CHALLENGE
- Our client, a large life, investments and pension provider, engaged Huntswood as a strategic partner for its new advisory and investment management joint venture: a “new to market” restricted advice proposition.
- We were tasked with the delivery of a full suite of compliance services to support, enable and empower the new advice proposition.
- Importantly, we were required to work in collaboration to design an approach that considered the interests of all parties (the provider, the technology partner and prospective member firms) in equal part. We were required to develop a new advice proposition, undertake member firm due diligence and support firms’ technology point of view.
ACTION
- During our engagement, we worked closely with all parties to develop a bespoke solution that supported the provider with subject matter expertise and empowered the member firms with proposition documentation and guidance. We also provided regulatory insight to the technology partner to maximise the efficiency of the new advice system whilst ensuring it delivered against regulatory expectations.
- Working with our client’s project team, we spent the majority of our time in a “build phase” where we developed the proposition advice documentation that would be used to sell the new proposition and the control environment that would be needed to ensure member firms were compliant with regulatory expectations.
- In collaboration with our client, we engaged each prospective member firm at the earliest opportunity. Our engagement involved building a working relationship; carrying out appropriate due diligence at each firm; giving face-to-face feedback with a supporting formal report; providing support as the firms transitioned across to the new proposition; and providing training on the new advice documentation and the regulatory side of the system.
- Whilst being experts in technology, the partner firm responsible for the build of the system required support to understand how the advice platform they were creating could be tailored to ensure robust reporting was available and regulatory expectations were met.
- It was important that the system did not interfere with the member firms’ jobs. To do this we: led workshops with the technology partner and provider to align regulatory requirements within the system build; provided interpretation and explanation on the advice documentation that would be available in the system; and provided on-going regulatory guidance.
RESULT
- Our engagement resulted in the successful delivery of the “new to market” restricted advice proposition with regulatory compliance at its core, which delivered both efficiency and risk management improvements to our client.
- As part of the proposition, member firms had the support of an advice platform with embedded advice documents, help text, state of the art fact finds and a dynamic training and competence scheme that facilitated online and real time risk-based first and second line assurance.
- We also produced ‘New Best Advice Guidelines’ for our client’s reference.
- Member firms reported an increase in customer confidence due to the partnership with Huntswood as we acted as a compliance partner who were able to offer independent assurance.