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If you wannabe my Robo

It will probably come as no surprise to you to hear that Leith’s leading platform and investment consultancy * are doing a fair bit of work at the moment in the exciting area of robo advice. Firms large and small want to understand what is going on, where the opportunity might be, and crucially what the target customer might look like. As we work through this exercise its striking that for a lot of companies their target customer is kind of like me. Early 40’s (cough), young-ish family, decent job (cough), some savings but looking to do more, reasonably tech savvy & seriously good looking. Sadly, when I look at the advice propositions out there at the moment, none are giving me what I (really really) want. So, if you wannabe my robo, this is what you’ve got to do (in no particular order)

I’ll tell you what I want, what I really really want

1. Advice. I want advice, and I don’t want it to be just about a single product. I want to be told to pay off debt, increase my employer pension contributions, sort out a will, whatever is actually appropriate for my needs.
2. Charging. I’m happy to pay for this advice, but don’t make it contingent on a product sell. I want to pay my robo the same whether or not I buy an ISA.
3. Charging again. And don’t force me to pay you an ad-valorem servicing fee. I don’t want to be paying you 1% for ever, but I’m happy to pay explicit fees as and when its required.
4. Risk. By all means assess my risk capacity and risk tolerance, but I also want to know risk required. How much risk should I be taking?
5. Tell me what to do. In addition to the risk I should be taking, tell me what I should be doing, nag me if I am not doing it, and stop me doing stupid things.
6. Blend online/phone/face2face. I like communicating on my terms. Sometimes I might want to speak to you. Sometimes I might even want to meet with you. Most of the time I want to do stuff online. However, whatever way I contact you I want it to be integrated & a seamless experience. I don’t want to have to tell the call centre who I am and what I want.
7. Integrate with my bank. My current account is the centre of my financial life. Everything I have comes in or out of my current account. I want to be able to see my investments & my financial plan alongside my day to day spending. I haven’t changed my bank this century, so I’m a (stupidly) loyal customer. Give me what I want….
8. Children. Nothing is more important to me than my children. Give me the ability to start saving for their future, and show me the long term impact of saving even small amounts. Allow me to share this with them and get them interested/excited with saving.
9. Mobile. I’m a cool trendy professional (cough), and I spend a lot of time with my iphone. I want to be able to see what is going on with my financial world wherever I am. I’m happy to be nudged into good behaviours, but don’t allow me to do a late night pub withdrawal.
10. Remember I am human. My behaviour is not rational. I have lots of inbuilt biases that often make me do stupid things. Be aware of these, protect me from them, and demonstrate how this adds value to my life, not how clever your ETF selection process is.
11. Regulation. It’s bad enough trying to understand the regulation surrounding online advice as an industry expert (cough), but it’s impossible if you are a real person. I want the comfort that my financial future is regulated and protected. I don’t want you to hide behind t&cs.

Over the last few months we have been lucky enough to work with clients who recognise the above, and are building solutions to address these needs. Some are going for specific elements, others are thinking big and building towards the full solution. My financial life is about to be spiced up, and I can’t wait.

* = Probably

Robo Spice

Back once again

Back once again (with the ill behaviour?)

In a move that will shock no one it has been reported that Santander & RBS head the lists of banks returning to the investment advice market. With several other large institutions rumoured to be planning similar moves it seems that the post RDR period of the banks not offering advice is ending. Reaction on the online comments & twitter (always an accurate barometer) has been pretty negative, but are these moves really such a bad thing?

At last month’s lang cat DeadX event, the Citizens Advice Bureau spoke about the advice gap. You can see their slides (and those of the other speakers) just right about here. Their research has shown that if the typical advice cost of a £11k ISA is £450, then 80% of adults would not be willing to pay for advice, and that’s assuming they could find an IFA who would want to give advice on this level of investable assets. The most recent HMRC stats show that ISA sales are increasing, with subscription amounts growing due to the increase in the annual subscription limit, however the vast majority are being held in cash ISAs. Might some of these individuals be better served in stocks and shares? Especially if they are advised this is suitable for them? For a lot of the population simply saving or investing in a sensible and disciplined manner would be a huge step forward, and if Santander and other banks can enable this then all power to them.

