The Productive Cycle: How to design the elements of a Non-Intermediating Financial Planning process

There are four important elements in the non-intermediating financial planning process that when completed in the right order improve the outcome for the client. These are:

Goals: Multi-dimensional goal setting.

Actions: The project plan to achieve the goals.

Means: The lifetime cash flow forecast and ‘what if’ analysis to make good shortfalls and financial education on D2C solutions.

Execution: Personal coaching programme to encourage implementation and review.

The Productive Cycle: The GAME Plan.

The complete process in the correct order is Goals, Actions, Means, Execution.

This sets inspiring goals for the client in every area of their life, creates a project plan, plans the client before planning the money, puts in place the financial architecture to support the goals, includes wealth creation strategies in the ‘what if’ scenarios to plug shortfalls, educates on DIY wealth management solutions and provides personal coaching to support plan execution.

The outcome is a solid plan to achieve inspiring life goals. The client is likely to find the plan inspiring and productive.

The Exhaustive Cycle: Living within your means

The reverse cycle looks at the money first, uses knowledge to optimise wealth management solutions, then looks at the life the client can afford to live without outliving their capital.

The outcome is a plan to achieve uninspiring financial goals, likely to exclude things that money can’t buy. Like friendships, love, respect, faith, honour. It risks locking the client into the treadmill of work existence for the best part of 50 years on the bet they can buy their happiness in the last sixteen years. The client is likely to find the plan uninspiring and exhausting.

The Destructive Cycle: Treating the money as the client

Just looking at one element, say Means. Missing out the life plan. This is the approach a traditional financial intermediary transforming to a non-intermediating financial planner typically takes: The lifetime cash flow forecast and ‘what if’ analysis to make good shortfalls and financial education on D2C solutions.

The outcome is a plan to plug gaps in a shortfall analysis based on product.

The client is asked to pay highest premiums from ‘disposable’ income to D2C platforms to make good shortfalls in preservation, accumulation, crystallisation, decumulation and succession.

The goals are set instinctively by the planner, not the client. And, when someone else sets the goals, guess what’s in it for the client. Not much! The objective is to maximise financial wealth, and ignores wealth in other areas of the client’s life. The client is left poor, all they have is money. This is not deliberate, it is just the way the adviser has been trained.

This is the ‘asset hoovering’ approach taught by conflicted product providers and their agents for decades. Hand over your life savings to the industry to hold on to and milk for as long as possible.  This is the robo-advice model, the non-advised sale. The client is likely to find the plan destructive and leading to a lifetime of regret.

The top five regrets of the dying according to the book by palliative care nurse Bronnie Ware are: I lived my life as others expected me to live rather than true to myself, I worked too hard, I didn’t keep in touch with friends, I failed to speak my truth, I didn’t allow myself to be happy. Where are these needs addressed in the above methods?

Which process would your clients value most?

Contact us today to find out how the Academy of Life Planning can help you transition from Financial Intermediary to Non-Intermediating Financial Planning firm.

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Stand and deliver won’t work.

How should you plan a client when non-intermediating financial planning?

When you set up a non-intermediating financial planning firm. There’s not enough value in the ‘traditional’ financial planning process to justify the sale when you remove product advice.


  1. Contract
  2. Factfind
  3. Needs analysis
  4. Recommendation
  5. Implementation
  6. Review

It just leaves needs analysis.

Modelling accumulation, preservation, crystallisation, decumulation and succession.

The hand your money over plan. Hand your money to providers, and they hang on to it for as long as possible before handing it back. “Stand and deliver,” from the highway robbers.

And this stand and deliver planning, fails to justify the fee as clients see it for what it is.

Highway robbery.

Contemporary financial planning is about planning the client before planning the money. Planning goals in every area of the client’s life, not just financial. But intellectually, materially, emotionally, and spiritually. Including things money can’t buy. Like friendships, love, respect, faith, honour.

With proper financial planning we answer the question, “what’s your life purpose?”

The answer is to use gifts and talents in the service of others.

We ask the question; “how do you create wealth?” For no “hand over your money to us” product creates wealth. The client creates wealth.

The answer is, turn your purpose into a vocation. Include “the business plan of you” in the financial plan. This creates wealth.

Traditional financial planners must learn to:

  1. Plan goals in every area of the client’s life.
  2. Include things that money can’t buy. Like friendship, love, respect, faith, honour.
  3. Establish the client’s life purpose.
  4. Turn the purpose into a vocation.
  5. Produce a “business plan of you” to create wealth.

The focus is wealth creation. Not wealth management. And wealth in every area of the client’s life.

When the business plan is done properly, it turns a lifestyle business into an equity business and generates a lifetime of income, plus a valuable asset.

When you do financial planning properly, fully, in the contemporary way, the “hand over your money to us” products become superfluous. As the business plan of you makes good those shortfalls.

You treat the client as the customer, not their money.

When you do this with friendship, love, respect, faith, honour, the client runs their own money.

The “I’ll hang on to my money thank you” method. Intermediation becomes unnecessary. Product advice is removed and not missed.

The resulting financial plan has enormous value. Value that the client appreciates and will pay for. You justify the fee.

If you are a traditional financial planner looking at setting up a non-intermediating financial planning firm, first become a contemporary financial planner.

Contact us today to find out how the Academy of Life Planning can help you transition from Financial Intermediary to Non-Intermediating Financial Planning firm.

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The Non-Intermediating Financial Planning Firm

The GAME Plan Generator

Do you want to create a sustainable and profitable business by doing more of what you love, and less of what you hate about the job?

Do you want to earn while you sleep and create a great work-life balance with ‘nocturnal’ income for life?

Where are you now?

Maybe, you are an IFA who has reached capacity on the 121-planning side and wants to set up a scalable NIFP side-line on the QT to future-proof the business and income you proudly built up over the years.

Perhaps, your network cannot handle invoiced fees and have got you all tied up legally as they seek to ‘hoover’ your assets onto their platform, and you feel trapped, worried, and responsible for your clients.

Potentially, you see yourself as a professional financial planner rather than a product salesperson; and want to learn contemporary planning skills that clients would value and pay for that are broader than just product.

Possibly, it has dawned on you that investment solutions are commoditised and no matter what you do in-house, after fees you cannot beat market returns. Prospects are looking to run their own money, and you cannot see how you will get paid.

