Nikki Bennett of regulation experts UKGI talks through what happens after you return your application to become an Appointed or Introducer Appointed Representative with Golden Charter. She explains the process and addresses myths and misconceptions.
Malcolm Flanders [00:00:04] Welcome to the Partnership Podcast. Today we're looking at the next step in our joint journey into regulation. Now that the majority of independents who sell Golden Charter plans have returned appointed, or introducer appointed, representative applications, we can look at what comes next. To do that, I'll be talking to Nikki Bennett of UKGI, our expert regulatory partner, which has over 17 years experience guiding non-regulated businesses into regulation. Some of you will have heard Nikki answering your questions on our recent webinar. Many of you will be hearing from UKGI now as they continue your journey. Today we'll talk about what that involves, and answer some of the questions that independents have asked.
Malcolm Flanders [00:00:49] So, Nikki, nice to see you again. How are you?
Nikki Bennett [00:00:52] I'm very well, thanks Malcolm. Nice to see you again.
Malcolm Flanders [00:00:55] Excellent, and I suspect you've been a tad busy, haven't you, the last two or three weeks?
Nikki Bennett [00:00:59] Ever so slightly. Very busy. All positive, but very busy.
Malcolm Flanders [00:01:03] Excellent. Well, thank you for joining us on this podcast. And this is sort of two or three weeks after the webinar we held with you, which was very, very useful, I know, to our partner funeral directors. So, look, Nikki, if I may, could you give us a brief explanation of what UKGI's role is in all of this? You're working with Golden Charter as a regulatory partner, but what does that mean for funeral directors who are applying as ARs and IARs?
Nikki Bennett [00:01:30] Okay, so we are, as you said, a firm of compliance consultants. Our job primarily is to translate anything which could be considered complex, into something that's very practical. My team are a team of natural fixers and helpers, and we've taken time to understand the complexities of the funeral planning world, and appreciate that very rarely are things the same from one firm to another. And for us, that makes it more interesting.
Nikki Bennett [00:02:00] But we've been working with Golden Charter since 2019, and the most critical part of that relationship is understanding Golden Charter, but also understanding how they work with their customers, and their funeral directors alike, so that we can get under the skin of the business, and make sure that before we start working with funeral directors who are going to ARs, or IARs, that we really understand them, and we hope that we can work with them in a way that it sits with what they already do.
Nikki Bennett [00:02:33] Everybody, Golden Charter, and the funeral directors alike, all have a desire to do the right thing, because it's the right thing to do. And our job is to make this journey quite simple. You've made the decision to go at it, you've filled in your application. It's not something to fear. But our job is to take any confusion, or anything like that, out of it, communicate in a way that makes everybody comfortable, and they understand, and know that we are there to hold their hand, and to provide that support, as much or a little as they want really.
Malcolm Flanders [00:03:04] That's very helpful. Thanks, Nikki. Okay. So how prepared do you think Golden Charter is for regulation, in your experience, and how prepared are independents by extension? Are we doing the right things to prepare independents?
Nikki Bennett [00:03:18] From all of the firms that we work with, and those that we know in the sector, I think Golden Charter have been incredibly professional in their approach to regulation. And I'd like to think that the regulator has seen that in them. They've taken time to understand the regime, in plenty of time, which has allowed them all of that headspace to prepare properly, and to go at things professionally, in a very practical and pragmatic way. And given that that's our general approach, I think that's why we get on so well.
Nikki Bennett [00:03:51] The whole ethos of Golden Charter, and the funeral director community, has had good outcomes for all of their customers. That just naturally aligns with what the FCA is trying to achieve. And we've seen that, in working with Golden Charter, and working with the funeral directors we've worked with already. It's not something that we've had to try and train in. It just comes naturally, which is a which is an absolute joy.
Nikki Bennett [00:04:16] I think Golden Charter have made it really clear that we are an extension of them, and the natural inclination for any funeral director is to do the right thing for their families. So there's a lot of thought gone into the process of how we can engage with very busy funeral directors.
Nikki Bennett [00:04:35] In the pilot we were very grateful for the feedback that we got, so that it allowed us to tweak anything that needed tweaking, to make things a bit more simple, or to go over things that in a way that made it easier to understand. To take out any hesitance there might be. So we were very grateful for that feedback, because we do appreciate that this can seem overwhelming, or a bit intrusive, and our job is to have those open discussions and provide that reassurance as we go through this journey. So, so far I would say that it's been very well handled.
Malcolm Flanders [00:05:11] Great. Just on the point you made around the pilot. I think we actually involved quite a few funeral directors there, didn't we, and deliberately test the processes you designed?