Of course, the key word in the above is suitable, and Santander don’t exactly have a great track record in this area. Anyone googling “Santander Investment Advice” will still be greeted by news of their 2014 £12.5m fine for unsuitable advice, so at a minimum their SEO guys need to do some work pre-launch. The one positive is that their FCA final notice does give them and any other bank wanting to launch an advice proposition a template of what not to do unless you fancy a visit from the FCA enforcement squad.

The main failings centred on establishing suitability and ensuring the investments were at a level of risk that the customer was willing and able to tolerate. This is an area where the recent development of “robo-advice” systems should deliver considerable improvement. Technology is now available to ensure compliant advice can be delivered consistently, and in a time effective manner within any size of organisation. The investment decisions can be made free of any emotion or bias, with systems and controls in place to ensure adequate monitoring at a head office level.

However, with any robo system the greatest risk must be that of systemic mis-selling. The huge customer bases the banks have, together with the reluctance of the vast majority of people to change their banks must make the business case look attractive so the quality of proposition design is crucial. One important element of this will be charges, and this is certainly something we will be looking at closely when these services are launched. Customers investing via these services are unlikely to be advised on the whole of market, so any restricted range of funds must be appropriately priced.

We have recently reviewed every multi asset/multi manager fund, and have discovered a range of over 150bps between the cheapest and most expensive solution. Anyone offering a robo-advice service, be they bank, adviser, whoever needs to ensure suitability. Cost is not the sole determent of suitability, something that is cheap and unsuitable is still unsuitable, however this is one area that scale should bring benefits for the end consumer. If the banks can deliver low cost suitable advice to the masses then their re-entry to the market will be a hugely positive move. If not, then they can expect a scathing blog from lang cat HQ. That should do it.

the lang cat’s albums of 2015

OK, not so much the company’s, but mine. Who says it’s a democracy? Next year we’ll maybe do a more inclusive roundup, but here’s what cheered me up this year:

Public Service Broadcasting – The Race For SpaceBleep, bloop, astronauts are nice was how I described this record, unkindly. It’s fantastic stuff and a good thing to bathe your brains in.

Iron Maiden – The Book of Souls – this was proper Maiden and maybe the best thing they’ve done since Seventh Son. And I met Bruce in the airport on the way back from New York. *fist pump*

Tom Mcrae – Did I Sleep And Miss The Border – Still grumpy, still singing about rain, still fantastic. How this man isn’t selling out big venues is a mystery to me, but it meant we got to go for a work night out to see him at King Tut’s in Glasgow which was ace.

Trivium – Silence In The Snow – just big metalcore loveliness. Trivum have always been one of those bands I couldn’t quite be arsed with, but this is a cracker.

Soilwork – The Ride Majestic – see Trivium. If it wasn’t for Maiden, this would be my metal record of the year. It’s been on pretty constant repeat since I first listened to it.

And record of the year goes to:

The Unthanks – Mount The Air – I don’t even know how to start describing how gorgeous this record is. The voices, the arrangements, the fluttering sound effect and the drone in Magpie, the catharsis of the title track – it’s all amazing. And if you can see them live, do. Proper shiver down the back time.

So there it is. I can only imagine Coldplay and Adele are furious not to have made it. Let me know what I should have included below.

Cheers

Mark

the lang cat’s roundup of 2015

So it’s the afternoon of 31 December, the lang kittens have been beaten over the head repeatedly until they agree to a nap so they can stay up to see the bells in, and I have a few minutes at the end of a tumultuous year to write this.

‘This’ being a self-indulgent round up of the year. I shall point out, as I do every time I do one of these, that yes, it is indeed self-indulgent, and no, no-one really gives a damn except me.

But none of that matters, largely because it’s my blog not yours, and also because self-censorship is not a skill I’ve ever really learned. Maybe if I had I might still be in corporate life. *shudders*

Lots happened in our little corner of the garden this year and there’s no great value in going back over it all. But I’ll carry two big themes away:

