Send Emails in Microsoft Access with VBA Programming Code in Total Access Emailer and Distribution #microsoft #access #email,programming,e-mail,vba,module,code, #distribution, #runtime, #library, #microsoft #access,ms #access,programmatic,total #access #emailer


Sending Microsoft Access Email Blasts Programmatically (VBA)

The add-in Wizard in Total Access Emailer lets you interactively create the email blasts you want to send from Microsoft Access.

In the Professional Version. Total Access Emailer offers a VBA programmatic interface that lets you run these email blasts from your MS Access code. This can be tied to an event (for instance, a button click), a macro via the RunCode action, or within your other VBA processes.

The nice thing is the complexity of creating, specifying all the options, and testing/previewing the email blast can be done interactively through the add-in, and you simply launch it in your code.


Interactive VBA Code Generator

Total Access Emailer add-in includes a Code Generator that lets you interactively choose to run or preview the email blast, specify other options, and see the corresponding VBA code for the currently selected email blast. Then paste the code into your module to run your email blast.

Code Generator to Send or Preview Email Blasts from Total Access Emailer

Sending an Email Blast from Microsoft Access

By adding Total Access Emailer’s royalty-free runtime distribution file as a library reference to your project, you can invoke its procedure. Any email blast created by the add-in can be added to your application with a simple function call. Each email blast is given a number. In this example, email blast #25 is sent:

That’s all you need to add the sophisticated email features of Total Access Emailer into your applications. The user interface can be completely hidden so your users don’t even realize Total Access Emailer is running in the background. You control your user’s experience.

Procedure Definition

Procedure Parameters

These parameters are available to customize how your email blast is sent. You can choose to have Total Access Emailer display its progress screens with your title, or hide it completely from your user.

ERP Software Cost Comparison: On-Premise, SaaS, and Hosted #accounting # # #erp #software,cloud,costs,hosted,pricing,saas,software,erp, #cloud, #saas, #software, #accounting, #statistics, #var, #reseller, #distribution


ERP Software Cost Comparison: On-Premise, SaaS, and Hosted


This article presents costs associated with different ERP software deployment scenarios. The numbers presented in this article have been gathered by averaging quotes provided by 2-3 different ERP and hosting service providers.

ERP Software Purchasing and Deployment Options

The Cloud has inspired a new way of thinking about ERP software deployments. Companies have the option to purchase a license or purchase a SaaS solution. When purchasing a license you own the software and have the ability to deploy it in your datacenter (on-premise) or outsource operations to an external provider (hosting). When you purchase a SaaS solution (sometimes called an on-demand solution), you rent a complete turnkey package that includes software and the entire delivery mechanism.

This article will examine the financial ramifications of these three models on your business.

Small Customer Licensing

With a very small deployment scenario, the cost of licensing the software is $20,000 and the cost of one year of SaaS is $16,000. The resulting chart (on the left below) shows that a SaaS deployment can provide lower costs in year one, but after 2-3 years of service, the hosted model can be less expensive in terms of total out-of-pocket money.

By looking at the graph, you would conclude that you should never purchase a software license and try to build your own infrastructure. However, in some scenarios (for example you are are running a point-of-sale terminal that needs to connect to your server) an on-premise deployment makes sense because you may not want to rely on an external Internet connection.

Mid-Sized Customer Licensing

For mid-sized businesses, we increased the cost of the license to $50,000 and the cost of SaaS to $40,000 per year. The resulting chart (above on the left) shows that the break even point for SaaS versus hosting occurs sooner (around year 2). In year 5 the cost of SaaS approaches the cost of a license plus internal infrastructure. These changes occured because the cost of the fixed license and recurring SaaS payments increased proportionately while the infrastructure cost remained relatively fixed. We observed a proportionate increase in SaaS and license pricing by comparing specific customer proposals from SaaS and license vendors.

Even though we increased the cost of hosting to $500/month, the cost of paying for 1/5 of an IT person to maintain the server, operating system, and software application caused the on-premise deployment to be more expensive than hosting over the long run.

Review of Assumptions

Cloud-based and Web-based Software

As previously reported, there has been significant discussion judging the merits of hosted ERP versus SaaS. In this comparison, we assume that the same software can be run as SaaS or deployed on-premise. This means that we are not considering the scenario where legacy client-server software is being hosted on the web along with VPN software, hosted desktops, etc.

We assumed that the software was web-based so client upgrades are not required.

Relationship between SaaS and License Pricing

The cost of the SaaS annual fee compared to the cost of the software license is critical to the analysis. For this analysis we used the following rule-of-thumb:

SaaS annual price = (2/3) x (Cost of license + One year maintenance)

This approximation accurately represents actual market data provided by SaaS providers and on-premise license providers. In both cases, the cost per user (when applicable) is reduced as more users are added at approximately the same rate. Also in both cases, the addition of modules increases the cost.

