Prod in the right direction
Playing still more with this concept, if we think about the new Prod (Product Intervention and Product Governance Sourcebook, available on the FCA website) rules – you should check out section 3.3 particularly – then we find that advisers have a whole new set of responsibilities in terms of defining the target market for products and services and ensuring suitability by that market segment. Which is to say, it’s increasingly hard to say that platform XYZ can be suitable for both your clients with straightforward needs and those with more complex needs.
As an aside, Prod is a big deal, and not enough advisers are paying attention to it yet.
A lot of things that have previously just been guidance or guidelines are now rules, and that means if you don’t get them baked into your own processes you may end up on the wrong side of the compliance Feds, and none of us needs that in our lives.
So put constantly increasing capabilities from the bigger back-office guys next to rapidly changing regulation, and the opening out of custody and trading solutions in terms of their ability to integrate with other systems, and what you might get is the start of something quite interesting. I have a feeling that it’s this sort of market shift Invesco quite likes the sound of being exposed to. Either that, or it’s really into Gabriel returns.
Life companies had it their own way for more than 100 years. Platforms came along and changed all that in less than two decades.
What if we’re seeing here the first really big moves in what might disrupt platforms in the next five or 10 years?
Whatever the future looks like, it won’t look like it does today, and that’s hugely exciting for both advisers and their clients.
Mark Polson is principal of platform and specialist consultancy the Lang Cat