Nikki Bennett [00:05:21] We did. And the purpose of that was to test. Test the structure that we built, test the processes that we put in place. But actually, to ask for that feedback, to get their engagement to say, "is there anything we need to change? Is there anything that we could have made clearer? Is there things that we could have made simpler?" And we've taken all that, and built that into the new process. So we're now working in the next tranche of firms, and we've built all of those fixes in before we started that journey.
Malcolm Flanders [00:05:51] Great. Thanks, Nikki. Can you talk through the checks that we need, in a bit more detail for us, and address a few common concerns? Now, some of the questions funeral directors asked you at the webinar were whether all staff needed to be approved and regulated? And what would happen if they changed their mind on anything after speaking to UKGI?
Nikki Bennett [00:06:12] So the process that we've built in place is that you'd have gone through some initial checks as part of your application, to make that decision as to whether or not going down the AR, or the IAR, route is for you. So for those of you who've done that, congratulations. You're now going into the hands of my team, who will take you through the next part of that journey.
Nikki Bennett [00:06:32] When we start that journey, we'll introduce ourselves via an e-mail. We'll set out what to expect on that journey. You'll have an introduction to the team, and basically we will set out what to expect in the journey. So we'll be gathering information about key individuals, we'll be gathering information about the firm. And we try to do it in a very succinct way. Rather than sending out the forms to be completed, sometimes we'll simplify it. We'll gather that the information, and populate that information for you.
Nikki Bennett [00:07:03] There are aspects of it which, the information is sensitive. So rather than us completing it, you will be asked to complete it, and we'll simply verify that you are the person who has completed that information. And we do that over the likes of Teams. We ask you to just show us your your identification, your passport for example, and we can say, "yeah, that absolutely is the person that we think it is."
Nikki Bennett [00:07:25] But we try to manage your time best. So when we start to engage, we'll ask you, what's the best time for us to try and speak to you? When would it be most convenient? We know that you're going to be busy and we will ask, if you can do that, we appreciate that you could be pulled away at short notice. Families will come in, etc. and they absolutely have to have priority. So we'll always try and find out when is the best next time to speak to you, so that we can give you the time, and try and do it all in those calls, rather than keeping toing and froing.
Nikki Bennett [00:07:57] So if we are calling, and you're not available, we will leave a message that says it's us. You are expecting our call, because we know your team will do the best to try and filter interference and calls that aren't necessary. So if you let them know that you are expecting a call from us again, that helps, and we will just try and make it as simple as possible.
Nikki Bennett [00:08:21] But you're right, the checks are around the firm and those key individuals. And it's the key individuals who are the ones who need to be regulated by the FCA. So they're the applications that we make. Everybody does not need to be approved. And so you don't need to think that you've got to put everybody who works within a funeral director through an application. Absolutely not. You don't. That's something to not worry about already. It's just the critical individuals who need to be on the register.
Malcolm Flanders [00:08:52] Yeah. And actually, as you were talking, if I was a funeral director, what happens next year? Is it a similar process or is it a lighter touch?
Nikki Bennett [00:09:01] Yes, very much lighter touch, breathe, take a sigh of relief. The initial checks are designed to make sure that those firms who are suitable, who want to go into this journey, the initial checks are a little bit more stringent to make sure that we go, "yeah, they are the right firms to work with, we've done all the right checks." And that's the initial due diligence done with.
Nikki Bennett [00:09:23] On an ongoing basis, that relationship is just about making sure that if anything's changed, that we need to be aware of, or that there are things that might mean something needs to be different. So maybe somebody decides to be an IAR, is very comfortable, and then wants to transition, they're the kind of conversations that we may have. So it's just about making sure that due diligence hasn't been impacted by changing circumstances. There aren't any concerns arising out of the information that was seen, so there'd be ongoing checks. And they're the basis of the information that we gather. You won't have to go through this process year on year, at all.
Malcolm Flanders [00:10:03] Excellent. Thank you. And just one more on that process. Am I right in thinking that irrespective of which plan provider you're with, these questions and checks are going to be very similar, because they stem from what the regulator requires?
Nikki Bennett [00:10:16] Absolutely, they should be. And so the information that's being asked for, whilst some of it may well feel a bit intrusive or a bit sensitive, the FCA sets their stall out quite clearly in what they expect of the likes of Golden Charter to do. And it is part of the ongoing protection of the ultimate, the customers, the families, that buy funeral plans. So there is nothing being asked that is being asked out of sheer nosiness or curiosity. All of the checks that are being done are there, driven by what the regulator expects, not out of what we think we'd like to see, or what Golden Charter would like to see. It's all required information, and it's treated with that right level of sensitivity and privacy.
