HM Treasury: public financial guidance
CII/PFS Consultation Response
08 June 2016
22 September 2017
Policy and Public Affairs
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 follows:
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 shopping.
- 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 theme.
- 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 money.
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 inquiries.
- 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.
CII Briefing (March 2016): HM Treasury consultation on public financial guidance proposals »
Consultation Response (December 2015):
HM Treasury consultation: public financial guidance »
This document is believed to be accurate but is not intended as a basis of knowledge upon which advice can be given. Neither the author (personal or corporate), the CII group, local institute or Society, or any of the officers or employees of those organisations accept any responsibility for any loss occasioned to any person acting or refraining from action as a result of the data or opinions included in this material. Opinions expressed are those of the author or authors and not necessarily those of the CII group, local institutes, or Societies.