Your client proposition changes considerably if you remove the full advice and recommendation service under service level 3.1(a) of the code. The role of an IFA is an advice-giving one, and I seriously question whether the provision of information-only by a broker is ever going to satisfy the expectations of the typical consumer. Most members of the public rightly assume a broker is searching the market options, applying their experience, then making a clear recommendation.
Given the regulatory landscape it is not surprising many brokers are contemplating a shift to information-only. Recent Mortgage Code Complaince Board registration renewal has seen a significant number of firms indicating they will no longer offer advice to customers, instead taking cover under service level 3.1(b).
This is dangerous as consumer detriment is more likely as a result of clients misunderstanding the role of the broker and the fact information-only service offers them no protection or redress. You must work out a way to continue service level 3.1(a), by complying with the requirements for trainee advisers and supervision.
Hundreds of brokers are in the same position as you and do not have an appropriately trained and qualified supervisor. But it is quite clear that a number of options will unfold in the marketplace, such as outsourced supervision services for small firms ‘ so watch this space.
Your unqualified advisers must be given every assistance and incentive to obtain the qualification ahead of the deadline. There are a number of CeMaP courses available as well as ongoing training programmes offered by networks and franchises.