FCA review of Roboadvice
Written on 10/08/2018

On 21 May 2018, the FCA published a webpage setting out the findings of its reviews of firms offering automated investment services.

The FCA reviewed seven firms doing automated online discretionary investment management (ODIM)  In these cases the firm has responsibility to invest on a client's behalf, within agreed parameters, on an ongoing basis.  They also reviewed three firms providing automated retail investment advice.
The advice firms fared the worst.

The FCA's findings include:

  • The service and fee-related disclosures at most ODIM firms weren’t clear enough.  Firms did not make clear whether their service was advised, non-advised, discretionary or non-discretionary. Some firms compared their fee levels against peer services in misleading ways.
  • ODIM firms did not evaluate clients' knowledge and experience, investment objectives and capacity for loss in their suitability assessments.  
  • ODIM firms were unable to show that they had adequate and up to date information about clients when providing an ongoing service.
  • Auto-advice services relied on assumptions about clients and lacked adequate fact finding and know your client focus.  FCA were unhappy with the level of information-gathering about clients' personal circumstances.

FCA highlights rules on communications with clients (COBS 4), and suitability (COBS 9 and 9A).
Many advisers wonder whether firms like Nutmeg will ever make a return to justify the investment in robo-advice.
As soon as you give advice, the floodgates open to suitability and Cobs9, and this makes it hard to comply in automated format. 
Far better to navigate the execution only side and then turn yourself into a marketing company – like Hargreaves Lansdown.  Or wait and see what works and then make your move on robo advice.
The FCA restated that its rules on suitability of advice apply regardless of the medium through which the service is offered and that its rules apply equally to emerging automated offerings. 
FCA will review more firms in the auto-advice market later in the 2018/19 financial year.

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