Maybe, you are being bullied by the network, compliance or PII insurers and your authorisation is at risk or has been limited, all the fun has gone out the door, and all the available cash is not far behind.

Perhaps, you have left or are leaving the industry, feeling forced out by circumstances beyond your control and you’re going to miss the best part of the job you love, helping people, your calling, your vocation.

Where would you like to be?

What if, you could take a proven ‘business-in-a-box’ for your NIFP firm and be up and running on the QT in no time at all, with no licensing or trademarks to worry about?

Here, you are a valued champion and impartial expert for your clients, on their side with no conflicts of interest, hidden agendas or perverse regulations getting in the way.

Imagine this, you keep what you earn with no other bosses taking their percentage, no high fees for intolerable regulators, and ridiculously low PII premium renewal quotes that make you smile.

Picture this, preparing a client report is fun and easy, completed in a fraction of the time, getting powerful, life changing, yet simple, easily understood, relevant plans across to your clients.

Imagine you’ve no tedious pointless returns to complete for regulators, auditors or networks that would otherwise eat up your time and drain your energy.

What if continuous professional development was about learning genuinely useful planning skills; rather than having to sit through countless, pointless and boring presentations about impractical regulations or from providers trying to sell you something?

Here, your business is scalable. Not just 1-to-many. But None-to-many. You exchange know-how for money, not your time. Your time is your own. Because your know-how is unlimited the upside is unlimited. The scalable lifetime ‘nocturnal’ income and freedom enables you to earn while you sleep and live the life you love without outliving your capital.

What if, you had wisdom, security, freedom, and a legacy, delivering these same qualities to your clients?

If that’s where you are, and this is where you’d like to be, then I’m sure you will agree that you need an adviser support network and a system, vehicle, or solution, to get you from here to there. Well, that is the Academy of Life Planning and The GAME Plan GeneratorTM.

Why is running a NIFP Firm important?

  1. The regulated financial adviser market has been contracting for decades, and the outlook for firms and adviser numbers looks set to continue in decline. Driven by obsessive regulation, restrictions to working practices, onerous reporting, time-consuming red-tape, hikes in regulatory fees, raised barriers to market entry, and hardening PII premiums.
  2. The ever-increasing cost of running a regulated IFA firm, combined with the limited capacity of delivering a 121 service, has forced the market to concentrate on ultra HNW. Leaving the mass-affluent disintermediated and underserved. With the advice gap leading to increasing wealth inequality in society. A gap that NIFP has the potential to fill.
  3. Product is commoditised. Product advisers can no longer deliver better outcomes for clients through research, recommendation, and maintenance, after costs, when compared to buy-and-forget passive retail-multi-asset funds; as accessible direct and as easy as on-line banking. The value add is now in the non-regulated planning, not the regulated product selection.
  4. A regulated firm is a lability taken to the grave. With NIFP there is no liability because there is no recommended product. There can be no malpractice, malfeasance, or miss-conduct by the mischievous minority when there is no product. There is no need for FCA registration & authorisation, FOS, and FSCS disappears. These labels are not benefiting clients when all you sell are plans. The risk of client detriment of getting a plan wrong are miniscule according to insurers, when compared to intermediaries.
  5. There is a need to mitigate the legal risk to your regulated business. The FCA has flagged issues with conflicted payments, such as asset-based fees for ongoing services they judge as unnecessary. A policy decision could impact your regulated firm ongoing revenues and business valuation multiples, overnight. You may be left with debt. You may not have the window of opportunity, or there might be restrictive covenants in place, when you later seek to migrate clients to a fee-for-service financial planning model.

Why now?

The FCA flagged the issue of conflicted payments in the Policy Statement PS20/6 in June 2020. Further decisions can be expected in the FCA’s Assessing Suitability Review 2 paper due early 2021.

Why AoLP?

In 2005, AoLP founder Steve Conley, as the Business Development Director of Berkeley Independent Advisers in Coventry, sold the UK’s fourth largest IFA network to Tenet Group, when regulators threatened to remove the licence for the business, with interruption to the authorisations of its twelve-hundred members, on the grounds of long past mistakes.

He learnt what it is like to be on the receiving end of threats of closure by the regulator and the need to act quickly to save the livelihood of advisers.

In 2012, the FCA completed the Retail Distribution Review. The resulting ban on commission and raising the regulatory bar on standards for financial intermediaries, led the banks to conclude that the regulated financial adviser market was a zero-sum game.

The regulator once again threatened the livelihood of advisers with their intervention. All banks laid off all their bancassurance advisers.

Steve was Head of Investments at HSBC at the time, and had successfully trained, piloted, tested, and proved the NIFP model. The banks were not interested, as ROI for the allocation of shareholder capital was deemed higher by raising levels of unsecured debt for naïve consumers.

Steve disagreed with the conclusions and ethics of the banks and left the banks to prove his point by championing the consumer.

Since then Steve has been an award-winning campaigner for improved market integrity; has run AoLP successfully as a NIFP firm creating wealth, accolade and happiness for many satisfied clients; has authored an Amazon bestseller on NIFP; presented 1-to-many on NIFP at events globally; and trained advisers to run Times best 250 nominated FP firms.

AoLP broadened its remit in 2020 in response to the deepening global life and money emergency, to offer an adviser support network to aspiring NIFP practitioners to spread the good work.

AoLP is the world’s first NIFP adviser support network. It is a work in progress, but many high-profile advisers have already seen the light and joined the ranks; the network is fast-growing and as NIFP crosses borders has gone global.

What makes us different?

When financial planning there are four key areas to address, in the right order.

GOALS: Set goals in every area of your life, not just financial goals.

ACTIONS: Build a project plan to achieve your goals, just like you would in business.

MEANS: Model the wealth you need to create and manage to achieve your goals throughout your lifetime. Create ‘What If’ scenarios to identify solutions to shortfalls. Note products do not create wealth. People do. So, you need to add a 3-year business plan for the ‘business of you’ into the Financial Plan.

EXECUTION: Provide a personal coaching service on-line.

For this AoLP has developed the unique system, The GAME Plan GeneratorTM

Contact us today to find out how the Academy of Life Planning can help you transition from Financial Intermediary to Non-Intermediating Financial Planning firm.

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What Happened Down Under

The Financial Planning Professional: Part 6 of 6

An account of an Australian financial adviser following the fee-for-no-service scandal.

