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	<title>threesixty</title>
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	<link>http://blog.threesixtyservices.co.uk</link>
	<description>This is the threesixty blog,  making financial advice work for everyone</description>
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		<title>Two Business Models: Godfather II and Superman III</title>
		<link>http://blog.threesixtyservices.co.uk/2012/05/12/two-business-models-godfather-ii-and-superman-iii/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/05/12/two-business-models-godfather-ii-and-superman-iii/#comments</comments>
		<pubDate>Sat, 12 May 2012 19:16:20 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[business]]></category>
		<category><![CDATA[Rants]]></category>
		<category><![CDATA[Business]]></category>
		<category><![CDATA[business model]]></category>
		<category><![CDATA[godfather]]></category>
		<category><![CDATA[superman]]></category>

		<guid isPermaLink="false">https://blog.threesixtyservices.co.uk/2012/05/12/two-business-models-godfather-ii-and-superman-iii/</guid>
		<description><![CDATA[I spend a fair bit of time explaining how our business works. It isn&#8217;t very complicated. It&#8217;s different from others and for that reason people assume it&#8217;s sophisticated. I thought I would summarise how most businesses in financial services work. &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/05/12/two-business-models-godfather-ii-and-superman-iii/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>I spend a fair bit of time explaining how our business works. It isn&#8217;t very complicated. It&#8217;s different from others and for that reason people assume it&#8217;s sophisticated. I thought I would summarise how most businesses in financial services work.</p>
<p>There are two business models. The Godfather II model and the Superman III model. </p>
<p>In Godfather II the young Don discovers that he can earn money by using his muscle to protect people in his neighbourhood against petty criminals. His position is initially morally ambiguous. Whilst unashamably violent his acts seem to be the lesser of two evils. However, as the business grows he formalises his position as a protection racketeer and eventual mob leader, not a heroic vigilante.  Many businesses generate revenue more through fear of negative consequences than expectation of positive results. It&#8217;s easy to draw analogies with big distributors, but it exists throughout most of the industry. One of the biggest mistakes you can make as a consultant or industry commentator, once you gain some profile is thinking you&#8217;re being paid for your intellectual abilities, rather than to shut you up. It&#8217;s the way it works. I kind of warm to the people that at least have the honesty to admit it. I would go as far as to say a high percentage of acquisitions in financial services have been based on Godfather II principles, usually those where everyone is left scratching their head asking &#8220;Why?&#8221;.</p>
<p>Superman III is a little more subtle. In the film Richard Pryor (his lowest moment) writes a programme which allows him to shave tiny fractions off every penny transacted, generating millions of dollars for no effort which nobody notices going missing. Your ahead of me already.  Many of the wealthiest in our industry have made their money by carefully examining the value chain and wedging themselves into it to siphon off a few basis points for themselves. This has gone on for years and is as strong now as it ever was. Some of the proponents of the Superman III model have had to be a little more creative of late, going to the trouble of offering model portfolios here, a risk profiling tool there, or even splitting the proceeds down the middle with accomplices.</p>
<p>To achieve optimal results it&#8217;s preferable to operate both the Godfather II and the Superman III models at the same time. A few have mastered the art, charging protection money from product providers whilst at round the back door emptying the back book and putting it onto a platform or fund where they skim fractions of a penny.</p>
<p>What&#8217;s weird is how easy it is. It doesn&#8217;t take much effort to pull either of these two models off. The regulator never stops it. I&#8217;ve been around the block enough to have seen it all first hand. I&#8217;ve allowed myself to be flattered only to realise I was being &#8216;managed&#8217; on plenty of occasions. I still get it, sometimes I enjoy it, I just understand the game a little better now, so don&#8217;t take it all too seriously. Most people don&#8217;t even know what&#8217;s going on.</p>
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		<title>I forgot to be omnipotent</title>
		<link>http://blog.threesixtyservices.co.uk/2012/05/03/i-forgot-to-be-omnipotent/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/05/03/i-forgot-to-be-omnipotent/#comments</comments>
		<pubDate>Thu, 03 May 2012 07:56:37 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[General]]></category>
		<category><![CDATA[People]]></category>
		<category><![CDATA[anthropology]]></category>
		<category><![CDATA[Business]]></category>
		<category><![CDATA[control]]></category>
		<category><![CDATA[control freaks]]></category>

		<guid isPermaLink="false">https://blog.threesixtyservices.co.uk/2012/05/03/i-forgot-to-be-omnipotent/</guid>
		<description><![CDATA[I made my daughter cry on the weekend as I forgot to be omnipotent. On Saturday we went bowling, just her and I, while her mum was away in London. Aside from the bowling we played on a few slot &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/05/03/i-forgot-to-be-omnipotent/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>I made my daughter cry on the weekend as I forgot to be omnipotent. On Saturday we went bowling, just her and I, while her mum was away in London. Aside from the bowling we played on a few slot machines. On this occasion we won big. Next day she asked if we could go back, more for the slot machines than the bowling I suspected. I told her we wouldn&#8217;t win again, she burst into tears. What I had meant was that it was very unlikely we would win again, but she thought I had simply decided not to win. In her head our success was a simple act of volition, not luck. I was in control of every outcome, I was omnipotent.</p>
<p>Lots of people I know describe themselves as &#8220;control freaks&#8221; and in many respects act like they believe themselves to be omnipotent. As impossible as we all know this is, there is a strong desire to accept blame or blame others for things which are beyond all control &#8211; &#8220;If its my fault than I can control it&#8221;. Claiming to be a control freak has become socially acceptable, and in a post-Jobs world something of a badge of honour. It shouldn&#8217;t be. It&#8217;s a complex, a neurosis.</p>