Malcolm Flanders [00:11:01] Fantastic. Now, by the time funeral directors hear this podcast, lots of work will have already begun. And I know that following a successful pilot exercise, as we've talked about, to test the process, you've now started working with hundreds of funeral directors, taken through this due diligence stage. Could you tell us how that engagement with funeral directors is going?
Nikki Bennett [00:11:21] I think it's going very well. I think that the feedback we've had on my team is all very, very positive. I think we're all, like I say, very reassuring in what we're going through. We give firms the time that they need, and any concerns around, for example, the sensitivity of the information being asked, we'll provide the reassurance about why we're gathering it, how safe it is. Any of the information we collect is stored safely and belongs to Golden Charter. It will all be given back. We don't we don't keep it, or anything like that.
Nikki Bennett [00:11:54] But I think the team have found that we've been on the other side of things. We understand how this can feel, and our job is to be reassuring. So it's gone very well. We've been sympathetic to the challenges. We've seen that challenge. You know, "we need to go, we can't carry on with the call." "Not a problem. Let you know when it's convenient. We'll call back again." And we're just managing that relationship. And I think the feedback we've had has been, "actually this wasn't how I thought it was going to be. It's been more straightforward, and I understand why you're asking for what you're asking for, and I know when you can't see information that I'm bothered about.".
Nikki Bennett [00:12:26] But the other thing is as well, where we have information that throws up something that might be a problem, or somebody might be concerned if they provide some information, they shouldn't be. Very rarely is there something that we can't overcome. Our job is to come up with solutions. And where we've had any issues arising, it's been something we can sort out. So that concern shouldn't exist. And if you think it is something that's delaying your engagement, don't let it. Raise it, let's talk to the team, let's see what we can do about it.
Malcolm Flanders [00:12:59] Great. That's very helpful. Thanks. Okay. Last question. And let's just sort of step back a bit and make this a broader question. Do you think the FCA has the balance right for customers? Will families actually be in a better place after the summer?
Nikki Bennett [00:13:15] Great question. I think the regulator always tries to do the right thing. And in taking in funeral planning, as with any other sectors they've taken in over the years, it's borne out of evidence of poor practise. And so invariably, they start their journey on the basis of poor practise, and then they take the time to understand the sector. And I think one of the biggest things they've learnt on this journey so far, is that no two firms in funeral planning are alike. Everybody just does it differently. And so I think there has been some challenge there, in how that translates into actual rules that are suitable for everybody.
Nikki Bennett [00:13:57] So I think they've been on that learning curve. Ultimately, do I think it's the right thing to do? Yes I do. I think it should provide better assurance to people buying funeral plans. At the end of the day, somebody buys a funeral plan because they want that piece of mind. They want that sense of safety and security. So by making the sector regulated, then they are buying something that they have that additional layer of protection for something that they ultimately wanted, that safety and that comfort factor in. So I do think in the long run, it's a good thing. I think it's a steep learning curve for many, including the regulator. But ultimately I think we will get there, and it will provide a much safer environment for people purchasing funeral plans.
Malcolm Flanders [00:14:43] Great. Just listening to you there, and knowing that you've been in this business for 17 odd years or so, why are you so passionate about regulation?
Nikki Bennett [00:14:53] It's the way I'm made, Malcolm. I think the team is built on like minded people, and we're all, like I said, we're all natural fixers, and helpers, and doers. And regulation is something that needn't be scary. It needn't be offputting. And it's just that, as with anything, sometimes you need someone to translate that into something that means something to you, and that isn't off putting. And we try to come up with all of our solutions, and all the challenges we face, as something that's practical, it's pragmatic, it's commercially aware, so that we can help that. And that's just the team that I've built over the years. We all share that passion and we're all on the side of those that we're working with. And we simply can't help it, is the answer to that.
Malcolm Flanders [00:15:40] Fantastic. Well done. I like the answer. Nikki, thank you for your time today for the podcast. Appreciate it. That was really helpful. And I know you're busy, but thank you for your time all the same. Appreciate it.
Nikki Bennett [00:15:52] Thank you for giving us this opportunity to help.
Malcolm Flanders [00:16:01] Thanks for listening to the Partnership Podcast. If you've started your regulatory journey, you'll hear more from us and from the UKGI. You can also speak to your business manager to ensure everything's on track. And if you have any questions about what you'd like to hear discussed on this podcast, you can also contact me at firstname.lastname@example.org. Our full catalogue of episodes is available at goldencharter.buzzsprout.com, or on a range of podcast apps, that includes the FCA regulation mini series that closed out 2021, and has lots of other perspectives on the journey to regulation. Thanks again, and I'll talk to you next time on the Partnership Podcast.