Download pptx - ( Suitability )

(Suitability)The Paradigm Board Game®

Interactive SessionLets play a new game!

Lets split up ……………..

(Suitability)The Paradigm Board

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Learning Objectives• How file review outcomes can be risk rated• What remedial actions can be set for file omissions/ errors• What follow up action should be set for file review

omissions/ errors• What evidence should be placed on file to show omissions/

errors and any training needs or remedial action has been completed


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Game Instructions• You will be given 3 boards and game tiles on which to play• You will have a few moments to place these cards in the

correct order in the “zones” as shown below• Paradigm will walk you through the model answers before

moving on to the next “zone”

• Please do not remove any of the cards or boards from the session, thanks


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Your Final Board…Suitable


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Red ZoneThe illustration is dated before the earliest dates shown on the fact find and client agreement

Anti Money Laundering: the file states the required documents were seen: but the documents are not evidenced on file

The suitability report details the adviser fee as 3% of the investment amount

Your Final Board…Unclear


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Red ZoneIt was not clear from the research why this provider has been recommended

Affordability not demonstrated

Remuneration taken higher than agreed with no explanation

The SR does not compare a cost comparison between the ceding and new products for replacement business.

Your Final Board…Unsuitable


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Red ZoneAn Occupational Pension Transfer has been completed by an adviser who does not have the required qualification to do so.

As a result of advice, the client has lost a guaranteed annuity rate of 9%, which the file indicates as being a valuable option for the client.

As a result of advice to surrender a bond, the client has incurred an income tax liability of £2,000. The SR confirms to the client that there will be no tax liability if the bond is surrendered.



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Purple ZoneA file note should be added to clarify the reason for this

The documented evidence should be obtained and placed onto file or the relevant details recorded such as the passport number and expiry date

The suitability report should detail the fee amount in cash terms and confirm whether this is to be facilitated to the provider or paid directly by the client. The amount and method of payment of the adviser charge should be included in an addendum letter to the client.



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Purple ZoneA file note needs to be placed onto the file to clarify the reason for selecting this provider

Any missing sections in the FF need to be completed in full / extensive file notes to be placed on file to cover this area

A file note needs to be placed onto the file to clarify the reason for this and an addendum letter sent to the client to explain this

An addendum letter should be issued to the client to provide a cost comparison and if the costs have increased explain why the recommendation is suitable

Your Final Board…Unsuitable


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Purple ZoneThe case needs to be checked by a competent person, to determine if advice can be evidenced as suitable. If suitable, a TVAS should be completed and the advice should be reconfirmed to client by a competent person. If the advice is subsequently deemed to be unsuitable, redress will need to be calculated. PI insurers should be informed here redress is required for the client.

Contact the client to gain their understanding of the interview and the advice they have received. Where client detriment is evidenced, redress will need to be calculated. PI insurers should be informed where redress is required for the client.

Where client detriment is identified as a result of advice given, the regulator would expect the firm make good the amount identified. PI insurers should be informed here redress is required for the client.



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Green Zone The adviser should continue at current level of supervision but reminded of the need to evidence the correct chronological document order

The adviser should continue at current level of supervision but a documented reminder of the importance of recording details of the evidence of identity on file.

The suitability report or report template should be updated to ensure that the fee amount is confirmed in cash terms.



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Green ZoneThe supervisor should ascertain if this is a one off occurrence or systemic, a one off occurrence would require no further action

The supervisor should ascertain if this is a one off occurrence or systemic, a one off occurrence would require no further action



Your Final Board…Unsuitable(Suitability)The Paradigm Board

Game ®Green Zone

1+2 A back review of all pension cases needs to be undertaken to ascertain if this is a one off or systemic breach. Any further cases highlighted will also need to be checked for suitability of advice.

1+2 100% file check on all pension cases until clear evidence that this error is not recurring. Formal retraining of adviser requires supervision by a competent person. Paradigm Pension transfer guide would be a possible source of training material. Paradigm also suggests that if this is a system breach, the FCA should be notified. If this is a one off case, the firms should update its breach register. The firm should notify the FCA of the breach if more cases are uncovered, and contact PI insurers to notify them.

3. A back review of all investment fund switching cases needs to be undertaken to ascertain if this is a one off or systemic breach. These cases will need to be assessed to see if any client detriment has occurred. PI insurers should be informed where redress is required for the client.



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Blue Zone The supervisor should monitor the next 5/10 files. Where there are any further dating issues a file note should be added and any additional training noted in the adviser T&C file.

The superviser should monitor the next 5/10 files. Where further AML evidence is missing the adviser should be retrained in the completion of this task, by a competent person. 100% file monitoring until this standard has been consistently met.

A company mandate should be issued to all staff to inform them of the changes to the suitability report.



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Blue Zone If systemic, 100% file checks to monitor this until the standard is consistently being met.

If systemic, Paradigm suggests the use of observed interviews, to uncover why the adviser is having issues with this area of the advice process. This could be done by observation, role-play or QA assessments (see chapter 7 of Compliance Manual).

If systemic, 100% file checks to monitor this until the standard is consistently being met.

If systemic, the adviser needs to be retrained in fee and proposition disclosure. CPD records will show learning outcomes/ future files should demonstrate that the correct process has been followed

Your Final Board…Unsuitable(Suitability)The Paradigm Board

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Blue Zone Written notification to adviser that a FCA breach has occurred and details have been placed in the breach register. Documented evidence that all previous cases have been checked with the results of the check. Future cases monitored to ensure no further breaches occur. Details of all remedial action placed onto the individual files. CPD records will reflect learning outcomes.

The adviser must undertake retraining; Paradigm has material that may be suitable in the appendices of Chapter 3A of the Compliance Manual (File review checklists, FCA template for Pension switching). CPD records will reflect learning outcomes.

The adviser must undertake retraining; Paradigm has material that may be suitable in the appendices of Chapter 3A of the Compliance Manual (File review checklists, FCA template for Pension switching). CPD records will reflect learning outcomes.

Keep Your Boards intact….(Suitability)The Paradigm Board

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Supervision Evidence• Paradigm provides a suite of Supervisor material in Chapter 4

• Quick walk through how this may look……..


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Available For Download• Copies of the final boards• Copies of the 121 documents

• Available now from website Member Events… Best Practice Spring 2014


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Summary Learning Objectives• How file review outcomes can be risk rated• What remedial actions can be set for file omissions/ errors• What follow up action should be set for file review

omissions/ errors• What evidence should be placed on file to show omissions/

errors and any training needs or remedial action has been completed


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Thank You• Please put the tiles in the envelopes, and keep them on the

table with the boards, thanks

• Please stay for a bite to eat

• Please complete your feedback sheets and leave them on your table

• Have a safe journey home


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