  1. PENSION REFORMS – My biggest giggle of the year was the dawning realisation on the faces of lifecos execs that Gideon gives exactly zero f***s about the life and pensions sector. “Butbutbutbut he’s a Tory, he’s meant to be on our side!” came the faint bleat which you could hear if you listened hard enough. Yes, he is, but he’s not a Tory who wants a job with any of you lot when his time filleting the state is over. What was really interesting about the GYMBOA reforms (as we christened them – Get Your Money Back Out Again) was that rather than being prospective in nature, it drove a cart and horses right through the most valuable bit of the UK long-term savings and investments sector – the pensions back book. This was and is massively destabilising, and lifecos haven’t yet felt the full impact. If we move from EET to TEE (looking less likely now, but it’ll all depend on the politics) then shorting the life sector looks like a sure thing.
  2. ROBOADVICE – hahahahahaha. I’ve come to love the term as much as many others hate it, mainly because it winds people up so much. No, there are no robots, and no, they’re not giving advice (at least in the way we understand financial planning). But this was the first year that we saw the barriers come down a bit to enable new entrants to come up with different models for delivering relatively basic advice. There is lots still to do – Project Innovate (again, hahahahaha) will be important along with its sandbox (which if it’s anything like my sandbox as a kid will be full of catshit in a week or two – but we’re seeing interesting new things happening with eVestor, Fiver A Day and others. I had the chance to spend a couple of weeks in the States in the late summer poking around robo a bit, and while the headlines go to the likes of Betterment, it’s the big engines of Schwab and Vanguard who are scarfing up assets even beyond back-book rewrites. Watch Vanguard very closely here. If anyone can redefine the market it’s them.

For next year? Watch replatforming – we had some of it in 2015, most of which was pretty tortuous, and there’s more to come this year. Everyone needs to have patience with companies going through this – but the companies themselves need to be honest with advisers and clients, and not delude themselves that it’s all going to be fine. As I’m fond of saying, there is no recorded instance of replatforming going well.

We’ll see the back book integrators (Aegon, Zurich, others) accelerate and become very big platforms in their own right – the interesting thing is what happens when that work is done. Can they become vertically integrated shops like Standard Life and Old Mutual? We’ll see the ‘black box’ providers such as SEI and Pershing do many more interesting things in the market, and over time it’ll be easier and easier for firms to create a platform in their own image. The niche guys will still be niche, the big guys will still be big, but those stuck in the middle will find it increasingly hard to get distribution footprint, and will also struggle to get development priority resource.

Dead imageI’d like this year to be one when we stop trying to outmanufacture each other. When we wrote that Platforms Are Dead, that’s what we really meant – the days of asset flows shifting due to more ticks on a crappy due diligence matrix are gone. Now it’s about doing the basics really well as a bare minimum. From there it’s about recentering the whole platform experience so that it’s less of a Godawful schlep to use.

From a lang cat point of view, this was a huge year for us. We were joined by Mike Barrett of Old Mutual, Terry Huddart of Nucleus and Shona McCowan of Aegon. Our little team is 10-strong now and we’re about to start hiring again. We’re gonna need a bigger cat basket. We published influential studies into advised and D2C platforms (including a deep dive into platform pricing which made us no friends at all), pension reforms and lots of other stuff. Our (well, Steve’s) pricing tables are now a feature of pretty much every personal finance section in the national press. And we still managed to have a giggle along the way.

2016 for us will be a year of consolidation and growth. We’ll keep applying our technical expertise to deliver insight and analysis that you won’t find elsewhere. Data is getting easier and easier to find, as it should be. It’s what you do with that data that matters. Our contention remains that if you know what you’re talking about and you can put it across with a half-smile on your face and some pictures of aggressive looking cats, then you’re all set.

As happens every year, when I look back at all the shitty stuff happening in far-off and not so far-off places, I remain grateful that we work in a sector which encourages more than one point of view and in which (with just a couple of mardy exceptions) we can robustly take the piss out of one another.

So thank you to all our clients and everyone we’ve worked with in 2015. Thank you from me to all the felines – please don’t go and get proper jobs any time soon. Thanks too to the apers and the haters – you keep us getting better. Here’s to a peaceful and fun 2016.

Mark

Tales from The Crypt

“Dearly beloved. We are gathered here today”

DeadX-1To quote Shaun Sandiford of Octopus, “man that was good”. A HUGE thank you to everyone who came to #langcatdeadX , deep down in the Crypt on the Green. Briefly, because we know you are busy and all that, here are just some of the highlights……

For some reason we felt right at home in the Crypt. It’s a fantastic venue, in a cool part of London, and helped create a great atmosphere. It also gave us the amusement of watching people try to find the venue. “I’m looking for a Crypt” was a FAQ. (Makes note to improve signage next time).

