Investments  

Do CIPs promote consumer duty compliance?

This article is part of
Guide to centralised investment propositions

Fee transparency can also provide detailed breakdowns of all associated costs, ensuring clients are fully informed about fees.

Performance monitoring of a fund’s performance data and analysis also helps to keep clients' portfolios aligned with their goals.

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Regulatory updates on how changes are impacting investment strategies and compliance requirements can also assist with compliance. 

Darren Mead, director of risk at Progeny, says platforms can also help advisers in assessing the funds’ value. 

He says: “Platforms typically offer a number of benefits for clients, including the ability to see the value of an overall portfolio, via consolidated performance and up-to-date valuations, and can support the reduction in overall administration for clients by having multiple investment wrappers in one place.  

“Associated fund and platform charges are visible, creating greater transparency, and platforms may also offer family linking discounts, which can be beneficial in terms of fair value for clients engaging in intergenerational wealth planning.

“Under the consumer duty the FCA expects advisers to consider a wider range of factors in their platform due diligence, including whether the overall cost to the consumer provides fair value, and proactively considering the foreseeable harms of using a particular platform.”

CIPs can provide economies of scale, which in turn can reduce the cost of investment management, assisting with the price and value outcome, notes Barry Strathearn, chief compliance officer at One Four Nine Group.

He adds: “CIPs can play a vital role in helping financial planners comply with the consumer duty regulations by promoting fair value and suitability in their investment advice.

"They provide a range of investment solutions that are tailored to varying risk profiles of clients and are aligned with the client's financial goals by the planner, which can help firms demonstrate consideration of the product and services outcome.

"By integrating a CIP into their business, planners can better meet regulatory requirements and avoid foreseeable harm, further enhancing overall client experience, which enables clients to pursue their financial objectives."

However, Chris Fisher, chief executive officer of Multrees Investor Services, raises questions on whether platforms should support compliance to consumer duty.

He says: “The key here is who owns the consumer relationship, or how far should a platform be going to prove consumer duty compliance? In theory, if a platform can offer volume-based pricing for CIP products, and these pricing benefits are being fed through to the consumer, then the platform can evidence compliance.

"Whether or not the CIP provider can offer volume-based pricing for what in effect is its own IP could be debatable.”