Other Assumptions

  • Calculations did not include NPV calculations.
  • Hardware and software costs for an on-premise deployment are similar for small and mid-sized customers. This equals approximately $15,000 for the deployments shown. This does not include off-site backup storage.
  • Maintenance fees are 20% per year of the license costs. In the hosting scenario, maintenance covers only the application, in the on-premise scenario the maintenance costs cover the application, OS, and database software.
  • Configuration, training, and data migration fees are equal across all three deployment models. We used a 1:1 ratio of license cost to consulting fees for this analysis.
  • Customization fees are not included, but would be equal across all models.
  • Application support is not included, but would be equal across all models.
  • For an on-premise deployment, power and replacement server parts were assumed to cost $1,000/year.

When is SaaS Better?

Businesses benefit from SaaS when they do not have IT resources to dedicate to installing and managing applications. Even in the hosted scenario, some level of IT expertise is required to install application upgrades. We assumed upgrades occur two times per year and require approximately 5 hours to install. As a result of this assumption, we budgeted $1,000/year for application upgrades in the hosting scenario. In all cases we assumed that the application was web-based so no client software upgrades were required.

Break Even for Mid-Sized Businesses

By lowering the SaaS cost by changing the SaaS rule of thumb (discussed earlier), we computed a break even point over a seven year deployment. Holding other assumptions steady, the break-even occurred when the cost of the SaaS annual fee is approximately 1/3 of the cost of the license plus one year of annual maintenance. So, if your only concern is out-of-pocket expenses, the option to purchase a $50,000 license + hosting + maintenance is roughly equivalent to a $20,000/year SaaS license.

Adding Cost of Capital

** section added May 2 **
After publishing this article, I received several requests to include the cost of capital in my calculations. Adding a cost of capital has the following impact on the different models:

  • SaaS expenses are deferred, so the model becomes more attractive as the cost of capital goes up.
  • Hosted the license cost is paid upfront, but some costs are deferred, so the benefits are less than with SaaS
  • On-Premise the on premise model contains the most upfront expenses as well as significant ongoing IT expenses that paid over time. As the cost of capital increases, the upfront costs are not impacted, but the impact of the ongoing IT costs is reduced so that the overall benefit is higher than hosted but less than SaaS.

Cost of Capital Impact on ERP Analysis

With ERP software there is a significant amount of upfront analysis, consulting, configuration, testing, and training, so the impact of the cost of capital is less than it would be for simple software applications. The graphs below show the impact of making adding a 3% and a 15% cost of capital to the analysis. This was done by discounting the future payments to reflect the time value of money.

The analysis doesn t change dramatically for the 3% case, but when the cost of capital is assumed to be 15% and higher, the SaaS solution will always be less expensive than an on-premise solution. At 15%, the breakeven between SaaS and hosted shifts by a few months in favor of SaaS.
** end of May 2 section **


This article addressed costs, but costs are only one part of the deployment equation. Your deployment model should be based on your level of IT expertise, your comfort level with outsourcing, the strength of your Internet connection and tolerance for downtime, and the timing of expenses.

As your business changes, your business requirements change. Company size, IT expertise, legislation, risk, programming requirements, and other factors will influence your SaaS versus on-premise deployment over time. You should partner with a provider that offers a choice of license and SaaS deployments so you can switch your deployment as your requirements change.

Contact us if you would like to receive a copy of the spreadsheet used to generate these graphs.

Related Posts

Retail, Wholesale – Distribution – Perspectives, insights and analysis for Consumer Business #retail #trends

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ULTA Beauty Careers – Retail, Salon, Distribution – Home Office Careers #retail #jobs #in #chicago

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The Beautiful Journey

Our first store opened its doors in the suburbs of Chicago in 1990. From the beginning, we set out to do beauty differently. We had a vision to create a world of fun and exploration. Over the years, that’s exactly what we’ve done, and along the way we’ve established ourselves a premier beauty destination. With a wide variety of brands to choose from, including everything from the broadly appealing to the niche, across every price point, we brought the best the beauty world had to offer in makeup, fragrance, skincare and haircare, together in one place. And a full-service salon in every store too – revolutionizing the beauty experience for all.

Ulta Beauty You

As a high-growth, fast-paced retailer led by Fortune’s #6 Businessperson of the Year with more than 30,000 associates in 48 states, Ulta Beauty offers rewarding career opportunities at our 900+ retail stores and salons, five distribution centers and corporate office. We are driving industry leading results, leading through a shared set of values, and together becoming the most loved and admired beauty destination.