I bought this business from the investment firm with a promise that if I were ever forced to sell, it would be on the same terms. Well now that promise has been broken and I’m facing ruin.

I don’t think there’s words that are strong enough.

To be sold something on one basis, and then to have that basis completely eroded by this much is reprehensible, in my opinion.

I bought clients from the investment firm several years ago, but it is now terminating me.

In effect, it means the investment firm can buy books back now for significantly less than what they sold it to us for.

In the paperwork that’s been put in front of me that I haven’t yet signed, if I don’t paint the investment firm in a glowing light they can remove all options that are currently available to me and essentially throw me on the street.

I feel like a complete failure and that I have let my family down, I am anxious and fearful for the future.

I have contemplated whether my life insurance is the better option for my family, for me. I have now had my will prepared so the investment firm can’t get a single dollar … I tell you this because I believe I’m not the only one thinking like this.

The investment firm is robbing us.

I’m not saying this lightly — a lot of people are on the edge of suicide.

I’m being thrown under the bus by them in response to their wrongdoing.

They offered us counselling.

They said they were worried about us, particularly our mental health.

They refer three or four of us a day to counselling support services.

Some of us have been advisers for a long time and have no other career options.

Some have been doing this for 30 or 40 years and this has been their life, and suddenly we have lost our business.

We are not sure if we are going to walk away with a loan. We are worried about our clients.

When we ask them whether they will forgive loans or ensure none of us will be left with a debt, they turn around and say, “We have a range of support measures available to practices.”

They said the changes to its buy-back program reflect “the significant economic changes that have occurred across the industry, including legislative change that will cease grandfathered commission, and other market disruptions.”

They say they had given us some choice about how we want to proceed.

“We wrote to a group of investment advisers indicating we did not believe their practice was viable and giving them a number of options to discuss with us, including their standard buy-out terms, an accelerated buy-out offer [expected to be within a timeframe of five-six months of electing this option] and merging with another practice.”

They said if we made no election by the deadline, our status as an authorised representative of the investment firm would end 180 days after the date of our letter.

There’s no doubt about it, the investment firm is in survival mode and I daresay they have decided that small, one-man practices like me do not now fit into their business model.

Even when I think I’m coping, I’m not.

I’m not making good decisions; I can’t think straight.

I’m so worried about my marriage, losing my home, how this will affect my family.

The counsellor called me. Said I’m not alone, there are people I can talk to and there are others in the same boat.

I think the investment firm has really tried to divide and conquer with what they are doing.

The termination letter from the investment firm gave us a short deadline to accept very unfair exit terms.

The terms vary, but generally we can either sell our business back to the investment firm for half of what we paid, despite what has previously been guaranteed full price by the them, or convince another investment adviser, who the investment firm wants to keep, to buy the business and take us on as an investment adviser.

The investment firm lent me hundreds of thousands of pounds to buy the business.

I will be left with substantial debts because of the investment firm forcing me out.

The deadline is less than three weeks away and I still don’t know how much the investment firm will pay for my business, still no answer on whether they will forgive any of the debt, or whether special consideration will be given if I am a genuine retiree.

If I fail to decide by the deadline, the investment firm may cancel my licence and take back my clients, with any loans remaining payable to them.

I am under significant stress knowing that by the deadline I will have no business, an unserviceable debt of about $400,000, and a five-year office lease I cannot get out of. And, I doubt I will be able to find another job given the state of the investment advice industry.

If you were to ask me, ‘Are you OK?’, the answer is no. Not anymore. And, neither is my wife. And neither is my family.

The investment firm has confidentiality clauses in its termination letters, which I fear will leave me with nothing if I speak out.

In the past, the investment firm encouraged us to take out loans to buy our businesses.

Many have loans that are bigger than what the investment firm has said it will now pay for those businesses.

So, by the deadline when the investment firm shuts them down, they will potentially all be left like me, with no income and a large loan.

The counsellors are inundated with calls from us all fearing for our futures.

People’s homes are definitely on the line. We know that many have got loans maybe several hundred thousand dollars, and the only way they are going to get it cleared is to sell their house.

But you’d like to think that the investment firm will do the right thing and make sure that doesn’t happen.

Until very recently, the investment firm was still encouraging investment advisers to take on extra debt to buy more clients and grow their business.

It’s not something they stopped doing three or four years ago; they were still encouraging people to borrow money, and probably still are encouraging people to borrow money.

I looked at applying to sell my business back to the investment firm before all this started, a process that normally takes 12 to 18 months.

When I applied, the investment firm was paying four times, but I have been told by my case worker that the investment firm will not hold to that agreement, and I will be paid about two-and-a-half-times my business’s annual income.

Instead of receiving about $500,000 for selling my business back to the investment firm, I will walk away with a sizeable loan, which I took out to buy the business in the first place.

They are using institutional power to walk all over the small guy … I don’t have the financial power to win court cases. And it’s scary.

I can join the other advisers and vote to pursue a class action.

I didn’t want to be aligned with the firm anymore as I watched the company implode in scandal after scandal.

I lost faith in whether they could provide what they needed to stay the same trustworthy company they once were.

Even where an investment adviser has been in the industry for many years and bought his book of clients from the investment firm “back when it was a respectable, good brand, with a good reputation”.

He may have worked hard in his community and brought many new clients to the business and serviced them on a fixed fee basis.

I’ve worked so hard to build the business and we don’t live rich; we get by on around $6,000 a month including the mortgage.

As I don’t have any employees, in our case it will just be me that loses his job, however the effect on our family is actually quite devastating.

Many people have little sympathy for us given what came out in the review, but the bad eggs were not the people the investment firm is getting rid of.

They are terminating those who don’t sell enough product, who don’t make enough money for them.

The smaller investment advisers like me that just charge for advice for clients who are not super rich, do a good job — that’s who the investment firm is terminating. I have never had one complaint or investigation into me.

I’m preparing to sell the family home and I’ve already pulled my children out of day care, meaning my parents have had to help.

My wife has been looking for work, but only found it in regional towns well away from the family.

The termination has left me in significant debt, a debt the investment firm says it will pursue.

I tried to contact the investment firm board to make sure it is aware of what is happening, but I’ve had no response.

I’m incredibly worried, incredibly worried about the investment advisers I’m speaking to.

The regulator said they were aware of the situation.

