How much is that website in the window, the one with the bright shiny logo


Andrew Power, partner at Deloitte, was recently on record as saying that increasing regulation and its associated cost will certainly exacerbate the trend that sees advisers dealing with wealthier and wealthier clients as they need a certain weight of assets to get an income flow”. He is also of the view that “there may also be a back-lash against regulation”.

The Financial Conduct Authority (FCA) recently told advisers in the A13 fee block (which covers most adviser firms) that they face an increase in fees for 2013/14 from £32.8m to £37.9m.

We also heard that firms regulated by the FCA would plug the Financial Services Authority (FSA)’s £107m pension deficit under the new regulatory structure.

Concern continues to mount regarding the costs of regulation upon adviser firms, most of whom are small businesses. As an industry, we are told that every effort is being made to ensure that regulatory costs are contained, that ideally budgets will be carefully considered, and that the FCA will exercise care in how it spends the money placed at its disposal by the firms it is empowered to regulate.

So, on seeing the new logo role out on the 1st April, it crossed my mind that perhaps the date was an omen for what is to come, an ‘April Fool’ but one that costs a lot.

To test that theory, we made a Freedom of Information request to the FCA asking:

“I would be most grateful if you can confirm the costs incurred to create and establish the brand identity of the FCA up to its April launch.

This should ideally relate to the creative, design and production costs. In particular we would request details of the cost of the logo design, the website design and build, the rulebook and all stationary costs to facilitate the creation and launch of the FCA in April.”

To put some contextual flesh on the bone, in the view of some well-placed industry experts, “the functionality of the FCA website seems fairly basic”. It is pretty much a re-skin of the FSA site, the rulebook has rolled over too. Some editing would be required, for example changing references from the FSA to the FCA, something that is a simple ‘Word’ function in many ways but on a large scale.

The staffing of the FCA is mostly a transfer from the FSA, the address is the same.

I am very pleased to report that the request was dealt with promptly, politely and we have now received the reply that we are sure will be of interest to the industry as a whole and small adviser firms in particular.

As a new regulatory organisation, the FCA states that it “needs to ensure that consumers, firms, markets and its staff understand its objectives as well as perceive the FCA as a new regulatory body. To this effect, we have developed a new brand identity to reflect our new objectives and how we will engage with consumers and firms differently”. The resulting logo design is clear and simple.

But should the exercise cost £1,061,423 including VAT? At nearly 3% of the 2013/14 adviser fee pot, is this money well spent?

The cost of the logo design:

“We have spent £48,000 on designing the FCA brand identity, £91,500 on developing the FCA brand guidelines, £57,000 on registering the new logo and on legal fees to resolve registration issues”. 

The website design and build:

“The cost of the new FCA website, which included its design, build, architecture, code and content changes was £723,576.81”.

The rulebook:

“We have interpreted ‘rulebook’ as the FCA’s ‘Handbook’.  The total expenditure for this work which involved the design, legal fees, development and build of the new site was £101,000”.

All Stationery costs:

“We spent £40,347.68 on the design and production of business cards, note pads and pens. It is worth noting that stocks of FSA stationery were monitored and run down and replenished with new FCA’s stationery in the lead up to 1 April to minimise costs”.

A spokesperson for the FCA commented: “Several agencies submitted quotes for the work on both the brand identity and website design and in both instances we chose the agency who offered the best value for money. All this was delivered on time and on budget.”

As Mandy Rice Davies said they “would say that wouldn’t they”?

One agency, GASP, did exactly that and said “I find a figure in excess of £700k outrageous. You can achieve a lot with that type of digital spend…the cynic in me has a good idea what has happened here.”

Marketing Director of Panacea Adviser, Sarah Paul, who has over 15 years experience working within e-business and marketing functions for several major financial services firms commented, “For a website with no apparent tools or interactivity, I find it incredible that over £700,000 would be spent on a basic rebrand”.

Simon Ryan of Social Advisers, who has considerable experience at corporate level working on rebranding projects, said “For the extent of the changes that were required for a simple refresh from the FSA to the FCA and looking at what they have delivered, I’m not convinced the FCA will be able to claim they have received value for money. The website costs would raise alarm bells for me”.

The news of this spend comes in the same month that David Geale, the FCA’s head of investment policy commented that “Forcing platforms to justify charges will reduce costs”.

He said “We are concerned that the current way that platforms are funded is opaque and makes it difficult for customers to understand how much they are paying for the platform service or to compare platforms”.

