The idea of decision trees without full advice, for products dispensed by unqualified individuals, could prove unworkable in today's complaints culture. Without full record keeping, there is no background information on which to justify advice.
The main concern is that advice and the long-standing principle of suitability appear to be sidelined. While consumer education is a nice idea, in practice, the recommendations in the Sandler report overestimate the public's ability and desire to understand financial products.
Advisory & Brokerage Services
We welcome simplified stakeholder products if they increase consumer choice. But the thought that these products can be purchased safely without regulated advice should be viewed with some cynicism. The most successful stakeholder pensions are those that have been installed with advice.
It is well-written in comparison with CP121 but the payment system it is proposing will not benefit consumers. We are concerned that Sandler is saying it is OK to sell simple products through unqualified advisers.
Momentum Financial Services
Providing simple products will not address the critical issue of motivating the consumer to invest. Sandler has missed an opportunity by not incentivising the employer to encourage a saving culture.