You are cordially (but professionally) invited (well actually, you’ll have to pay for half of it) to attend our forthcoming conference on tax planning (and please, Steve, extinguish any previous association you may have with the word ‘conference’. This is, I assure you, nothing of the sort).
”To elaborate (and by this we mean provide extra hard facts, rather than anything more extravagant) on the previous bracketed explanation, we can confirm that any idle pleasure you may have enjoyed at previous events (tut tut, Steve, did the clients benefit from your titillation?) will have no place at this strictly business affair.
“If you would like to attend, we have enclosed a client benefit consideration form for you to complete to ensure that nothing, save the client’s best interests, is at the heart of this decision. Before returning this form to us, Steve, please remember that you will only be cheating the client and, ultimately, yourself if a full disclosure of your motivations is not provided. We won’t be angry; more disappointed. There is, though, no legislating for how your regulator may respond as at this stage they prefer to not offer any more clarity on the matter.
“You will be required to present a signed copy of this document at the door on the morning of the event where our head of fun police will take this, and your general countenance (dark attire and solemn mood are recommended), into consideration before permitting your entrance. Note that trousers that are unduly tapered may be taken as a sign of your intent to carry excessive swagger into the proceedings, which may, in turn, divert the focus of others in the room from our raison d’etre – better client outcomes.”
Some party! Welcome to the new world.
Many want more specific examples of acceptable practice for things such as training, hospitality and gifts, all of which the regulator stopped short of giving in its paper on inducements. But the FCA says it will not issue further guidance.
The problem that this throws up is that when offering or accepting any invitation, all parties need to evaluate any conflict of interest. Without greater clarity and with the spectre of being judged retrospectively to have transgressed, it is safer to stay away. And many are.
Will this help create better outcomes? I don’t know – but it will certainly make the world a slightly duller place.
Phil Wickenden is founder of So Here’s The Plan – firstname.lastname@example.org and @PhilWickenden