Well, Mr. Geale, I think the industry is having difficulty understanding how much they are paying to be regulated – both in the past by the FSA and now the FCA.

In the world of regulation, a spend of £1.06m is not a lot of money – yet that is precisely the problem. The old adage about the pennies looking after themselves could not be directed at a more deserving target. After all, if this figure can be spent and is, for example, 30% more than it need be, the big question posed is where else too much money is being paid.

Perhaps the Treasury Select Committee (TSC), who has been advised of this spend, should conduct an enquiry into the regulator’s processes regarding infrastructure spending and ensuring value for money by way of quality at the very best price.

The time has come to stop the seemingly profligate spending of other people’s money, consumers’ money, in fact, as they are ultimately the ones who end up paying.

Or, is it the case that as now it is only the wealthy who have easy access to paid-for financial advice, that who pays the piper and how the piper acts really does not matter?

What do you think? Add your comment here.

London woman names daughter ‘Hashtag’


When I read this I was speechless and frankly this headline taught me that you can never ever predict the strange things people will do.

There are always new ways to innovate, but was this a step too far? It was Bill Gates who said, “The Internet is becoming the town square for the global village of tomorrow”.

In the ’90’s many businesses, and especially those in financial services, didn’t see why they needed a website, or indeed email or mobile phones. Just think, where would your business be now without any one of these?

Social media is exactly the same, not everyone gets why they need it, but eventually everyone will.  The sooner you and your business adapts, the sooner you’ll start to see the results. Social media will help your business flourish in so many ways today and will be an essential tool to the success you no doubt want in the future.

Social media goes from strength to strength. According to Incite’s recent Social Media Report, consumers continue to spend more time on social networks than on any other category of site, roughly 20 percent of their total time is online via PC and interestingly 30 percent of total time online via mobile devices.

Additionally, total time spent on social media in the USA across PCs and mobile devices increased 37 percent to 121 billion minutes in July 2012, compared to 88 billion in July 2011.

The recent proliferation of mobile devices and better, faster connectivity helped fuel the continued growth of social media and in the UK some 5% of UK households now own an Internet connected smart TV.

But social media is less about technology and more about relationship building; we are starting to see more women have a heavy influence, if not dominant role in the social media space. It’s no wonder that Facebook is being run in part by Sheryl Sandberg.

The range and diversity of social networks is also on the up, social media users are rarely tied exclusively to just one social network. Indeed, the interaction between different social sites is immense. Users dart between multiple networks in order to chat to their various groups of friends and associates.

But with financial services, the desire to embrace is countered by the urge to regulate it, and regulation and the Internet are not easy bedfellows. Indeed the Internet treats censorship or control as a ‘malfunction it does not compute’ and navigates around it.

Barrack Obama said recently, the Internet didn’t get invented on its own. Government research created the Internet (a British invention) so that all the companies could make money off the Internet. The point is that when we succeed, we succeed not only because of our individual initiatives, but also because we do things together”.

So why is financial services slower than most to engage?

Well, it could be an age thing, with so many within the adviser community being 60 or more, but I think it runs deeper than that. It is a simple fear of trying to understanding how, what, where, when and importantly the “is it compliant” impact upon the ease for them to engage.

Providers are very concerned that by engaging with social media it will open the floodgates for a tsunami of negative comments that they cannot control thus creating brand damage.

People and businesses care most about what their peers think and the technology is there for information, good and bad, true or false, to be quickly shared on products and services.

Getting information off the Internet is like taking a drink from a fire hydrant on full flow.

But by engaging with that social media flow, influence can move both ways. Because you or your business do not have a presence on Twitter, LinkedIn or Facebook does not mean anything bad or negative will be said about you. By being there at least you can put the record straight and to the same audience.

Google’s Chairman Eric Schmidt said, “The Internet is the first thing that humanity has built that humanity doesn’t understand, the largest experiment in anarchy that we have ever had”.

The FSA was not too keen on the use of social media or indeed anarchy and that is because it cannot control either. The guides that came from Canary Wharf about the consumer detriment 140 characters can cause is not grasping an understanding at all of the fact that increasingly, consumers don’t search for products and services, rather services come to their attention via social media, warts and all.

The FCA seems to be adopting a more considered position, Martin Wheatley, clarified the regulator’s intentions to make better use of Twitter in an interview with the Daily Mail in the days leading up to the transfer of power from the Financial Services Authority.

The Internet is now way beyond just making money. It is about brand awareness, reputation, creation, influence, opinion seeking or forming and much more.

But not definitely not control and certainly not by regulation.