The Crypt dates back to 1100AD, where it was the site of the first nunnery to be built in London. It was restored in the late 18th century, with the restoration funded by the sale of annuities. Oh how the audience laughed at this when Mark Polson cracked the joke. Thankfully he didn’t use the joke about nuns he rolled out during rehearsals…

We had three fantastic guest speakers, none of whom paid or were paid to appear, so an even HUGER thank you goes to them. First up was Joe Lane from the Citizens Advice Bureau. Joe took on the subject of the advice gap, and in particular the 4 advice gaps their research has indicated exist. You can see Joe’s slides here, and the supporting research paper is available here. This session really resonated with the advisers in the room, especially the suggestion of offering “free” advice to address the gap. Everyone is supportive of improving the access to and availability of advice, but more work is needed to ensure the advice industry are fully on board.

Next up was John Roe, Head of Multi-Asset at LGIM. John delivered a fascinating presentation on behavioural psychology and the impacts on investing. In particular, how our in-built human biases can influence us when setting goals, investing and reviewing our investments. Something for Proposition and Marketing heads to think about when designing consumer facing services. John slides are available here, with supporting material here.

DeadX-7Our final speaker was Pete Trainor, Director of Human Centred Design for Nexus UK. As Pete puts it, “we are not digitising investing, we are investing in a digital world”, and his session brilliantly exposed just how much work financial services has to do if it is to engage with “digital weirdos”. Pete started by getting the audience to swap their mobile phones with the person sat next to them, and then gave everyone 60 seconds to look through their neighbour’s phone. The audible gasps of panic instantly demonstrated the emotional effect technology can have on people. Financial services needs to recognise this and create services that inspire.

A special thanks is due at this point to Annalise Toberman, who was sat next to Rory Percival of the FCA and had his phone for 60 seconds. Fortunately (or perhaps unfortunately) she was too professional to look at his emails…

Pete’s slides are available here. You can also see his recent TedX talk on youtube if you want to see him in action.

So, that’s it, our last event of 2015. Thanks again to everyone who came, and especially the speakers. And don’t worry, we are already planning our next event…

DeadX-8

TURNOVER IS INSANITY. PROFIT IS PROFANITY.

The platform market is maturing and a natural by-product of this is increasing merger and acquisition speculation. This, along with ever improving due diligence practice, has brought the issue of platform financial strength and performance into sharper focus. Overall, this level of analysis is a good thing because adopting a platform that goes belly up or significantly changes focus could prove to be a rather costly pain in the rear end for an advisory business.

Of course, anyone who spends time buying or selling companies will tell you that straight-up on-paper financial performance is only a crude indicator of long-term financial viability. It matters, but as part of a bigger picture.

That bigger picture is where you live – in the real world, where you have lots of competing requirements. So priority comes heavily into it. Strong profit performance might be the number one concern for Adviser Kate, yet scale of a parent company or AKG rating might matter more for Adviser John.

Financial health is also a messy thing to assess. Independent wraps like Novia, Nucleus and Transact are easier because they all report accounts that clearly apply to the platform. Life companies and some of the former fund supermarkets are a different herd of cats. There’s a host of different business models and in some cases the platform is so heavily embedded into the overall company accounting that it’s impossible to extract properly meaningful data. There’s also the issue of how services are charged between different companies in a group – meaning that the platform can bear the cost of group services and be artificially held back from making a profit, if that suits the accountants.

WE NEED TO RELY ON SOMETHING THOUGH

You do, and here is my proposal for a wee checklist that might help. Add and delete from this as you like, these are just my suggestions. Some of this can be researched (for example via Companies House) but asking the platforms as part of your due diligence process is a good place to start.

Insanity big table x

insanity table 2 vX

If a copy of these tables in word format is any use to you, click here Turnover-is-insanity-profit-is-profanity-tables-only

You can interpret the results in a number of ways. If any measures that you deem to be a 4 in importance rate as a 1, it’s likely to knock that platform off the list. You can also do this in a matrix to produce overall scoring – spitting out a ranking of those that have the best match based on your own criteria.

And just to be really, really clear before anyone gets mardy: BUSINESS PERFOMANCE IS ONLY ONE AREA OF DUE DILIGENCE. I’m not suggesting for a second that people go about picking platforms based purely on it. In reality, assessing this stuff is often more about verifying that selections based on proposition have no business performance issues that will scare you off.

