Referring to KFIs as the “worst example of information overload”, he continues: “You should look at everything that consumers receive at the point of sale, surely. You put a bog-standard KFI in front of anyone and ask them to give a reaction, and they would say information overload.”
But the PFS’s Mr Richards believes the issue need not be confined to the FAMR itself. He says, “There is a strong argument that KFIs should be subject to the same level of scrutiny and review currently being undertaken for suitability reports. However, improvements can be made without necessarily expanding the scope of the FAMR.”
One issue in which there has been positive progress is the FSCS funding review. Advisers are set to see their contributions to the annual levy fall, according to the proposals put out in a December 2016 consultation. The change is less comprehensive than some had hoped for, however – a product levy, which would see more responsibility fall on product providers, has been ruled out by the FCA. The timeline for implementing the proposed changes is also a lengthy one: changes will not come into place until 2018/19 at the earliest.
“The burden shouldn’t disproportionately fall on advisers. I am disappointed that it will take longer to bring this into force, but it is better that we get this right for a sustainable long term solution,” says Chris Hannant, director general of the Association of Professional Financial Advisers.
Two other important issues for advisers addressed by FAMR have even lengthier timeframes. The original proposals ruled out introducing a long-stop limit for referring complaints to the Fos, and said the issue would only be looked at again in 2019 as part of the wider FAMR review scheduled for that year.
The other is the pensions dashboard. Here there was little expectation of a swift solution. Implementation may not take the decade predicted by former pensions minister Ros Altmann, but a target introduction date of 2019 remains some way off.
Last September brought fresh disappointment for some advisers with the news that building a prototype model would be the responsibility of providers alone: Aviva, Aon, HSBC, LV, Nest, Now: Pensions, the People’s Pension, Royal London, Standard Life, Zurich and Willis Towers Watson, under the oversight of the Association of British Insurers.
Advocates say enabling consumers to view all of their pensions in one place would help encourage a savings culture and curtail some of the confusion that continues to exist around where or how to save for retirement. But some are concerned by the government’s decision not to force providers to get on board.