To assist in creating a better understanding within our community, we just launched our Panacea Social Stream service.

It provides a great service that gets around all the problems so many advisers have about time constraints regarding how, what, where, when and importantly the “is it compliant” impact upon the ease to engage.

It will help you to develop your business in this field, engage with you clients and get the most from social media. This resource will grow richer each month, adding to the 70,000 plus site pages with new ideas and of course opportunities.

The power of social media is that it forces necessary change, any regulator, any adviser and any consumer, should see that as a very big and positive outcome.

Countdown to Panacea Adviser’s new Social Media Services


Where would your business be today without a website, email or mobile phone?  Social media is growing in the same way as these communication methods did, not everyone gets why they need it, but eventually everyone will.  The sooner you adapt the sooner you’ll start to see the results.

The Panacea Social Stream is a subscription-based service launching on Wednesday 10th April 2013.

A service that provides your firm with compliance-approved content, active social media knowledge and strategy,

A service designed to trigger a response from clients, increase website visits and generate more selling opportunities.

Why use the Panacea Social Stream?

Financial advisers that create content for social media successfully have created better client relationships and more sales opportunities.

Social media is generally not embarked upon for the following reasons:

  • It’s too complicated – I don’t understand social media
  • I don’t know where to start
  • I have Compliance constraints
  • I don’t have the time
  • I don’t know what to write
  • I don’t have anyone to help me with this

The Panacea Social stream can overcome all of these excuses through training, education, strategy and content to enable YOU to actively engage with clients and potential clients with a regular communication stream, consistent updates and relevant news.

If you want to know more about the Panacea Social Stream as soon as it has launched, please complete your details by going to


Generation Game


In the world of social media, there is nothing more compelling than a client endorsing your brand.

Social media ‘endorsers’ are seen to give all their friends, families and colleagues trusted advice that is far more credible than any source of advertising.

In addition to promoting your business or brand, they can defend it too against any negative messaging in the countless small interactions that determine a brand’s health and eventually it’s wealth

A ‘Brucie Bonus’ is that they can also come up with some great ideas for product and service improvements, like our community members often do for us, and importantly they do it all for free as they value what you do for them.

It’s no wonder, then, that just about every forward thinking business is looking for those oh-so valuable assets- the endorsers.

Of course at the forefront of this drive for brand enhancement and enrichment are the big corporates, all designing and constructing very focused social media programs to find, activate and maintain that vital business asset, the client.

And understandably, their efforts are focused on making evangelists out of their customers, widely and expertly considered to be the most authentic and valuable brand spokespeople that only good service and positive experience can buy.

Businesses will seek to cultivate opportunity in the news media, education and other fields. But while the very big brand ‘beasts’ spend fortunes, is this really necessary or indeed possible for small businesses.

For smaller businesses, and given the impact of the brave new RDR world upon financial adviser businesses, the need to create, project and grow your brand has never been more important.

This need not cost much at all as what is often needed for smaller business brand awareness creation, especially for those businesses dealing in intellectual, intangible and sometimes considered dull service deliveries, is a spark, an idea and a low cost way of shouting about it. That is the beauty of social media today as that is exactly what it can do with a little planning and importantly at low cost.

So, engaging with your clients via what is seen to be an important medium for them today, will frequently be via Twitter, LinkedIn and Facebook.

If you look back to the heyday of direct sales in financial services, getting a new client was often achieved by way of a referral from a golf club, school, church or similar social grouping opportunity and then asking that new client to refer more friends, family and colleagues.

Social media today is simply the new, prospecting “Generation Game, but a quicker more efficient way of doing the exactly the same thing, brought up to date in fact via your website, mobile devices and social media.

While we should be aware that it is not without some challenges, widespread client and even employee endorsers are the surest, cheapest way to scale up your businesses social media reach and as a result your business.

The late Steve Jobs said, “Technology is nothing. What’s important is that you have a faith in people, that they’re basically good and smart, and if you give them tools, they’ll do wonderful things with them”.

Your clients and prospective clients can, if you can embrace them via community communication technology, do wonderful things for you and your business.

The more your ‘brand’ is looked at by way of your website, or searched for on the Internet, the higher your brand will climb on the search engine rankings.

The result being that if your business brand search results appear within your geographical location on page one or two, you are more likely to get that telephone call or e mail than your lesser ranked, un-social media engaged competitor.

Within your business remember that each employee can be the first link in a long chain of intimate, person-to-person experience shares. By increasing the number of starting points for ‘social sharing’, your business greatly improves its chances of achieving marketing success.