They said, “It appears that a lot of investment advisers have had unfair treatment related to contracts with the investment firm. This is a major issue and something that we are very keen to look into.”

“Those with concerns should get in contact with us, and this can be done anonymously.”

In a statement the investment firm said: “We care deeply about the welfare of our investment advisers and their families and have offered them a range of support options including counselling.”

This just seems all so wrong.

Contact us today to find out how the Academy of Life Planning can help you transition from Financial Intermediary to Non-Intermediating Financial Planning firm.

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Changing from Directly Authorised to Appointed Representative

The Financial Planning Professional: Part 5 of 6

Time to Reconsider Your Options

Lockdown has given financial planning firms the time to reconsider if their business needs to be repositioned, and all firms should be looking from time-to-time at whether they should be directly authorised or with a network. Or if they are with a network if they are with the right one.

Here is one consideration to add into the mix. The direction of travel for financial planning. What impact does the “incomplete transformation” from product sellers to professional financial planners have on the future for you and your firm?

So, before you cosy up to a large network as many are doing just now, ones that are increasingly looking like vertically integrated firms, let us stop and think for a moment about what life will be like for the professional financial planning firm if a wall was to be placed between advice and product.

The direction of travel follows the continued demand from consumers for the separation of advice from product to improve market integrity – with the conflicted payments debate – countered by the continued lobbying of the investment industry, and more recently networks, to continue permissions for vertically integrated firms.

The investment industry has fought genuine customer-focused reform at every step of the way over many years. Regulators specifically rule out splitting advice from product sales, saying the costs do not outweigh the benefits. Read, successful lobbying of parliamentarians in the corridors of power.

It is a move that would not be cheap, but not separating advice and sales has already cost the public billions of pounds.

Who will win, investment firm bosses or consumers?

The answer to that question will significantly impact your financial future, depending on the choices you now make. The decision is really quite simple. You need to choose whether you want to be a product seller or a professional financial planner.

Joining a Network or Investment Firm

The big investment firms employ investment advisers with the express aim of selling their investment products. Similarly, the big networks now own big inhouse investment platforms. These days, independence does not mean truly independent advice; and there is little to distinguish between a vertically integrated firm and a large network with their own platform.

It is challenging being a professional financial planner with such a firm. They are also very unlikely to allow you to set up a separate non-intermediating financial planning firm.

Some large networks do not allow fee-for-service pricing, and insist on asset-based pricing.

Which means, even putting advice to one side, customers cannot be sure they are being recommended the best product.

Why? An investment firm does not want its investment advisers selling another investment firm’s products, and vice-versa.

Since the Covid-19 outbreak began, many more directly authorised advisers are committing to networks and not just “window shopping”. The increase occurred during the recent months of lockdown when many firms would have been reassessing their business and financial standing. 

What networks have seen is the interest from the directly authorised space, it is probably a catalyst for firms both financially and from all the added value that good networks can bring.

Part of the driver will be financial because obviously professional indemnity insurance and regulatory costs have hit firms heavily and particularly directly authorised firms.

An investment firm or network will support all member firms through these difficult times and a lot of the network’s smaller firms with less turnover you would expect would benefit most.

But that is not always the case.

While we were stressed and anxious about lockdown, one of the UK’s largest networks decided to send hundreds of its appointed representatives, the smaller firms with less turnover, threatening letters about personal development programme irregularities.

They even threatened those having undertaken thousands of hours of CPD studying for CII exams with suspension, saying there was a failure to communicate or paperwork was not up to date.

They even threatened to notify the FCA to permanently blot the copybook for the adviser.

Advisers want to make a living, enjoy work again, without bullying, fear, and blame. What impact do you think this corporate action had on the mental health of its members in these times?

If you are making the change from DA to network, you need to be ready for this.

Lessons from abroad

A former Australian investment adviser has described the investment firm giant they worked for as a “dictatorship”, claiming he was pressured to sell in-house products, including to a client who would have been left thousands of pounds a year worse off.

The incentives the investment firm offered him to join its network made him feel like, “a corporate slut; a bitch to somebody’s command”.

“A puppet would be the best way to describe it,” he said.

In a network you will formally review your performance with your line manager and discuss ways to improve and develop. Of course, you and your line manager will have regular chats about how you are doing throughout the year.

“Somebody above me was always going to pull my strings and I was too naive to realise it, or I was too blinded by the incentives”.

The investment firm began to pressure him to favour in-house products over others in the market.

He said each time his business reviewed a client or had a new client he would send a recommendation about the type of products they needed to the investment firm’s head office.

“Every time it came back, regardless of what I had put as an investment adviser, the product at the end of the advice or the structure was the in-house product.”

“The real issue in my opinion was the fact that they were trying to get my existing book of business over to their particular products and services.”

This “didn’t sit well with me, because being in the independent market space, I already knew that there were alternative options available, and as an adviser I was utilising those alternatives”.

He said the final straw was when he recommended a long-standing client set up a self-invested pension.

He says the investment firm’s managers pressured him into selling the client an in-house pension product, which, in the investment adviser’s view, would have left the client thousands of pounds a year worse off.

When the investment adviser argued against doing so, he says the investment firm pushed back and told him in a meeting, “I will be using the in-house product, because it is in the client’s best interest”.

“Now, best-interest duties for advisers are quite simple. Whose interest is it in? This particular case it was in the best of interest of the investment firm,” the investment adviser said.

He said he resigned as an investment adviser with the investment firm over the matter.

What would happen if the consumers won?

In the face of there being a wall placed between advice and product, say in the form of FCAs Assessing Suitability 2 due early 2021, vertically integrated firms might opt for a brutal restructure of their financial planning division. That’s what happened in Australia.

If that were to happen, maybe as much as a third of member firms may be sent a shock letter informing them they would be axed within a few months.

Smaller firms with less turnover.

Where advisers bought their firms, the investment firm might also cut by almost half the amount that it would pay investment advisers to buy back their business.

The investment firm may have had an agreement with investment advisers that it would buy and sell at a generous multiple of the annual earnings of each business but may now tell them, given the changes to the world of investments, it will only pay a lower multiple of the earnings of businesses.

“Some of them, they’ve been doing this for 30 or 40 years and this has been their life, and suddenly they’ve lost their business.”

“They’re not sure if they’re going to walk away with a loan. They’re worried about their clients.”

