QAR: does the first tranche cut it?

It just doesn't cut it! That is my personal opinion.

After speaking with Advice Groups over the past year, whenever QAR was mentioned it was always 'can't wait to see changes to the SOA requirements' and 'what can we do once SOA is a thing of the past'. This was a clear and exciting prospect for Advisers. An opportunity to create documentation for the purpose of the client and not a legislative requirement built by licensees and compliance officers. 

I am still hopeful for what the future will bring in the SOA space, but to see it missing in the first trance is disappointing.  

It was definitely disappointing that the removal of the Best Interests Duty safe harbour and the rationalisation of SoAs was not in the first package of QAR draft legislation, however a lot of work has been done on both of these critically important initiatives, so hopefully they will not be far behind.  We knew they would not be in the first package, but disappointing nonetheless.

The one big thing in this first package was the removal of FDSs, however I guess this does not count for much if you had transitioned your business over to annual agreements.  Hopefully the second package is not far off and will generate more excitely from the advice profession.

The removal of the FDS is of little benefit to us.  We use ongoing agreements and it is the duplication and handling of consent that causes us the most headaches and it does little for that.  I hold out little hope that product providers will agree to use our consent forms, or will insist on pages of ridiculous butt covering disclosure be included at the expense of clarity if they do.