It’s a great time to be on the fun side of beauty.

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Retail and Distribution Industry #retail #store #software

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Retail Distribution

Key issues affecting retailers​

The digital landscape: New technologies are fundamentally transforming how, when, and where consumers shop. Retailers able to leverage mobile and social tools to improve the customer experience and provide multiple buying channels can be well positioned for success. As shoppers demand more real-time, personalized information and offers, retailers will need to surround this service with strong privacy and security measures.

Store of the future: With more options for consumers to buy online or through their mobile devices, the physical ‘box’ is shifting from a transaction enabler to brand experience.

Real estate shift: As sales continue to shift out of stores to online, it will be important for retailers to reassess their space and location requirements as the purpose of the store evolves.

Global expansion: International expansion affords access to new markets, some with high-growth consumer incomes. Identifying the appropriate method of market entry will be important to ensuring sustainable results for retailers.

Regulatory pressures: The changing regulatory landscape is likely to have a significant impact on the retail sector. How retailers prepare for these changes and implement strategies to limit business disruption will likely be critical to their future success.

Innovation: After decades of growth through new store development, retailers are investing more in innovation and data analytics. Retailers must continue to challenge themselves to think differently about how technology and science are changing the nature of commerce.

The talent imperative: Having the right talent can help retailers delight customers, differentiate from the competition, and achieve profitability and growth goals. A diverse workforce serving a broadened customer base is an important success factor that can improve service outcomes and enhance financial performance.​ ​

Key issues affecting wholesale distributors​

Advanced analytics: The wholesale distribution industry is one of the more complex industries driven by the high number of SKUs, customers, suppliers and transactions, and their pricing and rebate structures. Distributors are beginning to see the value in advanced analytics to solve industry pain points in areas such as pricing, rebates management, and inventory optimization.

Customer experience: The confluence of a massive generational shift at distributors and among their customers, coupled with advances in technology and technology adoption is creating an opportunity to change the nature of the distributor-customer interaction.

Margin improvement: Financial pressure from the board, shareholders and competitors continues to be a key issue for wholesale distributors in the areas of sourcing, rebates and chargebacks, pricing, and supply chain improvement to improve margins.

Mergers and acquisitions (M A): Industry consolidation will likely continue to be a key growth driver for wholesale distribution which remains highly fragmented. Acquisitions will likely shift from incremental acquisitions (adding customers, products, geographies, etc.) to transformational/ strategic M A plays. Distributors will need to approach the M A process differently than they traditionally have, moving from a focus on small or niche transactions to larger, more strategic deals that bring scale advantages and strengthen channel position.

Omni-commerce: While a few distributors have highly developed digital capabilities and are generating meaningful revenues via mobile and e-Commerce channels, most are still in the early stages of development and adoption. Regardless of line of trade or company size, the ability to offer customers—or in many cases drive customers—to digital channels is very important.

Technology: As the wholesale distribution industry evolves, many distributors are still operating with fragmented, legacy IT systems. With inadequate technology in place, modernizing enterprise resource planning (ERP) systems might be a priority for the sector this coming year. As the industry matures, edge applications such as transportation management system/warehouse management system, mobility, and e-Commerce are expected to become more important to differentiate distributors from the competition.

Value chain disruptions: New business models can drive growth for some distributors or create significant disruption in the value chain for others. Managing these shifts to ensure sustainable business performance is a priority for wholesale distributors, particularly as new competitors emerge and apply additional pressures.​

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Retail Distribution Review Update #online #shooping

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Retail Distribution Review Update

By Paul Kruger on 18 November 2013

Up to the end of the previous century, regulation of financial services was by and large left in the hands of the industry itself. The advent of consumerism and money laundering, amongst others, and despite being strange bedfellows, led to more and more concerns about how matters were run in the industry, and led to the publication of the FAIS Act in 2002.

Possibly the single biggest trigger for active involvement came from a paper delivered by Rob Rusconi in 2004 to the Actuarial Society, in which he highlighted the negative effect of costs on returns of contractual savings products.

This led to an investigation by government, and the eventual signing of a “Statement of Intent” in 2005 which saw billions being repaid to clients, and “causal events” charges being capped.

A further outflow of this was the publication of the Discussion Paper on Contractual Savings, the first phase of which saw a 50% reduction of upfront commission for these products. This document set the tone for a major Retail Distribution Review (RDR) in the years to come.

The way forward
In an address at the FSB’s Insurance Regulatory Seminar on 31 October 2013, the Regulator expanded on phase 2 of the RDR, which proposes to deal with inherent conflicts of interest in the relationship between product providers and intermediaries. This phase will include determining just what “independent” advice comprises, and a further review of remuneration models.