<p>I don&#8217;t refer to myself as a control freak as it&#8217;s an expression which avoids accountability and is non specific. I have a need to take control of situations which asserts itself in specific circumstances and makes me impatient and intolerant. Specifically I get frustrated when others are seemingly indecisive in certain situations. It is very specific. I can think of no circumstance when this has been helpful. Many when it hasn&#8217;t. Arguably it was instrumental in my career progress, but accepting more responsibility is not the same as needing control. It is not a prerequisite for success. It can choke it.</p>
<p>Personally, I know exactly where this came from, and have learned how to spot it rising in myself. That helps me keep it in check. Sometimes, not always. Nowadays, I spot it more and more in others. In group situations, many people have different techniques they unconsciously developed to shift the locus of control to themselves. It isn&#8217;t just chest beating alpha male behaviour. I&#8217;ve observed specific individuals consistently declare themselves as ill or having &#8220;worked until 2am&#8221; before any difficult meeting to erect a barrier against anticipated criticism. Gender and age may alter the technique but the underlying issues are common to everyone. It does not distinguish between personal and business life.</p>
<p>I&#8217;ve met very few people who act like this intentionally, with any real understanding of what they are doing or the impact it has. In many cases the impact is minor, but in the context of thousands of interactions a week, in a family or office environment, these can be amplified into bigger issues, as others adapt their behaviour accordingly.</p>
<p>Families and businesses are often interlocking combinations of peoples&#8217; neuroses. That&#8217;s why people don&#8217;t get on. That&#8217;s why people who don&#8217;t get on, do get on, when something changes. You can&#8217;t solve them but you can watch out for them. Control freaks can start with themselves, and occasionally forget to be omnipotent.</p>
<p>I gave in and won on the slot machines again by the way.</p>
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		<title>Jargon: why it&#8217;s our fault</title>
		<link>http://blog.threesixtyservices.co.uk/2012/03/19/jargon-why-its-our-fault/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/03/19/jargon-why-its-our-fault/#comments</comments>
		<pubDate>Mon, 19 Mar 2012 12:51:52 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[language]]></category>
		<category><![CDATA[Marketing]]></category>
		<category><![CDATA[Blog]]></category>
		<category><![CDATA[financial advice]]></category>
		<category><![CDATA[financial services]]></category>
		<category><![CDATA[jargon]]></category>

		<guid isPermaLink="false">https://blog.threesixtyservices.co.uk/2012/03/19/jargon-why-its-our-fault/</guid>
		<description><![CDATA[There is an overwhelming consensus that financial services is full of jargon and that that&#8217;s a very bad thing. I haven&#8217;t found a single view to the contrary. So why it is still so rampant? Because of us. Most people &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/03/19/jargon-why-its-our-fault/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>There is an overwhelming consensus that financial services is full of jargon and that that&#8217;s a very bad thing.</p>
<p>I haven&#8217;t found a single view to the contrary.</p>
<p>So why it is still so rampant?</p>
<p>Because of us.</p>
<p>Most people in financial services fell into it by accident. We can dream of a future where graduates aspire for a career in our industry but that&#8217;s still a little way off. We are here by accident, we might not regret it, but circumstance and chance played a part. Not so with professions such as accountancy and law, where a more traditional career path is established during full time education. Much of our angst relates to a sense of inferiority against these more established professions.</p>
<p>This sense of inferiority bred a drive toward complexity in financial services, a need to prove that what we were doing was worthwhile, valuable and necessary. It was difficult, fiddly. Jargon is simply the language we created for ourselves to amplify that complexity. &#8216;We&#8217; is the important word. It&#8217;s easy to blame product manufacturers, but advisers are paid to cut through this for the benefit of clients. Compliance experts, technical experts, business consultants are just as guilty. As am I.</p>
<p>There isn&#8217;t an invisible machine generating jargon in financial services. We produce it, as a comfort blanket, a secret code that only we can decipher for the purpose of proving our own value to ourselves. Nobody else.</p>
<p>Clients and customers are oblivious to all this. They want simplicity. They neither understand nor care about our complexes. Not should they. Pretty much every financial calamity has been caused by a desire to add more and more complexity, when all anyone wants is less of it.</p>
<p>As we suffer another explosion of new definitions and acronyms, it&#8217;s the advisers who do the simple things well who should prosper. Adding more complexity to the financial world is pure vanity. It suggests insecurity.</p>
<p>The self confidence of those advisers who want to make things simpler, who don&#8217;t overcomplicate matters, is very evident. They tend to be accessible people, whose opinions are sought after. They are happy to disagree with each other, without taking personal offence. They look beyond financial services for ideas and inspiration. We need to be more like them, and remember George Orwell&#8217;s 5th rule of writing:</p>
<p>&#8220;Never use a&#8230;jargon word if you can think of an everyday English equivalent.&#8221;</p>
<p>The other 5 rules are worth a read as well.</p>
<p><a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/George_Orwell21.jpg"><img class="alignnone size-medium wp-image-282" title="George_Orwell2" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/George_Orwell21-300x227.jpg" alt="George Orwell" width="300" height="227" /></a></p>
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		<title>threesixty&#8217;s new look</title>
		<link>http://blog.threesixtyservices.co.uk/2012/03/10/threesixtys-new-look/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/03/10/threesixtys-new-look/#comments</comments>
		<pubDate>Sat, 10 Mar 2012 17:48:13 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[Change]]></category>
		<category><![CDATA[Marketing]]></category>
		<category><![CDATA[brand]]></category>
		<category><![CDATA[marketing refresh]]></category>
		<category><![CDATA[threesixty]]></category>

		<guid isPermaLink="false">https://blog.threesixtyservices.co.uk/2012/03/10/threesixtys-new-look/</guid>
		<description><![CDATA[&#160; Last year I decided we needed to invest some time and money into marketing to enhance the way we communicate to the outside world. I spent the last six months of 2011 making a lot of changes and improvements &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/03/10/threesixtys-new-look/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>&nbsp;</p>
