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FCA’s Proposals around Portable Fact Finds

09/10/17

The FCA has recently published guidance around its decision for clients to bring their fact finds from previous advisers to outline the foundations for new advice. David Boyhan, Associate Director at TCC comments on his views around portable fact finds.

The guidance outlined that a consumers personal information could be stored in line with data protection rules and with the clients permission, known as porting. Firms will need to have appropriate measures in place that ensure the accuracy of data before it is utilised. Once firms have acquired the necessary information, they are able to use this information for the suitability assessment. However, it is the firm’s responsibility to ensure the information it obtains is up-to-date and accurate.

The regulator previously raised concerns around portable fact-finds in terms of the qualitative information gained such as the client’s level of knowledge. David Boyhan, TCC’s Associate Director expressed his concern around the risks portable fact-finds may bring to advisers. He states firms must ensure the information firms provide must be as up-to-date and accurate as possible, as a way of mitigating the associated risks, including the risk of providing unsuitable advice. Firms may choose to conduct due diligence on the firm the complete the original fact find, or could repeat the key details on the suitability report during conversations with their client in order to verify them. David believes the gains associated with portable fact finds could be small due to the time required to mitigate the potential risks involved.

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