TISA urges FCA to revise targeted support plans for clarity & ease

The Investing and Saving Alliance has called on the Financial Conduct Authority to adjust its proposed rules on the targeted support regime to prevent confusion and operational difficulties for both consumers and financial firms.

TISA, which represents a wide range of financial sector members, stated its general support for the targeted support regime but raised specific concerns about elements of the latest proposals outlined by the FCA. The organisation highlighted the possible repercussions of proposed mandatory signposting requirements for pension communications and the approach to remuneration disclosures under the new rules.

Disclosure framework

Sophie Legrand-Green, Head of Policy at TISA, emphasised the importance of aligning disclosure frameworks with practical business operations and consumer understanding. She said:

"Targeted support has the potential to transform how consumers engage with financial services, but it must be built on a disclosure framework that is intelligible, supports consumer confidence and aligns with how firms operate. The FCA should leverage the Consumer Duty and recognise firms' ability to judge what information is most useful to their customers, how best to communicate it, and when their services will be ready. A flexible, principles-based approach - rather than rigid disclosure mandates - will better support innovation, operational readiness and consumer confidence. We welcome the FCA's commitment to progressing this regime and stand ready to work with the regulator and industry to ensure its success."

TISA's submission warns that the FCA's plan to require firms to signpost targeted support services in pension communications could lead to a situation where customers are directed towards services that are not yet available. The Alliance argues this risks causing confusion and frustration for consumers, who may expect access to support that firms are not yet prepared to deliver.

Operational challenges

According to TISA, the proposed rules could also place a heavy compliance burden on companies, including those with no plans to offer targeted support. The concern is that mandating signposting irrespective of a firm's readiness may force organisations to adjust their operations prematurely or confirm the absence of support, further complicating customer interactions.

The organisation is calling for more flexibility within the regime, allowing providers to adapt communications based on their individual service models and the timelines for rolling out these services. TISA contends that a more principle-driven approach would support the overall objectives of innovation, operational progress, and sustainable consumer confidence.

Remuneration disclosures

TISA has also expressed concern about the FCA's proposed requirements relating to remuneration disclosures, particularly for firms that operate complex cost or cross-subsidisation models. The Alliance believes that compelling firms to provide detailed breakdowns of internal cost structures may not help consumers and could, in fact, be counterproductive.

According to the submission, too much detail about internal financial workings could become overwhelming, undermining trust without offering genuinely useful information to customers. TISA has cautioned that the rules as currently proposed could also discourage the provision of targeted support to members of trust-based pension schemes, eliminating a potential benefit for those savers.

Industry collaboration

The Investing and Saving Alliance reiterated its willingness to work with the FCA and industry stakeholders on refining the targeted support framework. The organisation maintains that the overall potential of the regime is positive but that its successful implementation depends on rules that support both consumers and the operational realities of firms.

TISA's consultation response reflects broader industry engagement with the FCA's evolving approach to consumer support and regulatory policy, as the sector seeks to balance regulatory objectives with practical service delivery and consumer needs.