<p><a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/Adviser-Image1.jpg"><img class="aligncenter size-full wp-image-244" title="Adviser-Image" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/Adviser-Image1.jpg" alt="" width="470" height="224" /></a></p>
<p>Last year I decided we needed to invest some time and money into marketing to enhance the way we communicate to the outside world. I spent the last six months of 2011 making a lot of changes and improvements internally, but we really needed to reflect that in our marketing content as well.</p>
<p><strong><br />
<a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/Research1.jpg"><img class="alignleft size-medium wp-image-251" title="Research" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/Research1-265x300.jpg" alt="" width="175" height="196" /></a>What&#8217;s the problem?<br />
</strong><br />
Providing support services to IFAs is nothing new. When we launched in 2003 we were angry and young (well I was anyway). We were fee based, didn&#8217;t want to take a split of commission and, bluntly, thought everyone else did a poor, often overpriced, job. We thought we could do it better, and I think we did. We didn&#8217;t need to spend time and effort on marketing why we were different, it was obvious.</p>
<p>Nine years on and the market has matured in some ways, less so in others.</p>
<p>We&#8217;re still miles ahead of everyone else but many have copied aspects of what we&#8217;ve done over the years, be it the fee structure, the type of services, or even the copy used to describe what we do. They haven&#8217;t replicated how we do it, but superficially the points of differentiation are harder to distinguish. When we list what we do, most other businesses will list the same things.</p>
<p>And I hate lists. I really hate them. If the best you can do is to list the things you do and keep adding to it, you should give up.</p>
<p>After the best part of 10 years it&#8217;s easy to just keep adding bells and whistles and cloud the important issues; how you work, what you stand for, why this should matter to your clients.</p>
<p>That&#8217;s where we were heading. Nothing was broken, the business wasn&#8217;t struggling and our reputation had never been better, but it was time for a change. It might seem strange to tinker with something which isn&#8217;t broken, but it&#8217;s better to change from a position of strength. You can&#8217;t stand still.</p>
<p><strong><a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/blackboard.jpg"><img class="alignright size-medium wp-image-236" title="Protect, Grow, Realise" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/blackboard-167x300.jpg" alt="Protect, Grow, Realise" width="167" height="300" /></a>Where to start?</strong></p>
<p>We selected an external marketing agency to bring fresh ideas into the business. I have no qualifications or experience in marketing and I&#8217;m a big believer in bringing the best expertise I can afford in. The most valuable (and expensive) part of the process was the research. The agency undertook interviews by telephone, face-to-face and in group sessions with IFA business owners who were clients and non-clients. We did the same with staff right across the business.</p>
<p>The results were fascinating, and I couldn&#8217;t have got that depth and honesty of research myself. Having the results played back to us was illuminating. We spent a day collating this into a small number of key statements that summarised who we were as a business. There was nothing new. Nothing unusual, but we uncovered things which we had struggled to articulate succinctly before.</p>
<p><strong><br />
<a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/Lightbulb.jpg"><img class="alignleft size-medium wp-image-239" title="Lightbulb" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/03/Lightbulb-197x300.jpg" alt="The fun bit" width="197" height="300" /></a>The fun bit<br />
</strong><br />
After this we moved to the design phase. This is the part most people associate with marketing and brand work, but it only works with the hard graft on research done first. We were keen to be bold and make a sizeable leap forward rather than slowly add in incremental change. We rejected the first design concepts as we felt they were too traditional and corporate, we wanted to bring out a sense of individuality and self confidence through something really different. We got down to one of two themes. The first used famous quotes set against dramatic landscapes. Whilst it communicated an idea of expansive thinking, it still did this by using other peoples thoughts which felt a little at odds with our need for originality, and felt it could become a little predictable over time.</p>
<p>The second pretty much nailed everything we wanted to say, but had struggled to find the words for. It&#8217;s practically impossible to copy. It demonstrates our belief in clear, simple, direct messages. It&#8217;s got individuality without reliance on any one individual.</p>
<p>It&#8217;s been a really enjoyable process getting here and hopefully you&#8217;ll see that reflected in our new look. So enough words, I&#8217;ll let the the pictures take over at <a href="http://www.threesixtyservices.co.uk/">www.threesixtyservices.co.uk</a>, I hope you like it.</p>
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		<title>Independent – What’s in a Name?</title>
		<link>http://blog.threesixtyservices.co.uk/2012/02/29/independent-%e2%80%93-what%e2%80%99s-in-a-name/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/02/29/independent-%e2%80%93-what%e2%80%99s-in-a-name/#comments</comments>
		<pubDate>Wed, 29 Feb 2012 18:36:48 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[Marketing]]></category>
		<category><![CDATA[Regulation]]></category>

		<guid isPermaLink="false">http://blog.threesixtyservices.co.uk/?p=225</guid>
		<description><![CDATA[There is still a lot of confusion and concern amongst firms around whether to be an independent or restricted advice business post RDR. The decision is going to be a fairly subjective one for most firms, and for that reason &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/02/29/independent-%e2%80%93-what%e2%80%99s-in-a-name/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>There is still a lot of confusion and concern amongst firms around whether to be an independent or restricted advice business post RDR. The decision is going to be a fairly subjective one for most firms, and for that reason I can only offer an opinion alongside the facts as we know them now, to assist you in the process.  </p>
<p>Before I start it&#8217;s really important I make two important points to provide some context.</p>
