Apprenticeship model possible under new regime
Angus Dale-Jones said the new structure, with all financial advice providers able to hire nominated representatives, would offer more flexibility.
“The regime itself is designed to be flexible and allows for the full range of business models and situations and that flexibility of the code and the regime extends to training.”
Under the new regime, a licensed financial advice provider firm can employ a nominated representative who does not have the qualifications required of a financial adviser.
That person can then dabble in advice-giving, provided the provider has the systems and processes to “backfill” any gaps in their knowledge for the service they provide.
At the moment, only QFEs can operate this sort of structure.
Dale-Jones said all the existing ways that people trained advice staff could still be used under the new regime but there would be a further step that would allow an apprenticeship-style system.
“That is allowing nominated representatives to do some discrete parts of advice-giving while they are still training. I don’t think that’s something lots and lots of people will do but for people on a pathway to becoming advisers where businesses want to give them the opportunity to work in discrete advice-giving, then it’s an option for them to do it as nominated representatives.
"That would have to be permitted by the licenses with the finical advice provider. Financial advice providers have to have processes and controls around that to make sure the advice given is at the appropriate level. It’s not something you can do without thinking through the consequences but it’s an additional mechanism, an additional piece of flexibility around training that in the current regime only exists within a QFE.”
He said the working group was still going through the submissions it had received to its draft code.
“That will be subject to any updating and further targeted consultation we might decide is necessary over the next month or two.”