Although many advertisers have sought the support of highly connected “influencers” to initiate even viral marketing campaigns, research indicates that the most likely path to virality is a “big seed” strategy. In this approach, viral ideas are seeded by a large selection of first-generation endorsers and sharers, instead of a relatively small handful of highly- connected people.

Therefore although this is demonstrably successful on a large scale, it can also be successful in a scaled down way within your own smaller adviser business universe

To see how easy it is for your business to start on the brand building, business-growing journey, look no further.

Communication… communication… communication


This is a first in a series of articles from Inboxx on the basic principles of email marketing. We hope it will help IFAs to understand how they can make the most of email marketing techniques to improve and develop customer relationships. Bento is created and sent via the Inboxx platform.

It’s a mantra worth repeating over and over again. Good communications are the lifeblood of any relationship. Whether we deal with customers one-on-one or we speak to millions at a time, it’s a lesson we all need to learn (and relearn). If your relationships with your customers are good, you will do more business. It’s a fact.

Fortunately, in today’s online world, there are some simple and affordable ways you can keep in touch with your customers. All of them take some time so there is always a cost somewhere but technology has given us the wherewithal to gain control over the who, what, where and when of our communications messages.

Over the past decade email marketing has had a massive impact on communications and its power has not diminished with the advent of social media (as some have predicted). Its popularity remains mainly because email marketing works when it is handled well. Over the next few weeks Bento will include some short and easily understood articles based on tried and tested real life experience. They will help you to improve the way you communicate and drive more business so let’s get started with some vital basics…

The holy grail of email marketing

Get these three good things right and email marketing will be good for you:

1. Good data

If your data is good it will be ‘clean’ and up to date. Try to send emails to a database that is three years old and you will suffer. People change their email addresses so you’ll get lots of ‘bounces’. Have the people on your list asked to receive your emails? If you disrespect their wishes they may accuse you of spamming but a decent provider will help you with all this if you ask them.

2. Good reputation

Trust plays a massive role. Your reputation is usually invested in your brand or, on occasions, an individual. If people trust the sender of the email they are more likely to open it, read it and respond. Lack of trust does the exact opposite… especially in the financial sector.

3. Good advice

If you were active in certain retail areas, this might have been headed up as ‘good offer’ because people like real value for money and don’t like to be deceived. The same goes for the information and advice you give. People will ask… Is it worth giving up my time to read this email? Can I trust what I’m reading? Is it going to benefit me?

Do these three ‘good’ things well and email marketing will do a work for you. Do two of them well and you should be ok. Get only one right and, frankly, you’ll struggle. But the good news is that something can be done about it.

None of this is rocket science but it’s amazing how eye-opening it can be when it is put into practice. Next time we’ll open up these issues a little more.

Tom Sterling


01429 839292

Noel Coward was a charmer


For those of you familiar with the punk genre, the lyrics of Ian Dury can throw up some interesting inspiration.

Having recently attended one of the excellent Capita ‘Synaptic Modeller’ road shows, I was most impressed with the giant leaps that technology has made to assist financial advisers in doing an even better job for their clients.

The key message from Capita is that Modeller is unique in its ability to enable users to configure all the key elements in the investment planning process and define the specific criteria defined by your firm’s Investment Management Committee”.

But behind this great innovation can lurk the possibility of considerable adviser danger.

Much has been written over the years about the fact-find bedrock of  “attitude to risk”.

This focus is now in transition, morphing toward capacity for loss (CFL) and it is clear, fresh from attending this road-show, that the consumer redress possibilities that a failure to consider attitude to risk would throw up, going forward, has now very much changed to one of a “capacity for loss”.

If advisers do not chant the same CFL mantra, from what I see, it will all end in retro-regulatory interpretation tears, and, an ocean of consumer redress for advisers to drown in.

This is partly because in retro regulatory world, consumer detriment can often be attributed, increasingly and alarmingly wrongly, and with some regulatory ease to somebody’s/ anybody’s actions, errors or omissions and the result is a potential FOS/FSCS payout, all with the benefit of hindsight.

But unlike a regulator, hindsight is not a detriment metric that can be integrated into any software calculation functionality.

In a recent video interview for FTAdviser, Simon Morris from regulatory legal experts CMS Cameron McKenna, waxed lyrical about UK regulation, the lack of regulatory accountability and the ability for regulators to do what they want without needing to reference parliament for approval, or even as I have often noted, give a cursory regard to the Regulators Code.