<p>Firstly, threesixty will support client firms to the best of its abilities regardless of the decision you make. We have no vested interest (financial, political or otherwise) in which direction you take. That isn&#8217;t the case for most, but it is for us. Our views on this subject are guided by pragmatic, business assumptions with the best interests of our client firms, and your own clients, in mind. We do believe we have a role to play in helping advisers look after the best interests of their clients, but at the same time we do not believe this should be coloured by any political agenda. A few people have suggested to me we have been pro-independent recently. In trying to balance that up I&#8217;m conscious this could be read as pro-restricted. I&#8217;m not trying to be either.</p>
<p>Secondly, threesixty has long argued that the definition of restricted advice is too broad, and will not serve consumers understanding well. Under the umbrella of restricted advice will be direct sales forces, tied agents, multi-ties, and many advisers who are operating as IFAs today and do not advise on esoteric investments. Because of the political agendas of various factions within the industry, a proper debate on the sense of this breadth has been hidden beneath a fog of petty and divisive squabbling which the regulator could easily ignore. These comments are, therefore, based on the situation as is, not necessarily what we would want it to be.</p>
<p>Our last survey, which we will re-issue following this article, suggested that 48% of respondents were &#8216;seriously considering becoming restricted&#8217;. The main reasons cited were the avoidance of advising or maintaining knowledge on esoteric investments which were outside of typical client requirements. It was about staying whole of market, but not stretching into the new product areas covered under Retail Investment Products. Significantly, a good number stated they no longer described themselves as independent anyway.</p>
<p>First some facts, some of which may surprise you.</p>
<p><strong>Independence is at advice level, branding is not</strong></p>
<p>You can decide whether your advice is independent or restricted right down at advice level. So why worry? Whilst this might seem to give you the endless flexibility you need to avoid making any concrete decision, you can&#8217;t call your firm independent unless every adviser and all advice given will conform to the independence requirements. That means that if you remove the word independent from your company name and all marketing literature, and subject to making the relevant disclosures up front, you can pick and choose when you give independent advice and when you don&#8217;t. In reality we don’t expect firms to take this approach as it is too complex to manage on a case by case basis, as if you do this you will still need to maintain all the requirements to give independent advice at all times. Remember, you can only keep the name independent if you never use restricted advice, so if you think restricted may play a part in what you offer going forward you may want to look at how you market yourself now and from 2013 onwards. Do you need to change your company name, stationery, adverts, brochures?</p>
<p><strong>Marketing independence</strong></p>
<p>There will be plenty of IFAs who are passionate about continuing to give advice badged as &#8216;independent&#8217;. There is an emotional connection to the word which is entirely understandable as it has been the key word used to describe what they do for many years. I have noticed a considerable change in this in recent years, however. Many firms describe themselves as wealth managers, or financial planners, for example, and rarely use IFA. It has not been something they use to market themselves for some time, so there is no perceived value in using the word for them or their clients. Equally, advisers who have carefully managing the affairs of their clients over the years will have a relationship of trust with them which will always transcend whether they are restricted or independent. It&#8217;s about client perception.</p>
<p>The first part of the decision and one which few have gone beyond is an emotional attachment to the word independent. If you are passionate about this and really wish to continue to be independent then you should, of course, explore what is required. Meeting the standards is entirely possible for many, accepting there will be some more work involved. For the rest, it will be down to a purely rational decision based on the factors described below.</p>
<p>I&#8217;m not trying to belittle the importance of this more intuitive part of the process in any way. If you feel emotive about it, the chances are your clients will as well. It isn&#8217;t something you should ignore.</p>
<p><strong>What extra benefit do you get by being &#8216;independent&#8217;</strong></p>
<p>For some firms, whether they stay independent or not may just come down to a real desire to remain independent, or an inability to do so. There may be a marketing advantage to remaining independent, but whilst some investors fully understand what independence means I am sceptical as to how much of an impact this will really have given the demonstrable track record of success of non-independent brands such as St James&#8217; Place. Whether we like them or not, they are well regarded and used by many wealthy individuals. What other factors should be considered beyond client perception?</p>
<p>Professional introductions is the biggest issue in my opinion. If you get leads from solicitors and accountants will these stop if you go restricted? Currently, yes. There has been no formal change to the rules yet so introductions must be made to IFA firms. Will this change? That&#8217;s pure speculation. Personally I think it will, as the regulatory bodies could change the word independent to whole of market and achieve the same ends. There will be plenty who argue to the contrary but they haven&#8217;t stopped endless introductions to SJP to date under the current rules. We have already seen most trade and professional bodies agree to accept restricted advice firms as the equivalent of independent, so I think it&#8217;s just a matter of time for the rest. But as I said, this is speculation, so if you are reliant on referrals from solicitors or accountants then I suggest you look to remain independent for very simple, commercial reasons, although this doesn’t mean having to keep independent in your business name.</p>
<p><strong>What are the downsides?</strong></p>
<p>There is some cost and hassle attached to remaining independent, although much of that is already borne by some firms. Initially, much of this relates to the products outside packaged products but under the definition of Retail Investment Products, which includes tax shelters such as VCTs and UCIS.</p>
<p><em>T&amp;C</em></p>
