I'm sure many of you have been thinking about the challenge of a locum adviser in your business, given that it is part of the licensing requirements.

This isn't expected to be a significant challenge for those with multiple advisers in their businesses. For the sole operators, it's a little more interesting.

The first challenge is finding an adviser you can trust who can assist if you're incapacitated, or away for a holiday. Which on paper is probably the more straightforward thing to arrange.

The second aspect is having that adviser actually step into your business and sit in your seat. It's not as easy as everyone thinks.

Sure, getting your locum access to your email, usernames and passwords for providers and operating on that basis is just a technical process.

The more interesting piece is operating as you.

Let's look at the FSPR/licensing side of things first.

For your locum to be able to advise your FAP's clients, they need to be added to your FAP because they aren't your clients. If you have a Class 1 license, you have to remove yourself and add them, as Class 1 is only a single adviser.

This not only takes time but what happens to your registration while it's suspended? You must be reconnected to a FAP in a specific timeframe or get deregistered. How does this impact your professional indemnity coverage?

The next bit is documentation; you have many document templates in your business with your name on them, all of which need to be updated or duplicated and updated for your locum.

Once you have that taken care of, then your locum is good to go, right?

Not so fast. What about your provider relationships?

Yeah, those. It's easy enough to sit behind an existing adviser's email and portal/quotes accounts and operate; what about when you have to interact with the provider? Then what?

Because your locum is not you, they have to be independently verified. Your locum can't rock up and pretend to be you; that has professional issues. Not to mention the liability issues for you if they act as you. This applies to sitting at your desk with your email and portal accounts too.

Especially when it comes to claims, as this is the area where the client/adviser relationship will be most tested for needing an adviser in a locum situation. It's not just new business; it's the servicing that goes on where an adviser is required.

Presently, whoever thought up the locum requirements either doesn't understand what fraud is, or they do not appreciate the operational issues advisers have within their roles. The current approach of handing over accounts and access bypasses many fundamentals of existing legislation as well as the latest FSLAA requirements.

And this extends out from insurance to all financial services disciplines. Mortgage and investment, how comfortable are you, and your providers, with someone sitting in your seat being your doppelganger without any verification?

Taking this to the extreme, does this mean providers don't have enough verification on email and portal transactions? (No, I don't want more, what we have has already driven me to the edge).

The biggest issue in the locum's area is the provider agency access and management. The providers are not prepared for this, nor do they appreciate how difficult it could be.

Those that have worked through the sale and purchase process for a client base transfer will have some idea; that process is bloody awful.

This means you need to arrange for your providers to have authority enabled for your locum but not full-time complete access—only access when they have been triggered as your locum.

And you only want this access while they are a locum, so it needs to be turned off again when you're back in your seat.

This is a massively onerous task and process for the providers. In many cases, it will need the implementation of additional agencies with providers as advisers have a range of providers and agencies, and not everyone has every provider.

Even if we ignore the provider aspect, every time you trigger your locum, you need to be able to turn access off; this means you need to change passwords to ensure they can't get in if not authorised.

And what about 2FA, Two Factor Authentication, which is tied to your phone with an app or your phone number with text messaging?

The layers of authorisation, management, technology, and security are significant, and I think few have really thought them through.

Lastly, what about your PI, dispute resolution, and disclosure management? Does this drive additional memberships or extended coverage? And at what cost?

How are you going with all of this? As I'm looking at it going, this is nuts.

The frank reality after being on a disability claim for 18 months myself, the 10-hour clause became very important to cover off the basics and keep things moving. I had an associate at the time too.

Without that, actually bringing in a locum adviser would have been more onerous than the medical claim I was dealing with.

Do we need good business continuity plans? Yes. Do we need good locum plans? Yes. But the stark reality presently is that the reality is unworkable for single adviser businesses, especially if they are dealing with a medical crisis or are no longer with us.

The providers have to be involved in this, and they will have to spend money on their systems to make this work. The average adviser business can't sort this out on its own. Frankly, even larger adviser businesses will have their issues, as agency security and access is still problematic between advisers in the same business and office at times.

And yes, another thing that makes the cottage industry of financial advice harder.