The CII and PFS support the coordinated delivery of public
financial guidance. It must be accessible and inclusive, in keeping
with a wider national financial capability strategy, and be
underpinned by appropriate professional standards.
Our views towards the proposed delivery architecture are as
New money guidance body:
- No public profile:we agree that this body
should have no public profile, and should instead be focused on
sitting strategically above all the delivery bodies including the
"new Pension Wise" in a coordinating role.
- Responsibility to oversee signposting:one
consequence of the correct decision to remove public profile is
lack of consumer signposting from a single go-to body for consumer
inquiries. Therefore an important role of the new body is to ensure
signposting and active referral between the guidance delivery
organisations, even if this is not in those bodies' apparent
interests. It should verify this signposting with periodic mystery
- Duty to promote value of advice: while
professional financial advice might only be appropriate to certain
consumers, the new money guidance body should be given a statutory
duty to champion the promotion by the delivery bodies of the value
of financial advice, and conduct robust research around this
- Aim to address gaps, not overlap: the
body should aim not to overlap current public or private provision
but to address gaps. In terms of gaps assessment, priority must be
given to existing delivery by other organisations. The new body
should not duplicate services that are already available.
- Communicate value to levy contributors: the
organisation should include in its annual report clear indication
of the value of guidance to the levy-contributing financial
services sector, including its efforts to maximise value for
New pensions guidance body:
- Use Pension Wise brand: this should build on
the success of Pension Wise, and use that brand.
- Scope and divide with broader long-term savings
clarified:will the body cover broader long-term savings,
investments and later-life issues? Its scope should be clearly
defined in the legislation to prevent "mission creep".
- Signposting: there must be a
responsibility for the body to signpost out-of-scope inquiries to
other delivery organisations.
- Channels: we believe offering all
services across all three channels is neither cost effective nor
useful. The on-line and telephone services should be offered in the
first instance, with face-to-face used only for more detailed
- Promotion: considerably more promotional
support is needed for it to be the public's "go-t0" body for topics
within the agreed scope. It is also very important for it to
promote what services it can actually do for users.
View the attached consultation response »
CII Briefing (March
HM Treasury consultation on public financial guidance proposals
Consultation Response (December 2015):
HM Treasury consultation: public financial guidance »