Over the last four weeks we have been running a snapshot poll on RDR readiness. Over 600 have responded and so far only some 21% of respondents say they will be ready
This is currently showing that very few advisers will be ready by the year-end. With only 52 days left, what are the problems that are causing this very sad picture to be revealed?
We will be doing a more in-depth survey in the next week or so that I hope will provide a more granular insight into the problems and hopeful assist in delivering some support solutions to “those in peril on the sea” of change.
Lee Werral from CEI Compliance has some thoughts that are worth sharing with you right now. He observed that;
“The results are hardly surprising. RDR readiness is a very generalised and overused term that can mean many things to many people. One argument I have heard recently is that many firms are unprepared, as they have only had 6 years notice, whilst the counter has been that many rules for the ultimate landscape have only been laid down in the last 12 – 18 months.
So is the question being asked meaning that there will be full competence for 1/1/13; or maybe that IFAs expect to have their systems and controls in place by that time, or have they fully prepared their client base for the change and got their disclosure and proposition documentation in place?
Or all of these?
There is still time to engage a qualified someone to look at the whole setup within each firm to assist them to be RDR ready and to provide an external assessment of the readiness with recommendations and “sleeves rolled up” assistance if it is needed.
With the firms we have worked with, preparing them for “RDR Readiness”, other than competence, we have identified a number of areas that need to considered and discussed including;
- Business Vision and Mission Statement
- Business Plan
- Target Market
- Industry Analysis:
- Client Segmentation
- Marketing & Sales
- Your Service Description
- Mistakes to Avoid
- Operational Plan
- Financial Crime Systems & Controls
- Data Security
- Combating bribery and corruption
- Investment Process
- Focus on risk and return – profiling
- Growing and Recruitment
- Compliance & Risk
- TCF Processes MI Governance
- Management Team
- Joint Ventures (JV) Appointed Representatives – The Firm’s Responsibilities
- Exit Strategy
- End Game Planning
So if the question is are all these things in place or documented, the responses are unlikely to be yes, as many of these areas have not been fully explored. As far as being technically ready by all the competence and operational requirements to satisfy the FSA, then I am sure the great majority will be yes, (but will be more ready in the next few months).