Q: Who should be included in the ‘Total number of employees’ figure?
A: This should be the total number of employees[1] that worked for the firm as at the end of the reporting period even if they do not advise retail clients. You should not include employees that may have worked for the firm during the period but are no longer employed at the end of the reporting period.
Q: Who should be included in ‘Number of employees that give advice in each area’?
A: If employees advise in relation to more than one business type (advising on mortgages, advising on non-investment insurance, advising on retail investment products or advising on second (and subsequent) charge mortgages), you should count them in each applicable field. For example, if the same adviser provided advice on non-investment insurance and mortgages, the adviser should be counted in both Column A and Column B.
Note: in relation to advising on non-investment insurance, this total should not include employees that do not advise retail customers.
Q: Should I adjust the ‘Number of individual advisers employed by the firm’ to allow for part-time employees or those who advise in one or more areas?
A: No, the total should be the number of individual advisers employed by the firm, regardless of whether they advise in one or more areas. You should count each individual once.
Q: What should I enter for ‘Number of employees that give advice (FTE)’, is it not the same as the previous line (Question 26)?
A: The answer here uses the same data as line 26 but expressed in ‘full-time equivalent’ terms. For example, if the firm has 20 part-time employees that work 50% of normal hours, the figure would be 10.
Q: Who should be included in the ‘Number of employees that supervise others to give advice in each area’?
A: Firms should include all employees assessed as competent to supervise others. If any of these employees carries out supervisory activities in relation to more than one business type, you should count them in each applicable field. For example, if the same employee supervises others to provide advice on non-investment insurance and mortgages, you should count the employee in both Column A and Column B.
Q: Should I adjust the ‘Number of individual advisers employed by the firm’ to allow for part-time employees or those who advise in one or more areas?
A: This should be the number of individual supervisors at the firm, regardless of whether they supervise in one or more areas. You should count each individual supervisor once.
Q: Who should be included in the ‘Number of advisers assessed as competent by the firm in each area’?
A: This is a subset of ‘number of employees that give advice in each area’ in Question 2. If employees are competent in relation to more than one business type, you should count them in each applicable field. For example, if the same adviser provided advice on non-investment insurance and mortgages, the adviser should be counted in both Column A and Column B.
See TC Appendix 1.1R in the FCA Handbook for the detailed training and competence requirements relating to individual activities.
Q: For ‘Number of advisers assessed as competent in one or more areas’, should I enter the total of the figures I entered in Question 5 (‘Number of advisers assessed as competent by the firm in each area’)?
A: No, this total should be the number of individuals assessed by the firm as competent in one or more of the four business types specified in columns A-C and E. You should count each individual once.
Q: Why do you need the ‘Number of fully qualified advisers’ for Question 18 when I will list the advisers later in the return?
A: This question requests the total number of advisers holding appropriate qualifications to carry on activities 2, 3, 4, 6, 12 and 13 in TC Appendix 1.1.1 R (other than Holloway sickness policy). Later on, in question 24, you will need to provide details of all advisers at the firm, including those who are part qualified or hold a valid Statement of Professional Standing (SPS).
Q: Who should be included in the 'Number of advisers holding a valid Statement of Professional Standing (SPS)'?
A: This should be the number of individual retail investment advisers holding a valid SPS from an accredited body[2].
Q: Who should be included in the 'Number of advisers that hold an appropriate qualification in each area'?
A: This is a subset of the ‘number of employees that give advice in each area’ (Question 2). Where advisers have appropriate qualifications in relation to more than one business type, you should count them in each applicable field. For example, if the same adviser provided advice on non-investment insurance and mortgages, the adviser should be counted in both Column A and Column B.
Q: Who should be included in 'Number of individual advisers holding at least one appropriate qualification'?
A: This should be the total number of individuals holding at least one appropriate qualification for advising on mortgages, acting as a retail investment adviser, or advising on second (and subsequent) charge mortgages. You should count each individual once.
Q: Who should be included in 'Number of employees that left the firm during the reporting period'?
A: This should be the total number of employees whose last day of employment fell within the reporting period.
Q: Who should be included in 'Number of advisers that left the firm during the reporting period'?
A: This is the total number of advisory employees whose last day of employment fell within the reporting period.
If any of these advisers used to carry out advisory activities in relation to more than one business type, you should count them in each applicable field. For example, if the same adviser provided advice on non-investment insurance and mortgages, the adviser should be counted in both Column A and Column B.
Q: Who should be included in 'Number of individual advisers that left the firm during the reporting period'?
A: This should be the total number of individual advisers whose last day of employment fell within the reporting period. Each adviser should only be counted once.
Q: Should I register a ‘Yes’ or ‘No’ answer in all the cells related to types of advice provided for non- investment insurance?
A: Yes. If the firm has provided non-investment insurance advice in the reporting period, the firm should indicate on what basis it was provided by selecting either ‘Yes’ or ‘No’. The choices are:
- Fair analysis of the market
If an insurance intermediary informs a customer that it gives advice on the basis of a fair analysis of the market, it must give that advice on the basis of an analysis of a sufficiently large number of contracts of insurance available on the market to enable it to make a recommendation, in accordance with professional criteria, regarding which contract of insurance would be adequate to meet the customer's needs. (See ICOBS 5.3.3R, ICOBS 4.1.6R and ICOBS 4.1.8G). - Restricted – multi-tie
A firm provides advice on products selected from a limited number of provider firms. - Restricted – single-tie
A firm provides advice on products selected from one provider firm only.
Q: Should I register a ‘Yes’ or ‘No’ answer in all the cells related to types of advice provided for mortgage and/or second (and subsequent) change mortgages?
A: Yes. If the firm has provided mortgage and/or second (and subsequent) change mortgage advice in the reporting period, the firm should indicate whether the firm has provided advice for each type of advice by selecting either ‘Yes’ or ‘No’. Please refer to MCOB 4.4A when answering these questions.
Q: Should I register a ‘Yes’ or ‘No’ answer in all the cells related to types of advice provided for retail investments?
A: Yes. If the firm has provided retail investment advice in the reporting period, the firm should indicate on what basis it was provided by selecting either ‘Yes’ or ‘No’. The choices are:
- Independent
For a retail investment firm to provide independent advice its personal recommendations must be based on a comprehensive and fair analysis of the relevant market, and be unbiased and unrestricted (COBS 6.2A.3R). - Restricted
A retail investment firm provides restricted advice if:
(a) it makes personal recommendations to retail clients in relation to retail investment products which are not independent advice; or
(b) it provides basic advice.
Q: Do I need to complete all the ‘Adviser ID’ columns?
A: No, there are a variety of fields we use to identify new retail investment advisers (RIAs), while also allowing existing RIAs to continue using their Individual Reference Number (IRN).
Therefore, if an RIA has no IRN, please enter their date of birth and NI number. If the adviser has no NI number, please provide their date of birth, passport number and nationality.