Something that is unsuitable for your clients but financially rock solid is still unsuitable.

5 not out

So a big week for me and for the lang cat, although there’s no time to stop and reflect. Yes, this is one of those self-indulgent milestone blogs. Feel free to stop reading.

It’s five years ago this week that I left corporate life and started out on what would become the lang cat. With no kind of money, an additional lang kitten on the way and literally no clue what was going to happen, it was without doubt the scariest time of my life, except when I went on the waltzers. I hate waltzers.

I was lucky to have some very enlightened and trusting early clients – step forward Paul Goodwin and Anthony Rafferty of Aviva (at the time at least), Neil Lovatt of Scottish Friendly and Dave Ferguson of Nucleus. That gave me a start, and got me out of the spare room and into an office cupboard with no windows which was christened ‘the gimp cave’. Days of thunder, I tell you.

Spool forward 5 years and things couldn’t be more different. There are 10 lang cats with two based in a mythical place called England, we work with clients in Ireland, Australia and the USA, and the business now has two specialisms – the consultancy that I kicked off and a burgeoning strategic comms and PR business. “Look, Mum! What’s that business doing?” “Shhh, Timmy, it’s burgeoning. Don’t disturb it.”

Here’s 5 things I learned so far:

  1. People generally want you to do well. Let them, and take the help when it’s there, whatever form it’s in.
  2. Try not to be a prick. When you fail at that, say ‘I’ve been a bit of a prick’.
  3. Hire smart people and don’t forget the fact they could almost certainly get better jobs elsewhere.
  4. Make it about the work. When people ape your stuff, be flattered not cross.
  5. When you’re tired, and you will be if you do something like this, remember what got you going near the start and do what you need to do to get that feeling back.

I’ve said this before, but the lang cat started out as a howl against all sorts of things. We’ve changed and got bigger, but we’re still howling, and we’re not going to stop.

So a glass is raised to everyone we’ve worked for, everyone who’s bought our stuff, and everyone who’s made the jump and come to work here.

As I wrote at the end of our first year: cheers, skol, merci, takk, asante sana. Alla you.

Here’s to the next five years.

Mark

 

The exciting ever changing world of platforms

The exciting ever changing world of platforms.

The current state of the UK platform market is as exciting as it’s been for a long while, and in our view there are some hugely significant changes taking place. Over recent weeks we have seen a number of platforms being rumoured as being up for sale, and a couple of interesting acquisitions on the asset management side. And just today Money Marketing are reporting that AJ Bell have entered into an exclusivity period with Cofunds. The platform market is a-changin’

But as ever the question advisers need to ask themselves is “so what”? Even if you last reviewed your platform due diligence 12 months ago, and I suspect for a few advisers it will be a lot longer than that, the market is in a very different place. It is also highly likely that whoever your platform of choice is they have changed significantly from the last time you formally reviewed them, but “so what”? Is the current uncertainty for a number of big players a concern to advisers, or if not when does it become so? And if it is a concern, what should you do about it? It’s one thing stopping using a platform for new business, but an entirely different issue if you want to start moving existing clients off a platform. When does a change of ownership and/or direction become a problem? We’d love to hear adviser views on this subject.

As challenging as this might be platform suitability needn’t be rocket science. Client needs beat adviser needs with the needs of the provider coming a distant last. Advisers who select platforms based on client needs, and document how and why this decision was made rarely go wrong. Amidst all the excitement of the current platform changes it’s important that advisers don’t lose sight of this fact, and don’t press the panic button too early, but care is needed.

The FCA factsheet on using fund supermarkets and wraps states “Developments in the market could mean that your chosen platform provider(s) may not remain the most appropriate option for your business or clients. You may need to carry out periodic reviews.” It seems to me that the with the largest platform provider potentially changing ownership, the imminent sunset clause, and all the other changes happening, now is probably time for a “periodic review”.

 

 

 

 

What should we do about sequence risk?

Sequence risk has been a hot topic lately and with recent market volatility questions of post-retirement portfolio construction are at the forefront of advisers’ minds.

However, new research from CWC Research produced for the FE Investment Summit later this month, finds adviser attitudes towards sequence risk and its management within retirement portfolios vary widely across the industry.

