Inopportune opportunism 

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No doubt we've all seen those images of shoppers filling their boots, and just about every other receptacle, at this time of crisis.  Despite every media and government appeal for the population to behave in a responsible, public-spirited way, the shelves are still being stripped by those who apparently believe that The End of The World is Nigh, and are determined that their family are going to survive, and blow the rest.  Darwin's theory needs to be retitled, 'Survival of the Fattest'.

It's not pretty, this kind of behaviour.  And we all know it's not admirable, or moral, or constructive in any way - it is just that, for some people, a kind of pathological self-interest takes over, submerging all of their better impulses.

Spookily, there's something similar going on, in Regulation World.  Out of the blue, the FOS is suddenly sending out ultimatums in relation to cases which have been languishing on their desks for the last six months.  After such a lengthy hiatus, being given four days to respond would seem to most impartial observers to be a kind of gamesmanship, rather than indicative of a process which has at its core even a nodding acquaintance with concepts such as fairness or proportionality.  The fact that these cases are arriving in clusters, right after the Government began constraining commercial activity is suggestive that the strategy is intentional.  This is, in a sense, merely an escalation of a particular game that the FOS has been playing for years - a complete silence, lasting several months, is the FOS's response to a carefully documented analysis of what it is legitimate for one to conclude where there is a complete absence of concrete data supporting a claim for redress.  Suddenly, at around 17.00 hours on a Friday afternoon, there comes an email giving a seven-day response deadline, and ignoring pretty much everything that has already been documented.

It's not pretty, this kind of behaviour.  Indeed, it seems reasonable to conclude that these kinds of tactic are inevitable when a commitment to principle and truth has been sidelined, in pursuit of an ideology where the ends justify any means.  When there is nothing objective to work on, all that is left is playing the game, the illusion of due process.  These byproducts of regulatory culture are so unprincipled and venal in their underlying nature, that the temptation is to succumb to cynicism, and drop our standards, but that would be a mistake - the IFA community is much better than that.

There is an 'opportunism' which is valid, at times like this:

  • reach out to clients and provide reassurance, especially when investment markets are demonstrating increased volatility
  • ValidPath Members' admin systems allow us to categorise our vulnerable clients - so use that facility to offer additional support, where that is indicated.  If elderly and vulnerable clients are self-isolating, then just having some contact may be beneficial to them
  • make yourself available to the friends and family of good clients, who may not themselves have the benefit of a good IFA, and might therefore be anxious about the kinds of matter which require your expertise
  • write short, practical blogposts which clients (and others) can access, which will help them to stay financially safe - especially when those less ethical opportunists are making hay during the pandemic - and encourage access to them by using social media
  • compensate for the lack of opportunity for direct contact by leveraging your technology - Zoom, Join.Me, FaceTime, Google Hangouts and all these systems are great at facilitating 'face to face' communication.  And do it often!
  • prepare for the return of normality - we don't know when this will be, but the current measures won't last forever
  • for those clients who are able to afford to continue to make regular pension and ISA contributions, encourage them to do so - historic data is supportive of the view that crises such as this represent beneficial buying opportunities

It is a truism that we are living in difficult times.  It is also true that we can benefit from challenges by upping our game.  We look to help safeguard our existing clients, and to identify others who need the kind of support that only we can provide.

Kevin Moss, 24/03/2020