<p>Whilst you don&#8217;t have to advise on these products, you have to know why you don&#8217;t want to advise on them, and when they might be appropriate. This isn&#8217;t insurmountable but needs to be factored into your CPD. As much of it has to be structured from 2013 onwards you might view this as no additional burden. Given the complexity of these products, however, it&#8217;s highly likely that to control any use of them you will need to run an investment committee to control access to them. That investment committee might never make a decision on individual product selection if they are just inappropriate for the whole client bank, but at the same time you should consider what would happen if a client is identified where this type of tax structure is appropriate. There is a danger that a number of firms create an investment committee on paper, for the purpose of remaining independent, and get caught out by the regulator or a client when it becomes apparent that it is a token gesture, with no evidence of process, agendas, minutes etc.</p>
<p><em>Supervision</em></p>
<p>Researching specific specialist investments can be time consuming and expensive with no guarantee of success, so many firms will decide to go restricted as they don&#8217;t want the extra work and don&#8217;t see the value for their client bank. The more advisers there are in a firm the harder this gets from a supervisory control perspective, and this can ultimately result in more costs. Remember, a supervisor should be appropriately qualified for the role, so what might be minor inconveniences for the small firm can be amplified for multi-adviser businesses, and those with trainee advisers.</p>
<p>It is possible to structure your advice so that a joint approach is used to bring in additional expertise within the firm from those with the necessary experience to advise in esoteric areas, but this is subject to the requirements set up in GC 12/03 para 6.8 (reproduced at the end of this note). Again, this is a workable solution for some firms, but not for others, and adds an extra layer of operational control regardless.</p>
<p>We are putting together some more detailed guidance on the different scenarios where supervision within the firm will or won’t work, for example occupational pension transfers and long term care, and this will be with you shortly.</p>
<p><em>Professional Indemnity Insurance</em></p>
<p>As for more direct costs, it is likely that the PI market is hardening again, which will result in increasing costs and possibly more exclusions on policies. If the market hardens to its 2002 position, we will undoubtedly see a number of firms without cover for higher risk products, and whilst FSA has stated that those firms could remain if they choose to self insure, this is a potential catalyst to drive firms down the restricted route. We haven&#8217;t arrived at this state yet, I am only speculating, but early indicators are that there will be far more attractive premiums (over 50% reductions) available to those firms wishing to keep to the packaged product market, which is seen as less risky by underwriters. In fact, limiting the product range to a small number of pre-approved tax wrappers and investment solutions, which is what many firms using platforms already do is seen as the lowest risk model and likely to be rewarded by the lowest premiums. Less seems to be more for underwriters. Again, the higher your turnover, the more of a saving the reduction in premium will be. For those looking at retaining independence status we may see a move towards policies which will provide cover on a preapproved basis – i.e. cover all areas but for some higher risk product areas case by case approval being required to obtain cover.  This could reduce premium costs and limit requirements for additional capital adequacy funds but increase the requirements for recommending complex products and, ultimately the cost of providing advice in this area.</p>
<p><strong>Single Platform Solution</strong></p>
<p>A number of firms have asked me whether giving restricted advice could be a way of adopting a single platform solution without any regulatory pressure to justify platform or product selection in every case. In theory, I think it could. Whilst I doubt that advisers would want to formally single or multi-tie to a platform for all business, the very fact that restricted advice covers everything from whole of market to single tie suggests that there would be a way of disclosing how your advice would work, which platform or products you use for your service as mandatory, and proceed without the need to provide whole of market or independent research on file for each client. This will undoubtedly be a controversial point for many, and I&#8217;m not sure if this is what FSA would have anticipated, but as long as the relevant disclosure is made then there should be no problem with this approach. Again, it will come down to how this is perceived by your clients. It’s important to note that if you adopt this approach you will still be expected to pass clients on who aren’t suitable for your platform to another adviser.</p>
<p><strong>Summary</strong></p>
<p>That&#8217;s a lot to think about. To sum it up in one paragraph &#8211; if you want to stay independent, if it matters to you, then it is definitely achievable and we can help. If you, or your clients, don&#8217;t really value the label ‘independent’, or are unsure, I would suggest removing the word from your business name and marketing literature, as you can still continue to give &#8216;independent&#8217; advice post 2013 but are under no obligation to do so.</p>
<p><strong>Guidance Consultation 12/03 Paragraph 6.8</strong></p>
<p><em>&#8216;More than one adviser may be involved in developing personal recommendations for a client. An adviser may, for example, wish to consult an experienced colleague on a particular subject before delivering personal recommendations. Similarly, a number of people could be involved in product research and investment monitoring. However, we do not expect, for example, that a firm could meet the independent advice rules if a retail client was given multiple personal recommendations on retail investment products from more than one adviser within the firm (unless that advice related to the specialist activities identified above, i.e. pension transfers, pension opt-outs or long-term care insurance contracts). The adviser who delivers the personal recommendation should have the skills and knowledge necessary to ensure that the advice meets the standard for independent advice.’</em></p>
<p>Therefore, the adviser who delivers the personal recommendation must have sufficient competence to ensure the advice meets the independence requirements. The FSA also warns against independent firms making multiple recommendations from more than one adviser which would appear to preclude the option of making a referral to a specialist adviser within the firm. This is a complex area which we will be investigating in more depth as there are a number of issues we have already identified with implementing this.</p>
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		<title>Things Fall Apart</title>
		<link>http://blog.threesixtyservices.co.uk/2012/02/13/things-fall-apart/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/02/13/things-fall-apart/#comments</comments>