What we are seeing in regulation today is another manifestation of  “elf and safety” madness, but in this case with no consideration attached to cost or the impact it has upon firms just trying to do a decent job, looking after their client’s best interests and earning an honest living.

This lack of regulatory accountability impacts the consumer as the higher regulatory costs of paying for failures are simply passed back to them to pay by all involved in the advice process.

In 2013, regulation is it would seem, focused on making sure that consumers never, ever, lose out.

Mr. Morris said “it would be possible for an adviser to thrive but given the challenges of the RDR and the way in which the regulators view “suitability” then the advisory community will be hit by the perfect storm of stricter interpretation of the rules, explaining adviser charging and a triple-dip recession”.

He warned, “it is either change and comply, or get a new job.”

Donald Rumsfeld could have been talking about regulation, not terrorism when he said, there are known knowns. These are things we know that we know. There are known unknowns. That is to say, there are things that we know we don’t know. But there are also unknown unknowns. There are things we don’t know we don’t know”.

In financial services regulation, the problem with technology is that it can only deal with what is known. And with advisers, as with so many other industries and professions today, in becoming more reliant on technology what do we do if it all goes “Pete Tong”?

For those of a certain age, like me, map reading was a skill developed in an age when distance location finding was depenedent upon a Michelin type map, and sometimes topped up with an Ordnance Survey micro map. I doubt if many born in more recent decades would know too much about this, relying on in car ‘SatNavs’ or combinations of Google Maps and Streetview.

All very well with an internet signal, printer and post code. But if none are available what happens. And the same questions should be asked of financial software today.

But I digress a little.

Regulation today, if it were a game, should be viewed as you, a firm, playing an online game of chess with the regulations being the board and the FSA/FCA being your opponent.

But while you move your pieces on the software ‘chequer board’, the regulator is playing on a different 3 dimensional version of the game using different software and in a different continuum of cyber space and time. The intention being not to make sure regulations are clear and easy to understand, rather to make them as complicated as possible.

A firms’ regulatory failure can then be easily based, if public outcry, regulatory face saving or political opinion warrants it, on what will see a positive outcome for the regulator, politicians and even the consumer, regardless of the advisory firm following all the rules and the advice processes to the letter.

This is because in regulatory land the existence of a consumer miss-buying, possibly hindsight induced by having changed circumstances, aims and aspirations or being wise with the benefit of that same hindsight simply does not compute.

It may be a laudable ideal but it is neither fair nor reasonable that any industry or profession should be placed in a position by which it is judged upon what it did then, based upon what it should do now with the end result creating a form “Nanny state” protecting consumers from bad decision they may have made themselves.

Consumers must absolutely be afforded protection, but this should in the technologically advanced times we live in be by way of ensuring the products and investments, exotic or vanilla, that they ‘consume’ are fit for a clearly defined and understood purpose. And that should be a regulators responsibility and definately not an advisers or a ‘manufacturer’.

Regulation of adviser firms in the way we now see has little purpose these days, if history is anything to go by.

Scandals, product failures and rip off’s happened despite all the perceived good efforts (now seen as the failures) of previous regulators such as NASDIM, FIMBRA, PIA and the FSA to prevent them. And advisers along with the consumer pay for it, not them.

Perhaps consumers would be better protected with simpler, straightforward regulation and products, and importantly a consumer financial education programme starting with basic numeracy and literacy skills in schools.

With the FCA, the scandals, scams and rip off’s will continue, they will just be a little more sophisticated, take longer to expose, will be more costly, with fewer left to pick up the tab and will be driven by technology.

In fact, rather than regulation, perhaps financial services should be nationalised, prescriptive, non innovative and slowly reactive to change. That way nobody loses out and everybody’s capacity for loss is catered for by way of possibility of loss removal. The vehicle exists, NSANDI.

Regulation has turned into one of today’s few successful growth industries. It gives it’s workers unsackable career opportunities based upon civil service lines where jobs are not lost for failure, with no need to justify it’s existence, with no responsibility toward the Parliament that gave it life or indeed anybody.

It needs huge revenue streams to create a real life bureaucratic version of ‘Mad Max’s Thunderdome’ whilst paying what many may see as inflated salaries to the army of accountants, lawyers and other regulatory jobsworths, to support generous pension schemes, to provide health and many other employee benefits all of which many consumers and advisers could only dream of.

So, as we now know from Ian Dury’s lyrics, “there ain’t half been some clever bastards”, but in our industry most of them in regulation are there with the benefit of hindsight and not vision and even with that they cannot get it right.