPs represent retirement savings, the cornerstone of people’s future financial security. Most investors likely aren’t even aware of these hidden fees, which quietly erode their returns—all under the FCA’s watch. To be clear, I don’t oppose providers earning a fair profit. But these excessive FX spreads are exploitative and undermine trust in the system. This needs to stop. 🛑 💡 FCA, you have a responsibility to protect consumers and ensure fairness in financial markets. This practice runs counter to these objectives. It’s time to act. ⚖️ Close this loophole. Protect SIPP investors. Stop the exploitation. https://lnkd.in/eg_fZv-Y #Pensions #SIPPs #FXSpreads #FinancialFairness #FCA #Investing #Retirement #ConsumerProtection

There's no doubt that demand for targeted support is strong, and there's a journey providers now should embark on to ensure their data is in a fit state to provide the necessary insights, technology is in place to meet the demand and governance and brand is strong enough to support the need for trust that our clients/customers crave Altus Consulting | Robert Holford | Chris McCullam #targetedsupport #marketinsight #adviceguidanceboundary

This is a huge opportunity for banks and life companies to revolutionise the access to proper financial help for millions of underserved customers and pension scheme members.

EIOPA's Annual Work Programme for 2025: Key Priorities The European Insurance and Occupational Pensions Authority (EIOPA) has outlined a robust 3-year plan for 2025-2027, focusing on sustainable finance, digital transformation and financial stability. In this article, Marie Anderson and Chris Monks discuss the programme and the key initiatives, including: - Integrating ESG risks into frameworks for sustainable insurance and pensions. - Supporting a data-driven culture in the face of rapid digital transformation. - Enhancing supervision and harmonising cross-border services. - Updating technical standards in line with societal needs and new regulations. - Strengthening financial stability with a focus on emerging risks. https://lnkd.in/eKdtMrJP #EIOPA #SustainableFinance #DigitalTransformation

Additional guidance clarifying where communications are regulatory communications under the Consumer Duty / TPR Code, and therefore *not* direct marketing, including a helpful list of examples

The financial advice landscape has long struggled to serve the mass market, leaving many consumers in an advice gap. Those with smaller savings or less complex needs often lack access to affordable, actionable guidance while still facing critical financial decisions. The FCA's recent focus on targeted support aims to address this challenge, starting with pensions. This approach offers tailored suggestions to consumers with shared characteristics, empowering them to make smarter financial decisions. Our head of research and regulation, Robert Holford points out, targeted support could be pivotal in reaching the mass market: 📌It acts as a bridge between basic guidance and more personalised financial advice. 📌It provides millions of pension savers, especially those in auto-enrolment schemes, with much-needed support for better financial outcomes. 📌It gives financial services firms much needed tools to guide consumers to in more personalised ways to avoid foreseeable harms, helping those firms meet their Consumer Duty obligations Targeted support is an important first step on the path to building trust and delivering meaningful, individualised value. Ultimately getting people the help they need will go beyond 'people like you' approaches to delivering more highly personalised recommendations and support. With that longer-term goal in mind, the strong appetite for this innovation is clear: our research shows strong demand for targeted support. To truly start closing the advice gap, the Financial Services industry must embrace this opportunity, leveraging technology, trust, and regulatory clarity to serve a wider audience. Link to the full article published by Money Marketing in the comments below 🔗 Chris McCullam | Amira Norris | Rory Gravatt | Jonathan Warren | Jon Dean

As we see across the sector, and most recently with the Scottish Widows and Multiply announcement, the industry is moving in this direction and regulators need to enable the innovation and encourage engagement rather than stifle progress through onerous rule book changes.