FAMR – a familiar response

Pension specialist Fiona Tait takes a look at the Financial Advice Market Review and assesses the three areas where it suggests improvements can be made

With significant budget changes ruled out (for a while anyway), the pension community briefly turned its attention to the FCA’s final report on its Financial Advice Market Review (FAMR), hoping for something that would transform the savings market.

It hasn’t quite delivered that – there is too much of the usual “should consider” and “continue to work on” to give any hope of immediate action – but it does acknowledge, first, that financial advice is a lifelong process, and second, that we need to do more to make it accessible to those with less wealth.

For advisers and employers who look after retiring members these changes, if implemented, should make it easier to support them with the increasingly difficult financial decisions that they face.

The report highlights three areas in which improvements can be made and I will consider the key recommendations in each.

Make advice more affordable

If we want to make financial advice more affordable to more people, we need to reduce the costs of delivering it. Most people simply cannot understand why financial advice is so expensive, not realising just how much work goes into delivering it. According to the report, the typical initial advice process takes nine hours of an adviser’s time to deliver, partly because advisers usually consider every aspect of a client’s financial life before making a recommendation

Recommendation 2 – clarifying the definition of advice

Once a recommendation is made and the client follows it, the liability for any consequences lies with the adviser. If an adviser or an employer simply offers information or guidance, the liability for any subsequent action is with the consumer. However, there are very valid concerns that consumers do not realise this. Focusing on whether a “personal recommendation” has been included should make it easier for consumers and regulators to identify who carries the responsibility.

If the consumer makes their own decisions, it would reduce both the financial liability and the amount of work the adviser needs to do.

Recommendation 4 – make it easier to offer streamlined advice

Recommendation 8 – simplify the production of suitability reports

The recent pension freedoms have also led to a demand for more specific services. For example, an individual approaching retirement may wish for help in selecting the best way to take their pension benefits but not want or need help with other aspects of their finances. Reducing the scope of advice would obviously reduce the nine hours considerably.

Care must be taken to ensure consumers are clear about which areas of their finances are covered and which are not, which should be possible via a simplified suitability report with, for example, a checklist of areas discussed.

Recommendation 9 – develop automated advice models

Much of the work carried out by advisers involves analysis and projections. Technology will never replace the personal touch but it can make light work of the maths, making it quicker and easier to deliver, and it provides a valuable record of the work undertaken.

Make advice more accessible

Even if the cost of advice is reduced, many individuals may still need help in paying for it. The report includes two key suggestions on how this might be done.

Recommendation 13 – improve incentives for employers to pay for financial advice

Recommendation 14 – allow savers to use part of their pension fund to pay for advice

Both of these suggestions require changes to the way in which employee benefits are taxed. In the first instance, the Treasury has confirmed an increase in the exemption under benefit-in-kind for financial advice, from £140 to £500; and in the second it has confirmed a new exemption to protect any funds withdrawn specifically to pay for advice.

Reduce the cost of regulation for advisers in certain circumstances

The Financial Services Compensation Scheme (FSCS) provides valuable protection for consumers who have been missold or misled over their investments. The scheme is funded, not unreasonably, by the financial services industry. However, there are concerns that the current method of allocating costs is unfair.

Recommendation 20 – explore risk-based levies which reward good financial practice

Many well-run adviser firms that receive few or no customer complaints feel that it is unfair that they bear the costs of firms whose clients are less happy, particularly if their firm is recommending less risky investments, which have a lower chance of going wrong. By relating the levy to the type of advice and investments offered and the complaints experience of the firm, it should be possible for the better firms to flourish and to offer less expensive services.


This is by no means a comprehensive list of the proposed changes. As mentioned, there are 28 recommendations, all of which are aimed at making financial advice available to more people.

Those sectors of the market that are already well served by wealth managers and advisers who concentrate on high-net-worth clients will be largely unaffected. But it is to be hoped that these changes could make financial advice more accessible, and more familiar, to all.