So ask yourself, do you want to sell products or be a professional financial planner?

Contact us today to find out how the Academy of Life Planning can help you transition from Financial Intermediary to Non-Intermediating Financial Planning firm.

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Most IFAs are Fee For No Service

The Financial Planning Professional: Part 4 of 6

A study published yesterday in the Telegraph found that most financial advisers are “fee for no service”, in other words con men.

A fee for no service is the failure to deliver ongoing advice services to financial advice clients who were charged fees for those services.

The financial advice industry has stolen big-time from its customers for years in the form of “fees for no service”, which some countries discovered when investigated even includes the accounts of dead people.

That’s the problem with the asset-based fee model. Whilst it keeps most firms afloat, if a fee is taken a service must be delivered in any trade or profession. When in most cases it is not, the firm risks having to face huge compensation claims.

In other countries it’s a national scandal. Here in the UK apparently not.

Australia’s major banks and insurance companies are now facing a $1.15 billion compensation bill to repay victims of their fee-for-no-service scandal, and the size of the bill is still growing. The scandal stretches back to 2008 at least, and hundreds of thousands of customers have fallen victim.

That’s not happening here in the UK.

The Financial Conduct Authority, the UK regulator, has known about fee for no service for years and does absolutely nothing about it … some might say because of conflicted interests in corridors of power and lobbyist legislation.

As Money Marketing explained in 2016: “The question of what is appropriate to charge for advice may be one for the FCA, but the UK regulator has previously stated it does not want to intervene in policing advice costs.

The FCA even admitted their failing last month, when they said:

“Over time, these charges can have a significant negative financial impact for consumers.” (PS20/6 s3.1).

“Our view is that many consumers would not benefit from ongoing advice as their circumstances are unlikely to change significantly from year to year.” (PS20/6 s 3.10).

The investment industry has successfully fought genuine customer-focused reform at every step of the way over many years. And, here in fee for no service we see yet another example.

Even when we see it in our national newspapers, no one calls it out.

See yesterday’s article in the Telegraph – 18th July 2020:

“Financial advisers charge clients thousands of pounds annually – but don’t see them for years.”

“More than half (53pc) of 1,000 people who have between £50,000 and £1m invested with a financial adviser had not had a face-to-face meeting with them for two years or more, according to Bancroft Wealth, the wealth manager that conducted the study.”

“They paid on average 1.5pc a year in fees, or £2,835 based on the average portfolio size of £188,948.”

“Bancroft’s Keir Ashman said: Some were paying £7,500 a year and we’ve even come across clients in the past paying over £30,000 a year.”

Well it is illegal.

And if you took the fee for no service adviser to court, you would get your money back.

An adviser should refund to each client the fees paid for the service they did not receive. Each client should also receive interest, reflecting the lost investment returns on the fees that were inappropriately charged.

In other countries the regulator intervenes in policing advice costs, and this compensation calculation is automatic. For example, the Australian Securities and Investments Commission.

But Brits don’t bother.

Because firms lobby the regulator. The regulator doesn’t police fees.

The Brits like and trust their advisers. Have done for years. And, Brits won’t hear a bad word said about those they trust. As one telegraph reader put it:

“My IFA is more expensive than average based on this article, but good performance and always available, has been IFA for me for +15 years and my parents before that. Trust is imperative in this relationship and remember always that it’s ‘your’ money so ultimately your responsibility.”

Good performance! That adviser probably didn’t beat market returns. As many don’t.

If you want to read more about the senselessness of good performance claims by IFAs take a look at the evidence.

Truth is, as another Telegraph reader put it yesterday:

“If you are daft enough go for: Active fund fees. DFM fees. Adviser Fees. Platform fees. Trading fees. Bid offer charges. FX fees. Auto fix fees. 50% of the population is financially illiterate and includes high earners.”

Some fee for no service advisers do not think they are doing anything wrong.

They say, “The adviser can provide ongoing service out of the goodness of their heart.”

“Did you think yourself that taking money to which there was no entitlement raised a question for criminal law?” you might ask.

“Dishonesty would go to the intent and I don’t feel it was dishonest in that respect,” would be the reply.

Your conclusion, “Charging for what you do not do is dishonest. No-one needs legal advice to tell them that. The root cause for what happened was greed; the greed of advisers.”

See for yourself what Telegraph readers had to say about it.

“Maybe there is a market for financial advisors to the rich and stupid but in my experience these advisors offer virtually nothing and charge a fortune for it.   All the advice you need is free on the internet.  Advisors offer no magical door to better products or decisions.  All they want is to plug into your assets and charge a fee.”

“The capacity of people to be taken in by con men never ceases to amaze me. Why pay such people fees to invest in what pays them commission rather than invest yourself after a modicum of research into a wider range of products?”

“If they are so wonderful, why don’t they keep their secrets and make themselves a fortune. No, it is easier to make money out of poor advice, which in the end is on a guess and really only a gamble. It’s easy to spend someone else’s money.”

“It would be worth the fees if they knew which shares were going to go up and down. But they do not; nobody does. I do it myself and buy ETFs with fees like 0.03%.”

“What ‘financial advisers’ never mention is luck.  And you need a lot of that, ‘expert’ or not. What amazes me is that punters continue to pay someone to lose their money.  Remarkable. The real money is in taking a 50-year view and sticking with it.  That is what charities and some wealthy families will do.  Churning is much loved by experts, but it rarely pays in the long term.”

Financial advice will not be a profession until the conflicts that pervaded the industry are addressed.

Eliminate conflicted payments from your firm. Avoid the liability. Make payments fair. Charge fees for service.

Making financial advice a profession is important not merely for its own sake, it is a necessary step to protect those who seek financial advice.

Contact us today to find out how the Academy of Life Planning can help you transition from Financial Intermediary to Non-Intermediating Financial Planning firm.

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Fee for service advisers are more trusted

Business strategy planning as a concept

The Financial Planning Professional: Part 3 of 6

The good news is, the 2019 Edelman Trust Barometer: Financial Services report indicates that trust in the financial sector is at its highest level since Edleman started measuring it in 2012.

But at 57 percent trust among the general population, financial services providers and distributors remain the least-trusted sector measured by the Trust Barometer.

Investment advisers affiliated to investment firms, no-matter how tenuous the connection, in general, take pole position as society’s pariahs. When it comes to trusted financial planners, that is a combination about as toxic as you can get.

