The FCA has published its policy statement on how it will allow firms to offer targeted support to customers so as to offer them recommendations on investments but not a full, in-depth individual advisory service. Broadly, it is implementing the rules as consulted on. Key requirements will include:
- identifying consumer segments with shared financial support needs or objectives to whom ready-made suggestions could be made;
- clearly communicating the nature of targeted support when providing it;
- regularly reviewing and monitoring the outcomes of targeted support provided.
Firms will be able to charge for the service, if they wish.
Firms wanting to provide targeted support will need to apply for a VOP to do so, and the FCA has been having meetings with interested firms using its PASS service already – so it is on track to open the gateway for applications in March.
The FCA has also worked with the FOS and the ICO to clarify how the FOS will approach consumer complaints and how direct marketing rules interact with the ability to communicate with customers.
HM Treasury also published its policy paper on the changes, confirming its decision to go ahead, and that the legislation amending the RAO will also include disclosure requirements. It also confirmed that Appointed Representatives will not, at least for the moment, be allowed to provide targeted support. Once the Government has put in place its planned reforms to the AR regime it may reconsider this.
The FCA will make its final rules once the legislation is finalised, and is preparing for a start date of 6 April 2026.
