Financial Planning for 'Middle England'
Talking about tax
Engaging with the RDR
The fossilisation of value
The RRR is much more important
You couldn't make it up
Why are we in business?
A question of priorities
UK plc's uneasy relationship with debt
The art of reinvention
Life, Intelligent Life and...Insurance Companies
What price independence?
The smokescreen of complaint management
A contract you don't want
The clients you don't want
Upfront about reviews?
The inequities of long-term care - in microcosm
IFAs and the latest buzzword
Who ya gonna call?
The UK Complaint Culture
Another Sorry Saga
Fiddling...
Worth getting angry about?
Are we missing a trick?
Negative inflation - doesn't apply to us!
When governments default
The limited benefits of regulation
What happens if we don't market ourselves?
Lessons from Pension-Switching
Is small the new big?
The Banks and our clients
What if?
The death of indemnity commission
From the sublime to the ridiculous
Shooting ourselves in the foot
Careful Complaint Management
Friday afternoon irritations
Ruminating about Risk
Wales Fast Growth 50
Fiat Money Magic!
New regulatory horizons beckon...
Mourning old friends
Lame man banking
'Wall Street indices predicted nine out of the last five rec
Somebody...please regulate this sector!
Think and grow rich
If it's not about integrity, then...
Bearish works for me
Having the right impact
Enforcement is the new Big Thing
Well thank goodness that's over...
A demon of our own design?
A new national religion?
In a typical week...
The shrill cries of anguish
It's simpler, but will it be better?
Health warnings: reading the financial press
Unsustainable?
It's a crazy world
What's it worth?
CGT Changes and Simplistic Arguments
Waste...and more waste
Bank of England: Armageddon Scenarios?
With-Profits...again
Financial Risk Outlook 2008
CAR (Customer Agreed Remuneration)
Service is optional
Customers not consumers
Business tough in 2008?
Getting Tough on TCF
What is 'Primary Advice'?
RDR - Feedback Submission
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The fossilisation of values

trilobite1

 

The image is of a Trilobite fossil, held captive in a piece of Early Cambrian sedimentary rock, and dating back approximately 540 million years. We don’t have any contemporary living examples to compare it with, but we have a pretty good understanding of the different kinds of Trilobite from the records of around 17,000 species preserved in the geological column.
 
This is an image we’re all familiar with, from secondary school. It looks like a Trilobite, but we have no detailed, specific idea of how these things felt, nor indeed of how they behaved – because all we have is the mineralised mould of what once was a living thing. The appearance is ‘trilobitish’, but we no longer have a living example to observe and understand.
 
Which, in many ways, is a not inaccurate metaphor of the impact of regulation on aspects of our business proposition. For example, no sentient IFA that I’ve spoken to has any heartfelt objection to the principle of TCF (Treating Customers Fairly): who could possibly object to the broad idea that we should be ‘fair’ in our dealings with our clients? Someone who had real difficulties with the whole concept simply shouldn’t be in this profession.
 
TCF, then, is about the values which we bring to the table when we create our business proposition, aimed at delivering a service to our clients. But values are living, breathing things. They are what makes us tick. The problem with TCF is not about what it says about our values, but what happens to the whole concept once it becomes a regulatory device. In practice, the core idea becomes shrouded in layers of regulatory sediment, so that over a relatively brief period of time something that was alive and a catalyst in terms of direction and activity, simply ends up as another regulatory fossil.
 
Clearly, the FSA has not forgotten about TCF, and there is currently a renewed focus on assessing IFA firms for their progress and compliance with this initiative. Part of the problem for many IFAs is that, due to the process of regulatory fossilisation, the whole thing seems remote or irrelevant to what they are actually trying to do for their clients. It becomes something ‘extra to do’, rather than a living, breathing part of what they do.
 
2020 Financial Services have written a resource called ‘Beyond TCF’ to help with this dilemma. It is free to all our Member firms, and we’d really encourage you to download and read it. If you are not a Member firm, why not visit our enquiry page to find out more about the 2020 Financial Services model? Please click here.

 


Kevin Moss, 25/03/2010