If the Australian market is anything to go by, many investment advisers in the UK aligned with an investment firm, by either “asset-based” fee affiliation or vertical integration, may face a private hell in the months that lie ahead.

We need to explore the “asset-based” structural flaws to better understand how in Australia these flaws and ensuing price wars prompted investment firms to force hundreds of their own investment advisers out of business, with many advisers at risk of losing their homes as firms slashed the amount they were willing to pay for buying out businesses.

The most obvious flaw is the conflicted payments of “asset-based fees”, raised in the UK as an issue by the FCA in PS20/06 as recently as June 2020, which could be explored further under their Assessing Suitability Review 2, early 2021.

Conflicted payments require an investment sale — such as contingent adviser charges, and so-called “asset-based fees”, which are commissions by another name.

The choice between interest and duty is resolved, more often than not, in favour of self-interest.

The less obvious, yet more fundamental flaw, is the actual service delivered by most financial planners. In contemporary financial planning, a financial product is rarely the solution to a client’s problem. So, if all you have to offer is product, your service will more often than not fail.

You see, the thing about a product is, that no product in the world creates wealth. It is the client that creates wealth. The product simply manages wealth.

Let me demonstrate this with reference to business planning. Have you ever seen a business plan where the business was to give its capital away to another business to look after and then see it returned many years later with profit added? A shell investment company perhaps? The truth is, most businesses utilise working capital to follow a purpose, serve people, care for the planet and create profit through daily industry. Why should personal financial planning be any different?

I produced countless business plans in the banks for market-leading propositions. The time horizons seldom went beyond five years. The 5-year plan. The 3-year plan. Which coincidently is a time horizon in which no investment adviser works, but almost all their clients would want to see positive life change happen within.

Contemporary financial planning is about including a short-term plan for ‘the business of you’ in the lifetime cash flow forecast to make good shortfalls.

Once the business plan is embedded, the best planners will help the client navigate themselves out of their business. What I mean by this is a business often begins as a lifestyle business, where the business owner is exchanging time for money. Time is limited, so is the business. By productising services with the introduction of books and courses, say, the business owners begin to exchange their knowhow for money and creates what is referred to as nocturnal income.

Equity based businesses achieve higher valuation multiples than lifestyle business.

Creating significant earnings while you sleep is a great retirement plan. Better than any pension product. What I call it, is your path to financial freedom.

Are you including plans for the ‘business of you’ in your financial planning service?

Many clients would benefit from ongoing service of a plan for the ‘business of you’, for which an ongoing fee can be straightforwardly levied under a fee for service arrangement. Whereas for a financial product that is often not the case. The FCA’s view is that many consumers would not benefit from ongoing (product) advice as their circumstances are unlikely to change significantly from year to year (PS20/6 s3.10). For this read – yearly opt-in.

In Australia, the regulator challenged suitability of product advice and whether the firm had acted in the best interest of their clients. They banned conflicted remuneration, such as asset-based fees for unregulated or no activity, and introduced yearly opt-in.

Customers had been charged for investment advice they never received. Such as, customers who did not receive an annual financial check-up that they paid for. Even for customers who had died, fees were taken. Advisers thought mistakenly that there was no legal obligation to provide any ongoing service.

There was nowhere to hide.

“Just a few bad apples”, the industry had constantly told everyone as scandal after scandal was revealed, and people’s financial futures were ruined.

The regulator showed that up for what it is — a bald-faced lie.

Those at the top knew exactly what is going on.

“A culture in which conscious decisions were made to protect the profitability of the investment firm and put the interests of shareholders first, at the expense both of the interests of clients and of complying with the law”.

‘The root cause is greed’

The conflict-riven, asset-based model has lost its social licence to operate.

The investment industry has fought genuine customer-focused reform at every step of the way over many years.

It’s now lost control of its future.

Adviser charges on investments go to the heart of all that remains wrong with the investment advice industry.

If you are ready to launch a non-intermediating financial planning firm, then join us.

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The Great Journey

You sit facing the direction of the compass point as you meditate. It is useful if you do this as you complete the GAME Plan stages for that direction.


1.       The Path of Wisdom: This is about accessing the innate supportive knowledge which is in all things. This path is one of acceptance and silence, for true wisdom is not proclaimed by its finder but cherished and contemplated. Explore this pathway when you are in ignorance and darkness.

Contemplative Pathway: (North/ Winter/ Earth):

You arrive at an island whereon is a feasting hall: within is the head of Bran the Blessed, the great noble lord of the Raven. Any who may wish may enter here and listen to him recounting story after story, for he is a great source of traditional wisdom. Sit down before him and listen to his tales; these may supply the help or direction you seek. If Bran ceases to speak, other ancestors may take up the story you need to hear.

2.       The Path of Inspiration: When stale and lacking in desire, explore this pathway to re-discover and re-kindle your inner light of passion and inspiration.

Contemplative Pathway: (N.E./ Use taste and smell):

Come to the cave wherein is Ceridwen (keridwen), the goddess of the Cauldron.  The lunar goddess. White dress. Barley coloured hair. If you ask for a draught from the vessel, beware, you will never be the same again. She may ask you to serve her in some way in return for this privilege. Drink and follow the images, shapeshifting if necessary to keep up with them.

3.       The Path of Purpose: Find your direction and life purpose. This is about new beginnings, hopes and entering into things for the first time. This is essentially the path of child who views everything with a fresh perspective. Explore the pathway when you need to find your way, at the beginning of your journey.

.Contemplative Pathway: (East/ Springtime/ Air):

You arrive at an island where there is a castle; within is Olwen, Lady of Flowers, sitting in her garden. She is young and beautiful, and understands about the nature and restrictions and the need for freedom. Ask for her advice. She rises. Follow her. In every footprint she leaves a three-petalled flower. See where she leads you. Remember your journey and return.


4.       The Path of Strength: This is about building confidence and beauty. This is self-awareness and skilful use of talents. Strength is often confused with aggression because we experience very few strong people in the world. This is the pathway of warrior, who acts as a guardian and defender of freedoms. Follow the sense of feeling, knowing the true balance of the body with the spirit. Explore this pathway when you feel weak or disempowered. This is the pathway of overcoming obstacles.