		<pubDate>Mon, 13 Feb 2012 21:29:47 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[Change]]></category>
		<category><![CDATA[People]]></category>
		<category><![CDATA[The Future]]></category>
		<category><![CDATA[mental health]]></category>
		<category><![CDATA[RDR]]></category>

		<guid isPermaLink="false">https://blog.threesixtyservices.co.uk/2012/02/13/things-fall-apart/</guid>
		<description><![CDATA[Things Fall Apart. Achebe&#8217;s novel explores the social and pyschological impact of change on a society and an individual. It can be read in many ways. The change, in the novel, is to a traditional African village infiltrated by western &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/02/13/things-fall-apart/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>Things Fall Apart. Achebe&#8217;s novel explores the social and pyschological impact of change on a society and an individual. It can be read in many ways. The change, in the novel, is to a traditional African village infiltrated by western imperialists and Christian missionaries. But as with all great novels it contains a universal truth, about the traumatic consequences of change regardless of the intentions of those causing it.</p>
<p>I thought of this recently when I read an article regarding mental health issues in financial services. The article focussed on the pressures faced by high flying banking executives and a corresponding increase in stress related illnesses, and was unexceptional in many regards. In the months since Gary Speed&#8217;s death we have seen a lot more discussion about mental health issues amongst sports stars, but this was the first story relating to financial services, albeit loosely. It did make me think.</p>
<p>I&#8217;m not aware of any commentary on the impact that the forthcoming changes to financial advice will have on those unused to significant change. We know that change, both negative and positive, creates enormous pressures on the minds of many. Lottery winners often struggle to adjust. I regularly hear criticism of advisers who have their &#8216;head in the sand&#8217;, but how much of this is down to an inability to cope with the pressures which change brings, not simple belligerence.</p>
<p>I&#8217;m not trying to create excuses for anyone. I have supported RDR.  I like change, and usually benefit from it. I&#8217;m not trying to stop it, but I think that we need to be sensitive to the problems it will cause. It&#8217;s going to get noisy and aggressive over the next few months, and the less finger pointing the better. Not only will some people not make it professionally, they will not recover as individuals. That might sound dramatic, but it&#8217;s a well established consequence of change.</p>
<p>In Things Fall Apart, many of the traditional customs seem ridiculous and at times horrific to our eyes. The villagers could well do without them, and the author does little to shield us from this. Yet, in the end, we can&#8217;t help but feel some empathy toward the flawed protagonist, Okonkwo, destabled by the signs and signifiers he interprets the world with shifting beneath his feet, leading to the books tragic conclusion. That&#8217;s the empathy we need now.</p>
<p>Things fall apart. As do people.</p>
<p><a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/02/20120213-213420.jpg"><img src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/02/20120213-213420.jpg" alt="20120213-213420.jpg" class="alignnone size-full" /></a></p>
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		<title>Cloud Storage</title>
		<link>http://blog.threesixtyservices.co.uk/2012/02/09/cloud-storage/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/02/09/cloud-storage/#comments</comments>
		<pubDate>Thu, 09 Feb 2012 16:31:12 +0000</pubDate>
		<dc:creator>Tim Ng</dc:creator>
				<category><![CDATA[cloud]]></category>
		<category><![CDATA[General]]></category>
		<category><![CDATA[Web]]></category>
		<category><![CDATA[Data Protection]]></category>
		<category><![CDATA[EU]]></category>
		<category><![CDATA[ICO]]></category>
		<category><![CDATA[Safe Harbour]]></category>
		<category><![CDATA[USA]]></category>

		<guid isPermaLink="false">http://blog.threesixtyservices.co.uk/?p=107</guid>
		<description><![CDATA[Post inspired by a query via Twitter. More and more people are starting to backup or store their data online believing it more secure. But is it really? Probably. But do you understand all the risks? You are probably aware &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/02/09/cloud-storage/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>Post inspired by a query via Twitter.</p>
<p>More and more people are starting to backup or store their data online believing it more secure. But is it really? Probably. But do you understand all the risks?</p>
<p>You are probably aware that your data is fairly secure if stored in the EU since it is covered by EU Privacy regulations. Are you aware that things become more complicated if the company\provider in question is registered in the USA?</p>
<p><em>&#8220;Safe Harbour is the USA equivalent of the EU Data Protection Act and I should be safe if the company is registered with that!&#8221;</em>, or <em>&#8220;It is stored in the EU so they can&#8217;t have my data!&#8221;</em> are the common statements\misconceptions I hear.</p>
<p>Unfortunately a recent study discovered that the Safe Harbour Agreement (which is self regulated) is not rigorously enforced and therefore not worth the paper it is written on. As a company you can register yourself and say you will put processes into practise but you don&#8217;t need to prove it &#8211; and it turns out many don&#8217;t.</p>
<p>If that wasn&#8217;t bad enough storing data in the EU is not a guarantee of protection from the Patriot Act (not really a big issue -unless you store top secret info &#8211; but who feels comfortable?), if the company or provider is registered in the USA they are obliged to respond regardless of where the data is held (this was confirmed recently by Microsoft &#8211; the only corporation to openly admit this).</p>
<p>If you store your data in the cloud you will need to review your data security, how you categorise your data, review your documentation and processes to ensure clarity internally and for your client.</p>
<p>Nothing is risk free but as long as you are aware then you can at least mitigate your exposure.</p>
<p>Here are some links for further reading:</p>
<p><a title="Sending personal date outside EU" href="http://www.ico.gov.uk/for_organisations/data_protection/the_guide/principle_8.aspx" target="_blank">Sending personal data outside the European Economic Area</a></p>
<p><a title="http://www.zdnet.com/blog/igeneration/safe-harbor-why-eu-data-needs-protecting-from-us-law/8801" href="http://www.zdnet.com/blog/igeneration/safe-harbor-why-eu-data-needs-protecting-from-us-law/8801" target="_blank">Safe Harbor: Why EU data needs &#8216;protecting&#8217; from US law</a></p>
