Tag Archives: AF9

inclusive financial planning

Vulnerable clients

Vulnerable clients are what the CII’s Inclusive Financial Planning Exam is all about. So if you are planning to sit it, this blog’s for you. I will focus on just two key questions – what is a vulnerable client and where can you find the resources to answer the assignments?

If you want to know more about the CII’s Inclusive Financial Planning exam, click here.

Before I start, please note that this blog does not refer to any specific Inclusive Financial Planning exam assignment. The CII rules preclude a third party from providing any support to you that is specific to your assignment.

What do we mean by a vulnerable client?

For many people, a vulnerable client is one that has an illness or is over a certain age. By definition, this only applies to a small proportion of clients in a typical firm.

But make no mistake – vulnerable clients is a key part of the FCA’s current and future agenda. Why? The Financial Lives Survey 2017 identified that around half of UK adults have one or more characteristics of a vulnerable person. Wow – half your clients are likely to be vulnerable in some way.

How so? The FCA have set out four broad characteristics of a vulnerable client. Some of these will be easily understood – particularly those under the heading of ‘health’. But what about a ‘life event’ such as retirement?

Vulnerability might include those who are forced to retire early through ill-health or those in drawdown who take a high rate of withdrawal. What about people who have limited experience of financial matters or those that realise (too late) that they don’t have the income they need in retirement?

This image has an empty alt attribute; its file name is FCA-vulnerability.png
Source: based on FCA GC19/3, July 2019

The more you look into this subject, the more you realise it is likely to apply to most of your clients at some stage of their life.

So what does your firm do about it? How well do staff understand ‘vulnerability’ and how do you treat customers differently because of this? How do you recognise vulnerability and record it? If you are responsible for the advice process in a firm, what should governance and oversight look like? These are the sort of questions that the CII’s Inclusive Financial Planning exam is likely to address.

Resources for Inclusive Financial Planning

Where do you start researching for this exam? When you enrol, you will have access on the CII’s RevisionMate system to the study texts for CF8 (Long term care insurance) and ER1 (Equity release). It is possible that a specific assignment will include a client who is considering, for example, equity release or an immediate needs annuity but this is very much assignment-specific.

Reading the Assignment exemplars and guidance provided on RevisionMate should be compulsory reading for everyone sitting this exam. They show how assignments should/should not be set out and are the closest thing there is to an ‘exam guide’.

Other than the two study texts, the Inclusive Financial Planning exam does not provide any suggested reading. A level 6 exam such as Inclusive Financial Planning is degree standard. This means you’ll need to undertake your own research and work so you’re going to have to use the internet widely. Here are some suggestions to start you off (as at Nov 2020):

Customer Vulnerability (Occasional Paper Number 8), FCA, February 2015

Guidance for firms on the fair treatment of vulnerable customers (GC19/3), FCA, July 2019

CII CF8 Study text (available via RevisionMate) – the content in Chapters 7 and 8 will apply to many scenarios in some way.

Understanding the financial lives of UK adults, FCA Survey, 2017

Treating vulnerable customers fairly, FCA website and video

Ageing population and financial services, FCA Occasional paper number 31, September 2017

Addressing customer vulnerability, guide, ABI website

Vulnerable clients, Just Retirement website and video

Meeting the needs of vulnerable clients, PFS Good Practice Guide, 2017

Forces Moneyplan initiative, PFS, website

Assignment 1 will have a heavy technical emphasis so specific technical research may be needed for this assignment. Suggested sources include:

Just retirement

Scottish Widows

Prudential

Techlink Professional

Remember that things constantly change so use these references as nothing more than a start.

I hope that this this has been useful and gives you a starting point. If you want to know more about the ‘technique’ required to pass a Inclusive Financial Planning assignment, click here.

Ian Patterson

Ex-examiner and author of the current CII study texts for CF8, J07 and AF6.

inclusive financial planning

CII: Inclusive Financial Planning

Inclusive Financial Planning is an assignment-based advanced diploma exam that is currently being piloted by the CII.

This is an interesting addition to the other two current assignment-based CII exams – AF6 (Senior Management and Supervision) and AF8 (Retirement Income Planning). This is all welcome news to those of you that don’t like the traditional 3 hour written exam format.

The style of these exams is a very different challenge to the traditional written exam. I’ll look at some essential background and then give you our top 10 tips to help you approach this exam.

What is inclusive financial planning about?

This is about dealing with vulnerable clients. It is a topical area given that it has been highlighted in the FCA’s business plan for the past 2 years as a key element of consumer protection that applies to all firms. There is no doubt that this important area is attracting much wider interest.

Although elements of CF8 could help with the Inclusive Financial Planning assignments, it is NOT a glorified version of CF8. The syllabus has four broad areas:

  1. The technical knowledge that is required to advise in various vulnerable client scenarios. As you might expect, this could include areas such as living wills and LPAs. It might equally look at how pension benefits are treated in the event of ill-health and a range of different other scenarios.
  2. Identifying and addressing the issues that may affect the provision of financial advice for vulnerable clients.
  3. The governance and oversight of appropriate procedures for vulnerable clients within regulated firms. The FCA require all firms to have suitable procedures but what should these look like? How do you know if they are working and how do you measure this?
  4. A corporate responsibility policy and establishing an appropriate business strategy. How do you embed the process of dealing with vulnerable clients within the wider culture of the business? Do you approach vulnerable clients in isolation because you have to, or as part of a wider policy that might include community engagement and partnership arrangements?

Why sit the inclusive financial planning exam?

The glib answer is any CII member who wants 30 credits towards achieving Chartered status. If you also pass AF6 and AF8, then you have 90 of the 120 additional level 6 credits that you need to get to chartered status. And you will have achieved this without having to go anywhere near an exam hall (or remote invigilation nowadays)!