Contemplative practice: (S.E./ Use feeling and touch.):

You find a dip in the hills and nestling between it is the entrance to a forge where Gofannon the blacksmith is working. He is powerful. A stockily built man wearing a leather apron over his clothes. Go within and ask for help. He will make a weapon, a piece of armour or amulet that will give you strength in return for your work in his smithy. Listen to his advice for he is a man of strength.

5.       The Path of Transition: This is about accessing your power and purpose. It is very much the path of applying your potential gifts and about the discovery of self-knowledge. This is the pathway of the young adult who steps over the threshold on a quest to find the meaning and purpose of life. Explore this pathway when you need to learn a new skill, when to find an effective means of practice, or when you are facing difficult opponents.

Contemplative practice: (South/ Summer/ Fire):

You travel on the ocean to an island whereon is Scathach, the warrior-woman who trains potential heroes and heroines. She will challenge you to come ashore and you may wrestle with her and find yourself swiftly on the ground. Get up and ask her help in training. She has the ability to teach you the salmon-leap, to pass over difficulties with agility and skill, by crossing a narrow bridge that lies before you. When you are proficient you can follow her over the bridge to another part of your training.


6.       The Path of Insight: This is concerned with balance and the ability to make connections and find deeper knowledge; to be receptive and open; the gifts of maturity. This is the pathway of the ruler who balances the realm with insight and compassion. The ruler follows the intuitive sense of hearing so as not to miss the promptings which emulate from Mother Earth. Explore this path when you need balance, insight or healing; let it lead your mind to the heart of love.

Contemplative practice: (S.W/ Use hearing to guide you):

You walk to the sea front; there take a ship until you come to the entrance to the undersea realm of Manannan, god of the sea. Go beneath the waves with ease and come to his hall. Ask for his help: he will set you to search under the sea for the pearl which will bring you back into balance once again. The pearl is tuned to a certain note which you may distinguish as a chant or call. Listen to its wisdom and become attuned once more.

7.       The Path of Understanding: This is about assimilation, fulfilment and desire. It is the path of the mature adult who seeks to live responsibly and brings healing, to find enlightenment and to become more deeply human. Explore this pathway when you need to understand how best to act when problems become overwhelming, where peace is needed, where desires are out of control.

Contemplative practice: (West/ Autumn/ Water):

You come to an island full of apple orchards where you encounter Morgen, the queen of Avalon. She is a guardian and healer. She will invite you to listen to the birds singing at twilight and you may rest in the orchard, taking a healing sleep. Remember the images of your dream and use them to solve your problem. Morgen will interpret your dream if you ask her.


8.       The Path of Cleansing: This is about self-clarification and true sight. The other name for the pathway is the ‘first death’, and it often serves as an important part in the development of the apprentice, cleansing and purifying whenever necessary. This act of reprocessing has to occur in all spiritual experience and it marks the end of one cycle and the beginning of another. This is the pathway of the traveller who follows intuition to perceive the heart of all things. Explore this pathway when truth and justice are needed, or when you require purification to undertake a particular kind of work.

Contemplative practice: (N.E. / use sight to guide you):

You descend into the Cauldron of Rebirth: place whatever part of you that needs treatment into it, and see what bobs up from the cauldron in its place. This may appear in symbolic form. Take it forth and place it upon your body, allowing the symbol to pass within you.

Building the Wall Between Advice and Product

The Financial Planning Professional: Part 2 of 6

Non-Intermediating Financial Planning is financial planning that does not involve a product recommendation. In the UK, such financial planning is not a regulated activity and product advice is regulated by the Financial Conduct Authority (FCA’s PERG 8.26.2). Traditional financial planning ties financial advice to the making of a product recommendation. Contemporary financial advice goes much further. It covers a wide variety of topics, such as lifetime cashflow forecasting, tax planning, life planning, residential property portfolio planning, and wealth creation through business planning.

I found when I was a financial adviser who did sell products using a proper financial planning process, that the outcome was seldom a product. When you plan the client before planning the money, there was usually a wealth shortfall. No financial product in the world creates wealth. Wealth is created by the client, and what they needed was a plan.

Products manage wealth. And, if financial advisers are honest they must admit, none of us can manage wealth better than the default arrangements now available. I was head of investments for the world’s largest bank, so I should know.

With investment products commoditised through the introduction of passive retail multi-asset propositions such as Vanguard’s Life Strategy funds being offered on D2C Platforms, and the widespread availability of Workplace Pension Schemes (WPS), the FCA’s recent recommendation that default schemes such as WPS be considered when making product recommendations may render product advice superfluous, further regulation amendments are expected in FCA’s Assessing Suitability Review two, due early 2021.

“Our rules require firms to demonstrate why any non-WPS they recommend is more suitable than a WPS” – FCA’s PS20/06.8.35 (June 2020).

Most product advisers charge asset-based fees which creates: conflicts between the adviser’s interests and those of a client; a strong monetary incentive to recommend one course of action over another; and over time, these charges can have a significant negative financial impact for consumers.

A conflict of interest exists when there is a clash between professional responsibilities and personal (often material) interests. There is a large body of evidence that documents how conflicts of interest play a substantial role in influencing advisers’ attitudes and decision making. Such conflicts can lead advisers to give biased advice. Professor Sunita Sah, Cornell University outlines some of the literature in this report and describe how conflicts of interest can lead to biased opinions, often with the conflicted adviser being unaware of the influence.

To better understand the arguments for change and the potential impacts on the UK industry we may see in the year ahead, we need only look at the Australian market today following the reforms emerging last year from heavy and unexpected criticism at the Hayne royal commission.

Central Queensland University academic Angelique McInnes, who completed her doctoral thesis on conflicts of interest in financial advice, has said the “link between the adviser to an entity or licensee that has a separate profit motive” is the issue from which all of the industry’s woes have stemmed.

As one Australian financial adviser put it: “A puppet would be the best way to describe it.”

“Somebody above me was always going to pull my strings and I was too naive to realise it, or I was too blinded by the incentives”.

In June 2020, The Financial Planning Association of Australia recommended several significant reforms that aim to streamline regulation of the financial planning profession. Advancing the profession is the spirit of the policy framework, which includes the separation of product and advice.

“The regulation of financial advice is currently tied to the recommendation of a financial product, reflecting a history in which a product recommendation was the core component of most financial advice. In a professionalised financial planning sector, this is no longer the case,” Financial Planning Association CEO Dante De Gori said.

