Perhaps I've been around for too long in compliance but wasn't it always the case that you weren't allowed to pay an adviser or network anything outside the inducement rules?  Back in Lautro days we talked about indirect benefits and some people still do.  Things like a congratulatory advert was banned as that was a benefit to the IFA outside the indirect benefit rules and would still be in breach of the current inducement rules as it has no benefit to the client and is simply a free advertisement.

These issues were often the discussion of the Compliance Officers Discussion Group that meeting of compliance geeks that loved to examine the rules and continue to do so many years later.  However how did we come to the place when firms were paying over a million pounds for a rate card of ridiculous benefits that were obviously designed to profit the IFA or network without any reference to customer benefits or the idea that you might have to repeat the same for all advisers in similar circumstances?  Some firms even think a trip to the Middle East for networking by the sea in 5 star hotels is somehow perfectly aligned to the inducement rules and totally acceptable as a client benefit in line with the FSA COBS rules.

Well it seems at last these outrageous claims have had their day and finally the FSA is clamping down.  However not because it was always wrong and in breach of the rules but because somehow it offends their precious RDR principles.

Actually it is not about RDR but simply a matter of product bias and adding a provider's products to your panel not because of the benefits of the proposition but because they happen to be giving you so much money for spurious benefits that they effectively 'pay to play'.

Well I have to say that as a compliance manager for a life company I was turning down these requests over a decade ago.  It may have been much to the annoyance of my marketing and sales colleagues but it was the right thing to do.  It may explain why my team was wound up and we were all made redundant but such is life when you stick to a principle!


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