<p><a title="http://www.engadget.com/2011/07/06/microsofts-patriot-act-admission-has-the-eu-up-in-arms/" href="http://www.engadget.com/2011/07/06/microsofts-patriot-act-admission-has-the-eu-up-in-arms/" target="_blank">Microsoft&#8217;s Patriot Act admission has the EU up in arms</a></p>
<p><a title="http://www.computerworld.com/s/article/9218167/EU_upset_by_Microsoft_warning_on_U.S._access_to_EU_cloud " href="http://www.computerworld.com/s/article/9218167/EU_upset_by_Microsoft_warning_on_U.S._access_to_EU_cloud " target="_blank">EU upset by Microsoft warning on U.S. access to EU cloud</a></p>
<p><a title="http://www.ftc.gov/os/comments/privacyroundtable/544506-00022.pdf" href="http://www.ftc.gov/os/comments/privacyroundtable/544506-00022.pdf" target="_blank">Privacy, Self-Regulation And Statutory Safe Harbors (Page 14)</a></p>
<p><a title="http://export.gov/safeharbor/eu/eg_main_018476.asp" href="http://export.gov/safeharbor/eu/eg_main_018476.asp" target="_blank">EU-US Safe Harbour Overview</a></p>
<p><a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/02/cloud.jpg"><img class="aligncenter size-full wp-image-211" title="cloud" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/02/cloud.jpg" alt="" width="294" height="172" /></a></p>
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		<title>2012: Armageddon &#8211; Cookies and Compliance with ePrivacy Directive</title>
		<link>http://blog.threesixtyservices.co.uk/2012/02/06/2012-armageddon-cookies-and-compliance-with-eprivacy-directive/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/02/06/2012-armageddon-cookies-and-compliance-with-eprivacy-directive/#comments</comments>
		<pubDate>Mon, 06 Feb 2012 10:02:34 +0000</pubDate>
		<dc:creator>Tim Ng</dc:creator>
				<category><![CDATA[Web]]></category>

		<guid isPermaLink="false">http://blog.threesixtyservices.co.uk/?p=189</guid>
		<description><![CDATA[The year is 2012 and some believe that this is the year that the world will end &#8211; doom sayers point to the fact that this was predicted thousands of years ago by the Mayans. Undoubtedly this will be a &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/02/06/2012-armageddon-cookies-and-compliance-with-eprivacy-directive/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>The year is 2012 and some believe that this is the year that the world will end &#8211; doom sayers point to the fact that this was predicted thousands of years ago by the Mayans.</p>
<p>Undoubtedly this will be a year of change for many people with numerous regulatory changes on the horizon &#8211; in a sense it will be Armageddon for the unprepared, imagine over the coming months RDR, VAT, the FSA being disbanded and remoulded into the FCA and PRA with the good old BoE thrown in for good measure&#8230;.brr!! doesn&#8217;t bear thinking about for many.</p>
<p>If you are one of the believers then the deadline (26th May 2012) for the years grace for compliance with the ePrivacy Directive must seem to be pretty unimportant in the scheme of things.</p>
<p>The half term report from the <a href="http://www.ico.gov.uk/news/blog/2011/half-term-report-on-cookies-compliance.aspx" target="_blank">ICO</a> does not bear good tidings, phrases as &#8220;could do better&#8221; and &#8220;must try harder&#8221; are being rolled out &#8211; not many sites have even attempted to comply (I haven&#8217;t found any but the ICO site) but then I haven&#8217;t looked very hard. Reasons for this are many and varied:</p>
<ol>
<li>I don&#8217;t understand what it means.</li>
<li>ICO will not fine everyone if no one does it.</li>
<li>Technology is not available to support it.</li>
<li>It will destroy the user experience.</li>
<li>It will make my site less accessible.</li>
<li>Users will just ignore it and not read the messages.</li>
<li>Users will stop coming to my site and go elsewhere.</li>
<li>Users will complain and refuse.</li>
</ol>
<p>None of them are valid ones for non compliance, the ICO will take a patient view and will judge each case on its merits but they <span style="text-decoration: underline;">will</span> act on any reports of non compliance.</p>
<p>Website owners need to be looking at their Terms and Conditions, Privacy notices etc.. on their website and explore options on how to comply (there are solutions out there or develop your own).</p>
<p>Armageddon is said to be a series of cataclysmic events like a perfect storm, the ones left will be the ones best prepared &#8211; are you prepared?</p>
<p>For more information see my previous post <a title="The new rules on electronic marketing and cookies – are you ready?" href="http://blog.threesixtyservices.co.uk/2011/09/27/the-new-rules-on-electronic-marketing-and-cookies-%e2%80%93-are-you-ready/">&#8220;The new rules on electronic marketing and cookies – are you ready?&#8221;</a></p>
<p>If you would like to discuss feel free to comment or contact me via <a href="mailto:tim.ng@threesixtyservices.co.uk&amp;subject=cookie directive">email</a> or twitter @tim_kc_ng &#8211; see you on the other side.</p>
<p><a href="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/02/nuke.jpg"><img class="size-full wp-image-199 aligncenter" title="Armageddon" src="http://blog.threesixtyservices.co.uk/wp-content/uploads/2012/02/nuke.jpg" alt="" width="200" height="174" /></a></p>
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		<item>
		<title>Transparency a Poor Proxy</title>
		<link>http://blog.threesixtyservices.co.uk/2012/02/02/180/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/02/02/180/#comments</comments>
		<pubDate>Thu, 02 Feb 2012 23:07:50 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[General]]></category>
		<category><![CDATA[platforms]]></category>
		<category><![CDATA[The Future]]></category>
		<category><![CDATA[Platforms]]></category>
		<category><![CDATA[RDR]]></category>
		<category><![CDATA[Transparency]]></category>
		<category><![CDATA[trust]]></category>
		<category><![CDATA[wrap]]></category>

		<guid isPermaLink="false">https://blog.threesixtyservices.co.uk/2012/02/02/180/</guid>
		<description><![CDATA[Calls for greater transparency are ten a penny these days, and on the face of it hard to argue with. Who wouldn&#8217;t want greater transparency? Whilst I think it will help, I&#8217;m not convinced that it is really more than &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/02/02/180/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>Calls for greater transparency are ten a penny these days, and on the face of it hard to argue with. Who wouldn&#8217;t want greater transparency? Whilst I think it will help, I&#8217;m not convinced that it is really more than a tool to achieve an objective we&#8217;ve lost sight of.</p>
<p>The objective is probably one of two things; understanding or trust. Some clients need to understand what the hell is going on before they are prepared to commit to their financial future, others just want to be able to trust their adviser without worrying about understanding it all. Good advisers achieve this already. Transparency is a poor proxy for understanding and trust and we are gravely mistaken when we believe that it will achieve instant results. This is because it is such a loose term, and entirely open to abuse.</p>