“Contemporary financial planning is about a lot more than recommending financial products. There is a wide variety of topics that might be covered by financial advice and many may not include a product recommendation. Regulation of financial advice should reflect the variety of advice that can be provided, and not continue to be tied to financial product recommendations,” he said.

The FPA believes existing requirements to deliver financial advice should be reviewed to ensure they apply effectively to financial advice that does not include a product recommendation.

“Future regulation of financial advice should focus on the broad nature of contemporary financial advice and not limit its focus to financial products,” Mr De Gori said.

“The law should be changed to separate the regulation of financial products from the regulation of financial advice.

The post Major overhaul of AFSL system required to reflect new era of professionalism in financial planning appeared first on The Financial Planning Association of Australia.

In the UK, financial planning is not a regulated activity, although it can become a regulated activity when it is provided in the preparation for or in the process of a regulated activity. For example, a financial plan prepared with a view to intermediate for the buying or selling of investments is a regulated activity, and the financial planning fee may be deducted from a regulated product.

If, however, a member of a WPS asked an investment adviser for advice on carry forward, using tax allowances, and contribution levels to pensions, this service can be non-regulated financial planning. The outcome is likely to be a top up to the default arrangement. The financial adviser is unable to deduct the fee from the default arrangement or a regulated product.

This causes firms who operate on “asset-based” fees to not know how they are to be paid, and that challenge is growing, given these default arrangements are available to every employee in the UK.

One solution is for pure (non-intermediating) financial planning to become a separate service payable by invoice. Either as a separate trading style or a separate company.

Financial intermediaries can currently facilitate deduction of regulated financial planning fees from products, where the financial plans are completed in preparation for investment advice. Nine times out of ten such fees are “asset-based”, and here lies the problem.

If you are ready to launch a non-intermediating financial planning firm, then join us.

Contact us today to find out how the Academy of Life Planning can help you transition from Investment Firm (Regulated) to Non-Intermediating Financial Planning firm (non-regulated).

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Contemporary financial planning is about a lot more than recommending financial products

The Financial Planning Professional: Part 1 of 6

The financial intermediary sector emerged mainly out of commission-based life insurance sales from the last century. Judging from continual unfavourable conclusions from industry consultations at home and abroad, even now advisers are still in the “incomplete transformation” from salespeople to professionals. Advisers are still more the selling agents of one or more investment firms rather than professionals.

An ‘Independent Financial Adviser’ (IFA) is a financial intermediary, a selling agent for a sufficient range of relevant products available on the market and is rarely a fee-for-service agent of the client. The norm throughout much of the financial advice industry is the so-called “asset-based fees” (a percentage of your investments).

Asset-based fees are simply commissions by another name, and the regulators say they influence the advice that clients receive.

Asking an investment adviser who charges asset-based fees: “What if the best advice you can give a client is to pay off their house?” The IFA would not know how to get paid. In other words, the IFA must sell you a financial product and get hold of your money so he can take a cut of it.

An IFA who charges asset-based fees is no more “independent” of this sufficient range of investment providers, than any other investment adviser affiliated to a restricted range of investment firms. Independence is only assured when you have no affiliations with product providers, and you are not paid by the amount of product sold.

A fee-for-service adviser is a buying agent of the client and an asset-based adviser is a selling agent of one or more investment firms.

Salesperson or adviser? And whose best interest is he working for?

Investment advisers reading this will rightly claim that they are bound by the “best interest” duty in the Conduct of Business Sourcebook. But how low is that bar?

And, according to the UK regulator, the Financial Conduct Authority (FCA), most firms operate under asset-based fees, which the regulator recently described as a remuneration arrangement that creates conflicts between the adviser’s interests and those of a client (PS20/6 s1.12).

Initial and ongoing asset-based fees create a conflict of interest, as an investment adviser may have a strong monetary incentive to recommend one course of action over another (PS20/6 s3.1). In other words, the regulator admits that there is a strong incentive to place earnings ahead of clients for most advisers in the UK.

The strategy where earnings are placed ahead of clients is known as ‘Asset Hoovering’. The way it works is this, asset-based advisers create an in-house investment proposition of model investment portfolios run on a platform and take ongoing fees for investment advice and portfolio management services. The fees are typically between 0.5% and 0.75%, and in two-in-five cases at 1%, per annum or more. In so doing, the investment adviser becomes affiliated with their own in-house investment firm, much in the same way as the restricted vertically integrated firm they so readily disparage.

The investment adviser affiliated to the investment firm then advises clients to cancel existing investments. The clients are sold similar replacement investments of the affiliated investment firm or portfolio of firms. The investment adviser receives “asset-based” fees. The asset hoovering technique generates extra unnecessary fees for the investment advisers and their affiliated investment firms, when compared to low-cost default arrangements available to their clients.

The price difference between the investment adviser’s in-house portfolio service and the default low-price retail multi-asset funds on a D2C platform, or Workplace Pension Scheme (WPS), is the investment adviser’s “asset-based” fee.

Adviser charges should reflect the services provided. Ongoing charges should only be levied where a consumer is paying for an ongoing service. Details of the service need to be confirmed in writing ahead of sale, as do the costs, and how the client may cancel. Firms must maintain robust systems and controls to make sure clients receive the ongoing service investment firms commit to. The level of adviser charges must at least be representative of the costs of the services delivered and the firm must not conceal the amount or purpose of the adviser charge (COBS 6.1 A.9).

The proposition of the asset-based investment adviser used to attract client asset is this, the focus is on short-term market-beating returns, as opposed to long-term planning. Even if those promises could be met, and in many instances they are not, the reputation of the investment adviser depends upon something outside of their control. Then the customer proposition becomes about price, which as customers compare returns, forces prices down.

As the regulator looks at the service for fee, consults on decency and uncovers examples of fees for no service, these asset-hoovers seek timely exit from the market, persuading naive advisers and behemoths to leverage to buy back books at high valuations; like some huge game of Russian roulette with valuation bubbles about to burst.

The investment advisers arguably knew — or should have known — at that time, about “the detriment this conduct caused to the clients”. Regardless, the investment firms and their advisers press on and fail to take reasonable steps to address the wrongdoing, as years of detriment pass by.

According to the regulator, over time, these charges can have a significant negative financial impact for consumers (PS20/6 s3.1).

To be continued.

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