Compliance News 04/21 (Learning from Re-certification Workshops)

Thank you all for completing the tests which followed each of the 4 compliance workshops which we ran towards the end of 2020.  The following statements relate to the knowledge we tested, which you can refresh by reading these statements.


Sales Process – If you don’t meet with a new client and so cannot see their original ID, then you must ask Lynn or Pete for an Equifax AML (anti money laundering) check to be done.

Sales Process – There are customer benefits in conducting your telephone appointments over more shorter calls, rather than one or two lengthy calls, to keep their attention and to help their understanding.

Sales Process – It is mandatory to provide the client with The Right Advice brochure when they are first time buyers.  Although it can also be provided to any of your clients.

Sales Process – You must always obtain a CI Expert report when you are recommending that a client existing CIC policy is to be cancelled or replaced.

Sales Process – The minimum requirements to evidence income and affordability for an employed applicant are three months payslips plus the corresponding three months bank statements.

Sales Process – And the minimum requirements for self-employed are either the last two years accounts or last two years SA302s.

Sales Process – Some common examples of staged income ‘could be’ where an applicant works in the family business, or an applicant who has had a large recent pay rise, or an applicant with multiple jobs, or an applicant who has just changed their employed job which now pays significantly more than their previous employed job or self-employment.

Sales Process – Before deciding to take leads from a new lead source/provider, you must first tell Pete Burgess so we can undertake some due diligence.

Sales Process – If you have any concerns regarding an applicant or their paperwork, you must report a Suspicious Activity Referral to Pete Burgess (this can be the specific SAR form on the Knowledge Hub, or an email or phone call – anyhow will do!).


Mortgages – We have access to over 100 lenders.

Mortgages – The new HTB scheme came into effect on 16th December, for completions from 1st April 2021.

Mortgages – We are responsible for the advice when we use a packager to help place a case.

Mortgages – We are not responsible for the advice when we make a 2nd charge referral to CSC Loans. The advice for 2nd charges sits with CSC Loans.

Mortgages – The current reduced rates on Stamp Duty Land Tax end on 31st March 2021.

Mortgages – For Later Life advice, we feel Equity Release qualified Advisers are often better placed to help the client.  Also, if you recommend a product which is both interest only and beyond an individual’s intended retirement age, then your advice must be checked.

Protection – We do not have a preferred provider for Income Protection.

Protection – The Vitality product where the guaranteed premiums cannot increase is Essentials.

Protection – You should recommend Vitality’s Serious Illness Cover over a traditional Critical Illness Cover policy, only when the client wants more illnesses covered than from a CIC policy.

Protection – Examples of “value added benefits” on a protection policy are the likes of Global Treatment from Aviva; Fracture Cover from Vitality, Aviva or Zurich; Best Doctors and GP24 from various insurers.

Protection – All single life Term Assurance and Critical Illness policies should be written in Trust, but it is not necessary to do so for joint life policies.

Protection – You can only make use of a “nomination of beneficiaries”, instead of a Trust, on a Life policy (Guardian and Royal London) where you are sure there is no IHT liability on the applicant’s estate.


Complaints – The excess level provided by our PI cover is £2,500.

Complaints – To improve the chances of a complaint being defended in the future, add lots of Notes to The Key to provide soft facts to help justify your advice.

Complaints – If you receive a complaint, don’t try to deal with it yourself, don’t admit liability, do pass it to Pete immediately, do provide a report when asked.

Breaches – Our most common type of breach is for Record Keeping, so things such as the RWL not being done within the required 10 days, or supporting documents not added to The Key.

SARs – Our most common type of SAR is for Staged Income, and “possible examples” of staged income are working for a family business, a large recent pay rise, individuals with two or more jobs.

Conduct Rules – There are 5 First Tier Conduct Rules for Advisers to follow.

Certification Regime – The types of evidence needed to demonstrate your competence to the FCA are fitness and properness checks, evidence of the minimum required hours of CPD being attained, an analysis of your product sales to demonstrate the right customer outcomes are achieved and details of any breaches and complaints, etc.

CPD – We now require an Adviser to complete at least 4 hours a quarter of CPD in each of your licence areas, so if you advise on mortgages and protection, that is 4 hours of each.


Mortgages – When sourcing a mortgage using ‘Total to Pay’ and the client wants to add the fee to the mortgage, you should only add the fee when creating the ESIS from your sourcing results (and not earlier in the sourcing process).

Mortgages – With a product transfer you can proceed with reduced supporting documents when dealing with an existing client and nothing in their circumstances has changed.  Please add a note to The Key to confirm these points.

Mortgages – Where your client is being gifted their deposit, you need to obtain a gifted deposit letter plus a bank statement or other evidence confirming where the funds are being held.

Mortgages – If you are arranging a mortgage for a client and it runs beyond the anticipated retirement age then you need to record how the client would afford it from retirement income.

Mortgages – Where you have arranged a mortgage for your client, and at the time you agreed with them to review protection when the offer was issued, but the client will not return your calls or emails about reviewing protection, then you should issue the “no protection letter 2” (can be found in The Key) and also keep trying to contact the client to review protection.

Protection – If you are recommending income protection for your client this should be written to the client’s anticipated retirement age.

Protection – If are making a family protection recommendation, and your client tells you they want to take out lump sum cover, we would expect you to recommend Family Income Benefit which the client partially accepts and then takes out lump sum cover. Please provide a reason why the client wanted lump sum cover in your RWL.

Protection – If your client has given you a budget that does not fully cover all their protection requirements, the needs analysis should be completed on the basis of what you believe the needs to be regardless of whether you can recommend full cover for all of them.


Where you requested training on any of the following systems, then this training will be provided within the next few weeks.


Paymentshield – integrated with the Key.

Smartr Quote

Smartr Criteria

Smartr Fit

CI Expert


Criteria Hub/Affordability Hub

Zoom (Teams/Skype)



A reminder of those 5 Conduct Rules that all individuals are required to follow are: