Back Office Support
Consumer Duty:
- What information was provided to the client to allow them to make an informed choice?
- Storing the information (email + attached PDF, copy letter and example document)
- Evidence of clients confirming that they are making an informed choice – how is this recorded/stored in the Back Office system?
- Recording of a client’s investment/mortgage preference and objective decision
- Linking Investment/Mortgage preferences to due diligence
For ESG, Sustainability and values-based investment, the level of information needed to ensure a firm is aligning client and fund target markets is extensive. To start, the target market is identified by the product provider’s product governance process and includes identifying both positive and negative target markets for the funds (it is not expected that a client would invest in a funds in which they are the negative target market for). Following this, the adviser should then fine tune the target market to reflect their own client base (segmentation).
A firm’s client bank segmentation may include groups for:
- Clients that do not want ESG applied (match to funds that do not have ESG embedded)
- Clients that wish to invest ethically (match to funds that invest ethically)
For ESG, Sustainability and values-based investment, the level of information needed to ensure a firm is aligning client and fund target markets is extensive. To start, the target market is identified by the product provider’s product governance process and includes identifying both positive and negative target markets for the funds (it is not expected that a client would invest in a funds in which they are the negative target market for). Following this, the adviser should then fine tune the target market to reflect their own client base (segmentation).
A firm’s client bank segmentation may include groups for;
Client wishes to invest in funds that have sustainable objectives (match to sustainable focus, improvers or impact)
Sustainable Disclosure Requirements (SDR) and investment labels:
- Sustainable labels
- Sustainable Disclosure statement – the client file must demonstrate how the disclosure statement has been provided to the client and when the next annual update is due for each fund to ensure these are made available to the client
RegData:
- Total amount invested across the sustainable fund labels
- Average investment in each label
- Largest investment amount
- Distribution across providers for each label
We are currently reviewing what is available from the main back office providers and have compiled a database of those systems that are already ESG/Sustainable/Values based investment friendly.
NOTE: We have made a number of attempts to review existing propositions from the main Back Office software providers. To date, none have responded. As such, we are not in a position to provide advisers with information on those providers who may have built ESG, Sustainable and values-based data capture facilities.
If you are using one of the main Back Office software providers which offer some support, which includes using the Spectrum of Capital and dedicated Informed Choice and Investment Preferences and Objectives areas, we would love to hear from you. Please do email us HERE with any information you would like to share.
Other back office support
Suitability report generation
Increasingly technology is helping advisers and outsourced paraplanners firms produce well-crafted suitability reports. These technology solutions need to cover the personalised investment pathways of clients who are making Informed Choices about their investment options.
The best technology solutions in this space will be able to accommodate not just the basic ESG options, but also the forthcoming Sustainable fund labels and ethical or other values-based options.
Our sustainable back office database also includes firms that have demonstrated a commitment to supporting advisers with up to date information on ESG and sustainable options.