The research, based on detailed interviews with advisers, finds that while many believe sequence risk is an issue for their clients, not all agree. Within the CWC Research sample, one third of advisers hold no cash whatsoever to manage market volatility, while 40% recommend holding two years’ or more.

Within the responses, Clive Waller, Managing Director, CWC Research, found one adviser recommending seven years’ worth of income in cash or near cash for clients with a low attitude to risk, while another argued that holding a cash reserve reduces the return on the portfolio, making it harder to achieve the benchmark and the portfolio asset allocation, dictated by the client’s attitude to risk, is sufficient hedging of sequence risk.

Such diverse views are confusing for would-be clients and do little for confidence in financial advice. Fortunately, advisers will be able to hear further details of the research at the FE Investment Summit on 22 September and debate best practice for post-retirement investment across all market cycles. Speakers include:

Morning Session – Blending asset management, platform & insurance solutions. What do advisers need to consider?

Clive Waller – CWC Research
Thomas McMahon – Financial Express
Martin Lines – Partnership
Nick Dixon – Aegon
Simon Massey – Met Life
John Lawson – Aviva
Gregg McClymont – Aberdeen Asset Management
Carlton Hood – Old Mutual Wealth
Paul Boston – Novia
Richard Romer-Lee – Square Mile

Afternoon session – The challenges for advisers. How to deliver compliant advice in a commercially viable manner.

Mark Polson – the lang cat
Ian Shipway – HC Wealth Management
Anthony Villis – First Wealth
Malcolm Kerr – Ernst & Young
Rory Percival – Financial Conduct Authority

 

Tickets are free for advisers, and £495+VAT for anyone else

To book your place email shona@langcatfinancial.com.

What will September bring?

If there is one thing I’ve learnt during 20 years in financial services, it’s that August is traditionally a quiet month. Everyone goes on holiday and then frantically crams in two months work into September. Already I can feel the September surge coming through, but this time it feels different. Quite a lot did happen in August, and it wasn’t particularly pleasant.

During August the FTSE100 went down by 9.52% , or 637.74 points if you prefer. Anyone who spent August on a beach away from it all would have had a nasty shock when they logged on yesterday. As well as the traditional accumulating investor there is now a new set of investors for whom August’s events could potentially have been very damaging. The pension reforms, and resultant surge in drawdown investors have created huge debate about the risks of “pound cost ravaging”, and August duly served up a live example of just how damaging market falls in drawdown can be. Any investor who went into drawdown in the first few days of pension freedom would have invested with the FTSE above 7000, or 13.64% above where it’s at now. If ever you needed an illustration of the need to take advice at retirement this is it.

Advisers we speak to are generally very confident about their investment propositions, normally with some sort of centralised investment proposition in operation, but are less confident about post retirement propositions. The rules are changing, there are new products coming to market, and whilst the need for advice has never been greater, how can advisers construct a centralised retirement advice proposition (might need a new name for this…) that is compelling, compliant and commercially viable?

Fortunately, there is a conference later on this month that will discuss all of these issues and more. The FE Investment Summit will explore the issues surrounding post retirement financial planning, with experts from asset management, regulation, insurance and advice.

The day will be structured into three distinct cohorts looking at the post retirement world from the point of view of insurers, asset managers and advisers. The insurer cohort features Partnership, Met Life and Aegon, Asset Management is represented by Old Mutual Wealth, Novia and Square Mile, and the adviser cohort will feature HC Wealth Management, First Wealth and Ernst & Young.

Alongside the cohorts we have 4 keynote speakers, Thomas McMahon from FE, John Lawson from Aviva, Gregg McClymont from Aberdeen Asset Management and Rory Percival from the Financial Conduct Authority.

Throughout the day there will be plenty of opportunity for questions, discussion and challenge from floor, with panel sessions hosted by Clive Waller and Mark Polson. The presenters have been told to expect questions! Tickets are still available…

Tickets

Click here to book your place.

Early bird, prior to 4th Sept

• Adviser individual seats are available at £100 plus VAT.
• Tables (seating 8) are available at £1,950 plus VAT.
• Provider individual seats are available at £395.

From Sept 4th

• Adviser individual seats are available at £125 plus VAT
• Tables (seating 8) are available at £2,495 plus VAT.
• Provider individual seats are available at £495.

• A 10% discount on all adviser rates is available for PFS and IFP members.