The Training Environment For Financial Services

Selling Insurance or Investment Products without giving Advice

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Background & Objectives

The history of compliance is littered with disasters where firms offering a non-advised service have been accused of either giving unsuitable advice or failing to be clear, fair and not misleading. 

Yet, in many areas, firms do not want to give advice because of the resource implications. Customers do not want to pay for a personal recommendation or take the time to go through a full advice process. 

The first task is to sort out whether advice or more seriously a personal recommendation has been given and the different implications of the three types of behaviour: non-advised, advised and personally recommended.

The second problem involves sorting out whether in an attempt to make a non-advised sale, the firm has breached the requirement to communicate in a clear, fair and not misleading way to its clients. Trying to make a sale without giving advice often tempts firms into breaching the “clear, fair and not misleading rule”. 

Attending this focused course will help you:

  • Understand the difference between a personal recommendation, advice and a non-advised transaction
  • Review the rules that apply to each type of transaction
  • Know the key elements of “clear, fair and not misleading”
  • Apply the rules to well-known sales techniques
  • Demonstrate compliance in the sales process

Who will benefit?

This practical course will be of value to Compliance, Risk, Marketing, Sales specialists and Advisers in firms offering insurance and investment products.

Course Programme

Topics covered may include but are not limited to:

Introduction

  • Distinguishing personal recommendations, advice and execution-only
  • Principle 7, ICOBS 2 and COBS 4.2.1R – clear, fair and not misleading 

Deciding whether sales staff have given advice

  • What the FCA says about this? PERG 5.8 (insurance) and 8.24-30B & Annex 1 for investments
  • Explaining the lack of advice

Sales techniques found by the FCA to be either giving advice or a breach of clear, fair and not misleading

  • Objection handling 
  • Lack of balance
  • Comparisons
  • Pre-purchase questioning
  • Questions and answers that lead customers towards making a purchase
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