<p>Calls for transparency on platform charges are fair but won&#8217;t achieve much. That&#8217;s because advisers right now are using transparently charged wrap platforms, &#8216;white labelled&#8217; with extra charges on top which they skim off into their own back pocket. The charges, and where they go are transparently laid out in key features documents and, in theory, explained to the client. Transparency presumably doesn&#8217;t extend to explaining to the client that they are being scammed, and the same investments could be added to the same platform for 10 or 15 basis points cheaper, or that their platform selection was motivated by a vague promise that they might be bought in future if they put enough assets on. </p>
<p>I asked an adviser how he justified this some years back. He answered, angrily, that &#8220;everyone is ripping everyone off, Gordon Brown is doing it, why shouldn&#8217;t I?&#8221; I think the question was rhetorical. Transparency is worthless without the means for fair comparison. This adviser could not be trusted, had no consideration for his client&#8217;s best interests. He was very transparent. You can transparently mug someone.</p>
<p>The current calls for transparency on fund charges are entirely justified, but will only really change investor attitudes if they can understand what the hell these charges mean and whether they are reasonable. This requires the standardisation and simplification of charging structures, and some objective benchmarks for comparison. I&#8217;m pleased to see this idea start to gain traction, but it will require firm and prescriptive regulation.</p>
<p>Transparency is a valuable tool for the diligent adviser, who accepts fiduciary responsibility for the safekeeping of his clients money from forseeable harm. Unfortunately, too many advisers still turn a blind eye to this and prefer to collaborate with platforms or fund managers for their mutual benefit rather than that of the client. It&#8217;s important that we admit this. It&#8217;s important the regulator speaks clearly as to it&#8217;s views on it.  And acts on it.</p>
<p>I don&#8217;t recall platforms making the national press at all over the past 10 years. My suspicion is that the first time it does, it will be another scandal about money exchanging hands behind the scenes between manufacturer and adviser, another consumer rip off. It will undo any good work the RDR will have done to instil trust in the public. What they will understand is that there is no real transparency in financial services. That nothing has changed.</p>
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		<title>The Message is the Meaning</title>
		<link>http://blog.threesixtyservices.co.uk/2012/01/26/173/</link>
		<comments>http://blog.threesixtyservices.co.uk/2012/01/26/173/#comments</comments>
		<pubDate>Thu, 26 Jan 2012 00:14:02 +0000</pubDate>
		<dc:creator>philyoung</dc:creator>
				<category><![CDATA[language]]></category>
		<category><![CDATA[Marketing]]></category>
		<category><![CDATA[communications]]></category>
		<category><![CDATA[IFA advice]]></category>
		<category><![CDATA[marketing]]></category>
		<category><![CDATA[marketing financial services]]></category>
		<category><![CDATA[Semiotics]]></category>

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		<description><![CDATA[Something I&#8217;ve been reading about recently is language; how we use, what is means, what it does to our brains. One concept which took a while to grasp was &#8216;the message is the meaning&#8217;, not the content of the message, &#8230; <a href="http://blog.threesixtyservices.co.uk/2012/01/26/173/" class="more">Read More <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>Something I&#8217;ve been reading about recently is language; how we use, what is means, what it does to our brains.</p>
<p>One concept which took a while to grasp was &#8216;the message is the meaning&#8217;, not the content of the message, the medium. I found this hard after a lifetime of concentrating on substance over style, content over form, and a mistrust of highly polished surfaces.</p>
<p>Having studied this in more detail I began to relate this to my own experience of communication; books, phones, social media. I picked up on an idea I read about some months ago that different types of communication had their own &#8216;texture&#8217;. This made sense to me. Paper has always had a texture, a quality, but even electronic messages mean something when we receive them &#8211; something beyond the content, before we have even read the content. For example, SMS &#8211; a text message &#8211; was always received as a present. For myself, and I believe many others, there was a point in time when the beep of an incoming text message signified a very personal message, almost always bearing good news, something interesting and very specific to you. An invitation to open it. It cost money to send it. This gave text messages a special importance, a texture.</p>
<p>Emails had an early naive quality but quickly became very functional carriers of information. Email is convenient, practical, utilitarian. It can be personal but is often one-to-many and the bearer of non-descript news, work. How often do you get an email that gives you the same feeling that the beep of a text message gave you once? Emails have a texture, a feel (or lack of one) in keeping with this.</p>
<p>So back to the point, the message is the meaning.</p>
<p>Chatting to Jon Pittham (@ClientsFirstUK) recently it struck me how passionate he was about communication, and how much clients appreciated it. It made me think. In many respects we are stifled by insecurity around what to say to clients and in an attempt to perfect the impossible, communicate little or nothing at all. Much of the industry wide research suggests clients really value face to face contact. I think you could extend this to different and varied forms of contact. There is little evidence to show that the content itself is essential. The message is the meaning. Not the content. The message.</p>
<p>If you&#8217;re using social media, that very fact is communicating more than the content of your blogs and tweets. For example, the semiotic code of twitter is enormously inclusive, it can hold incredibly divergent opinions within one community in a way in which many other forms cannot. Again, the message is the meaning. &#8220;I&#8217;m part of this. I&#8217;m engaging. I&#8217;m like you, even if my opinions aren&#8217;t.&#8221;</p>
<p>Instead of worrying about what to communicate with clients, maybe more time should be spent on how to communicate with clients, in what format and frequency. The texture of the medium used. How does it feel to receive it? Maybe then we&#8217;d do it more often.</p>
<p>My mum appreciates a phone call. Doesn&#8217;t matter what it&#8217;s for. Is everyone else so different?</p>
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