The Financial Sector Conduct Authority ("FSCA") recently published its General Retail Distribution Review Status Update ("RDR Status Update").
A copy of the relevant document can be accessed here.
The RDR Status Update summarises the current implementation status of the 55 RDR regulatory proposals initially published in 2014, and sets out additional proposed developments planned for 2020.
In addition, the FSCA also published the following RDR documentation, which must be read together with the RDR Status Update, namely:
- RDR Discussion Document on Adviser Categorisation and Related Matters
- RDR Second Discussion Document on Investment Related Matters
- RDR Discussion Document on a Remuneration Dispensation for Savings and Investment Products for the Low Income Market (Proposal TT)
- RDR Position Paper on Equivalence of Reward (Proposal RR)
- RDR paper on Intermediary Activity Segmentation and Related Matters
Some noteworthy proposed RDR developments to look out for in 2020 include:
- In furtherance of Proposal J of the initial RDR document regulatory proposals (i.e. more clear delineation between intermediation activities, outsourced services and advice), the FSCA is in the process of considering possible legislative proposals (amongst other things):
- that will facilitate the charging of advice fees separate from commission, entailing a clear split between advice and “services as intermediary”
- replacing the current outsourcing notification processes with an approval process and introducing further reporting requirements in respect of outsourcing
- possible extension of the current binder caps beyond non-mandated intermediaries who provide advice, to other potentially conflicted relationships between non-mandated intermediaries and product suppliers
- Regarding the two-tier adviser categorisation model, stakeholder views are invited on various practical implications of the two-tier adviser categorisation and related RDR proposals, including but not limited to:
- the appropriate designations for “product supplier agent” ("PSA") and “registered financial adviser” ("RFA")
- the FSCA permitting advice to be provided by juristic representatives of either a PSA or an RFA, subject to certain conditions being met
- the FSCA's proposal that a PSA (including a juristic PSA), will be limited to providing both advice and non-advice intermediary services in respect of its home financial group’s products only