‘Not sure’ is the very brief answer. A slight longer answer might be ‘not sure there is such a thing’. On balance I’d probably opt for the second slightly longer version.

In the run up to RDR, the adoption of processes that can be brought in to the business and costed will help organisations understand what they could reasonably charge as a fee that is fair and reasonable to the customer whilst generating at least a normal profit for the adviser and their business.

To some, technology is seen as a major part of the answer, and in many respects they are right. It should help establish a move towards best practice, better collection and collation of data. Tools can be incorporated more easily and, in turn, the review processes supported and potentially shortened by the clever re-use of data that was captured previously on the system.

Fact Finds can be extensive and thorough and reports can even be built to cater for particular interpretations of the legislation.

But that’s also the problem. The FSA to the best of my knowledge have yet to endorse any technology and award it a  ‘compliant’ badge. Rather they have looked at tools and questioned some of the way that the conclusions have been reached.

It seems like the FSA want to know that the process adopted by the advisory practice is robust rather than the system itself. If a system has failed to capture all the info that the FSA require, is that the system’s fault? I would argue no, it’s not, but it’s something that the system can then amend to better reflect this interpretation. I don’t believe there’s a system out there that would ever claim to be compliant.

What instead should the system do? I believe it should deliver support for the sales and advice processes. There’s a diminishing argument for systems just to be point of sale, or just CRM or just back office, a system should be attempting to bring these elements together so that the adviser knows that the process available is tightly knitted together by the same technology. Here at Focus that has long been our aim. Even to the point where Focus have developed focus:progress which supports adviser’s CPD, training and development needs. But we would always shy away from tagging it with the compliant badge.

It’s the advisory practice that is regulated by the FSA and the buck stops with them when the FSA are conducting a compliance visit. The services they take from their network or support services firm are there to help them in this respect, and systems also need to be listening closely to what these organisation say and how they interpret the FSA’s steady stream of comments.

Systems need to take responsibility for keeping in line with the legislation and the interpretation of FSA consultancy papers. They need to ensure that they create not a sea of un-navigable spaghetti, but a clear process that can support a firm’s interpretation of what they need to do to create a complaint case.

To this end systems in the intermediated world may never be compliant, merely always trying their best to create a process which supports those who have to be.