Legacy assets: reading between the lines
With the publication of Policy Statement (PS12/03) in February 2012, the Financial Services Authority (FSA) has formally confirmed the end of incremental commission for advice given after 1 January 2013 on Retail Investment Products (RIPs) sold prior to implementation of the Retail Distribution Review (RDR). On the face of it, this sounds straightforward. However, even before the FSA published Consultation Paper (CP11/26) in November 2011, the implications of the true impact were a concern throughout the retail investment industry, attracting significant commentary.
Since the publication of the FSA’s Consultation Paper (CP11/26) in November 2011, firms RDR programmes should have had a workstream investigating the potential implications and impact in detail.
Firms should be well into design and potentially into implementation phases by now. However, all relevant assumptions and decisions should now be revisited as a result of this Policy Statement.