As this is a pilot, you will have to register your interest before being allowed to start. Click here to do so. You may have to wait, depending on demand.

Please don’t regard this as an ‘easy AF option’, it isn’t. Unless you’ve already completed AF6 or AF8, it is a very different experience. In addition, CF8 is a level three exam; Inclusive financial Planning is level six. You have been warned.

What’s the format of the exam?

There are three assignments, each of around 2,500 words. You’ll need a mark of 50% or more to pass each of them and you have 12 months from the start date to complete them. Note that this timescale includes any re-submissions.

Support material is relatively limited. You’ll get the syllabus, guidance on how to complete the assignments, and exemplars. There is no study text like AF6 and AF8. Inclusive financial planning is a degree level exam so you’ll need to get on the internet to research the content.

Assignment 1 seems to cause the most difficulties. This includes a completed fact find along with the assignment. This is where your technical knowledge of dealing with vulnerable clients is primarily tested. Anecdotal information suggests that if you provide any incorrect knowledge, particularly any that could be detrimental to a client, you will be penalised so be very careful what you say.

Assignments 2 and 3 cover government and oversight, and the business strategy in some way. Although technically less demanding, these test a broad range of themes that most people will have limited experience of.

This exam also allows you, uniquely for a CII exam, to apply assignment 2 and 3 to your own firm, as an alternative to the assignment. Hat’s off to the CII for trying to make this as relevant as possible to both you and your firm.

Unlike written CII AF exams, there isn’t a ‘model answer’ where you only get a mark if your answer is on the model answer. Instead, the marks are allocated based on:

  1. Knowledge and understanding – 25%
  2. Application and analysis – 50%
  3. Coherent structure – 10%
  4. Relevant examples and wider reading – 5%

A word of caution

I’ve already mentioned that there is only limited study support available. This also applies to commercial training providers for two reasons:

  1. The exam is still very new and in it’s pilot phase, and
  2. Training providers aren’t able to provide direct support on the specific assignments you are given. The assignments you complete have to be your own work without assistance. In other words, any other support is likely to only be generic. This can feel a little uncomfortable for some people. Click here to watch the CII video on what is plagiarism.

Because of this, The Patterson Group does not provide individual support for Inclusive Financial Planning. The generic support provided in this blog is as far as we go. We want you to pass and we’re here to help as much as possible – with this and your other CII exams.

Inclusive Financial Planning: top 10 tips

Here are our top ten tips:

  1. Start early. With 12 months to complete three 2,500 word assignments, it sounds like a breeze. This isn’t the case because once you’ve submitted your assignment, the CII could take up to 40 days to mark and return it (40 days x 3 = 120 days = 1/3rd of a year) Sensibly, you wouldn’t submit your second assignment until you have received the result from the first assignment. This means that you need to start quickly and be structured in how you approach these assignments.
  2. Finish early. The 12 month timescale starts when you enter the exam and finishes once you’ve passed your final assignment. If you submit assignment 3 after 11.5 months and don’t pass, you have no time to re-submit and will fail. All three assignments need to be passed within 12 months so submit assignment 3 by month 10 to be on the safe side. In our experience, many people who sit the assignment-based CII exams will need to resubmit one or more of their assignments so build in time to do so.
  3. Always focus on the marks. There is little point in demonstrating a huge range of examples and wider reading when the most you’ll get is 5% of the marks. If you fail an assignment, it will probably be because your knowledge is limited or inaccurate, and/or because your answer is too generic rather than addressing the scenario provided. More about this next.
  4. Show your analysis and application. Over half the marks are awarded for analysing and applying knowledge. This means that you must link your knowledge to scenario you are given. Showing the benefits and drawbacks of something is a good way of demonstrating critical analysis.
  5. Do as you are told. If the assignment asks you to write a formal report, do just that, i.e. write an introduction, executive summary, main content (the way the assignment is worded will usually give you a good structure for this), recommendations (if required) and conclusion or where next. If you are asked to ‘assess’, don’t go into making recommendations – you haven’t been asked to and you’ll fail to gain those valuable marks.
  6. Link your answers back to the client(s). This applies to all three assignments: if information is provided, expect to use it in some way. Remember that 50% of the marks are given for your analysis and applying your knowledge. In particular, assignment 1 includes a client fact find document which is likely to have a degree of complexity beyond that of, say AF5. Ask yourself ‘how can I use this information?’. It’s been provided for a reason so don’t just give generic answers. Provide solutions to their problems.
  7. Demonstrate your wider reading. Make sure that you show lots of citations and wider reading – nine or more relevant examples that demonstrate your own research.
  8. Use the CII specimen assignments (exemplars).  These are a must. If you’ve not experienced CII assignment-based exams before (or even if you have), these provide great examples of what to do, and what not to. These are the best way of understanding what your assignments should look like.
  9. Use your word count + 10%. Each assignment will state a maximum number of words but you are allowed to go 10% over without being penalised. Make sure you do. If your word count for an assignment is only 1,400 words when the max is 2,500, you are unlikely to pass.
  10. Don’t cheat. This sound pretty obvious but you need to be clear how the CII define plagiarism. To quote the CII: ‘Writing of assignment responses must be done individually without collaboration of any kind.‘ Exchanging notes with other people sitting the exam or copying material without referencing it may fall foul of this. Next time you get a CII magazine, notice how many people have been disciplined for plagiarism across the range of CII exams – they can and do catch people out.

We hope you find this useful. If you want to know more about our range of study support when you sit other CII AF and R0 exams, click here.

Until the next time…

Ian Patterson

Ex-examiner and author of the current CII study texts for CF8, J07 and AF6.

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