This really is an age-old question, alongside legends such as “why is the sky blue?” and “in the land of Cinderella, why did she have such unique feet that she was the only size in the village, yet the shoe was such a perfect fit, it still managed to fall off?”. I digress, sorry. So, the question of “just what is a paraplanner?” has haunted me at dinner parties, the occupation box on ANY application form and even in my own industry. It’s not one that is easily answered but SM&CR (Senior Management & Certification Regime) has dictated that we give it another bash.
For those not familiar with the new SM&CR proposal, in a nutshell, it is new FCA legislation around ensuring the people in your business who can impact upon the client are properly regulated and appropriate for that role. Senior Managers and Certified People. (Learn more about how our sister company, Apricity, can help you in your SM&CR preparations here).
The Senior Management side of things is pretty easy to define, but the second area; the Certified personnel is slightly more obscure. The relevant factors that firms would be required to consider in assessing individuals include whether the role is simple or largely automated, or involves exercising discretion or judgement.
In essence, the FCA has said it is up to advice firms to conclude whether paraplanners should be considered to hold the Client Dealing Function. The FCA rule has been drafted in a way “that provides firms with the flexibility to exercise judgement on whether a role requires certification” Helpful.
Therefore, it may seem quite obvious for the majority of people in your business. You know yourself who has what impact (planners/advisers) and those who have less impact (administrators etc), but what about that weird hybrid we call the lesser spotted Paraplanner?
In general, there are three species of paraplanner.
Usually found around the same watering hole and highly skilled in client relations, business models and specific investment propositions. They tend to have the larger impact on your business and depending on the genus of your particular paraplanner, are the most likely to be needing certification. This is especially important if they are involved at any decision level of the advice process or if they contribute to any investment proposition choices.
These tend to roam around the habitat and are curious creatures. They taste a lot of different foods and specialise in a number of different providers, investment strategies, tax areas and financial planning solutions. They tend to be less involved with the client, interacting more with the adviser and thus tend to have less impact upon the decision making of the business and are less likely to require certification.
The third is the middle ground. The Liger, if you will. Those paraplanners who are either inhouse but make no decisions and perform more administrative duties or are just essentially report writers; or the outsourced paraplanners who have such a strong relationship with the adviser they do assist in decision making and can impact upon the end client.
Essentially, it will be up to adviser firms to decide whether your chosen paraplanner should be considered a certified employee and whether or not they should be included in the second tier level of the SM&CR rules. My advice is to use discretion, but to err on the side of caution. If you think they may have any impact, have them certified. It can’t hurt. Unlike Ligers which apparently can hurt you. (I appreciate I’ve stretched this metaphor really far now and am going to leave before I turn full Attenborough and start preaching about how we should recycle paraplanners to stop turtles getting their noses stuck in them).