The IDD brings a change in the language used when setting out the scope of your service.
The aim is to ensure that when carrying out a 'fair analysis', it is made clear that this is taking into account the individual personal circumstances of each client and that sufficient research is undertaken to ensure that the results reflect the personal needs of that client.
The follow up to this is to ensure that the client is made aware that the recommendation is personal, so again reinforcing the fact that you have taken into account their needs and personal circumstances.
You will need to review sales processes, and output documents to ensure wordings in correspondence, reports, and demands and needs statements indicate that you have (where appropriate) made a 'fair and personal analysis' and that there is a 'personal recommendation'.
The FCA has also pointed out that where any demand or need has not been met, they expect firms to explain this to the client so they know what they are covered for and can make an informed decision.
Where you do not use a 'fair and personal' analysis and use a panel, the significant change is that you must disclose the makeup of that panel 'upfront'. At the moment, it is on request. Going forward, you must list all the companies on your panel. This should be disclosed in the client correspondence, and you cannot rely on this data being included in your TOBA alone.
Please speak to your RWA Business Manager if you have any questions.