Factors which will influence the local roll-out of the second phase include international developments such as the RDR implementation in the UK in 2013 and Australia’s “Future of Finance”. Local interventions, and notably Treating Customers Fairly and the Twin Peaks model of regulation will interact to form what is hopefully a safer environment for consumers.

Two years ago, the Insurance Division of the FSB called for contributions on intermediary services and related remuneration with two objectives in mind:

  • To promote appropriate, affordable and fair advice and intermediary services and
  • To support a sustainable business model for financial advice

In November 2012, the FSB shared its initial responses. It concluded that “…a broader, cross-cutting RDR is required under the broader TCF banner, and this should not be limited to insurance, nor focussed on remuneration only.”

The Regulator indicated that any reforms should take into account South African conditions, and not blindly follow events elsewhere in the world. It should also continue to support financial inclusion for all, and not become the prerogative of the rich.

One of the broader objectives of RDR is to apply the inherent principles consistently across all financial sectors, rather than only where investments are concerned, and ensuring that all distribution models support the key TCF outcomes.

Assessment of the current landscape
The Regulator identified three areas of risk which need to be considered in the review of product distribution:

The risks to customers:

  • Conflicts of interest
  • High (sometimes hidden) impact of intermediation/advice costs on product value
  • Accountability for quality of advice and customer outcomes not always clear

Risks to intermediaries:

  • Not always properly remunerated for advice
  • Value of intermediaries’ services not properly recognised
  • Up-front commission not a sustainable business model
  • Inappropriate incentives expose intermediaries to regulatory risk

Risks to effective supervision:

  • Imbalances in product supplier/intermediary responsibilities
  • Standards for intermediaries not always proportionate
  • Some products related advice fall outside regulatory net

The current model also contains benefits which should be recognised and accommodated:

Ease of payment for advice

  • The collection of advice fees, paid in instalments, and facilitated by the product provider

Cross-subsidisation in favour of low-income customers

  • Recognition that, in any new system, it may not be feasible for the cost of advice to be fully paid for directly by low-income customers, and

Professionalisation of the financial advice and intermediary sector

  • The industry should build on the strengths of the FAIS framework, allowing for proportionality and effective mechanisms for product-specific training and continuous professional development.

Key FSB Proposals

  1. Move to a component/activity-based approach to regulating advice and intermediation
  2. Clarify contractual relationships for different forms of intermediation to avoid consumer confusion
  3. Remuneration should be linked to the activity-based approach
  4. “Conflicted remuneration” should be addressed and
  5. The FAIS framework should be reviewed.

In comparing the current views to the original thinking in 2011, it is clear that the dialogue between the industry and the Regulator has led to a more pragmatic approach which will be beneficial to consumers and the industry.

Retail Distribution Review – Barclays Stockbrokers #retail #online #stores

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Investing in funds: what’s changed?

In 2014 the Financial Conduct Authority (FCA), our regulator, changed the way providers of investment products and services charge their customers. These changes, part of the Retail Distribution Review (known as RDR), make it easier to understand who you are paying, how much, and what those charges relate to.

We’ve applied the new regulations to all funds bought through Barclays Stockbrokers since 1 March 2014. We also then actively converted clients’ existing fund holdings from bundled to ‘clean share classes’, so that you benefitted from the lower charges as soon as possible.

As a result the cost of investing in funds has reduced for most Barclays Stockbrokers clients. Previously the cost of administering your fund investments was met by payments we received from the fund manager, which was paid out of the Annual Management Charge (AMC) the fund manager charged you for investing in their fund.

The new rules mean that you now pay us a separate Fund Administration Fee for the administration of your fund, and the AMC applied by the fund manager is often lower.

The key changes we have made are:

In 2014

  • Access to new, lower cost ‘clean share classes’ from fund managers who no longer pay us trail commission
  • Converted existing fund holdings to clean share classes where we believed this was beneficial to you
  • Introduced a Fund Administration Fee, payable directly to Barclays Stockbrokers.

In November 2015

  • Converted most remaining holdings to clean shareclasses where available
  • Confirmation given where no conversion is possible, for most remaining holdings.


  • From 1 January all fund holdings are liable to the Fund Administration Fee
  • A small number of funds remain to be converted to a cheaper version, or confirmed that no cheaper version is available. Until this is confirmed we will waive the Fund Administration Fee on the holding. We receive no trail commission on these holdings.

View our video

Our video explains the RDR changes and the benefits for investors.

Post-implementation review of the Retail Distribution Review #careers #in #retail #management

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Post-implementation review of the Retail Distribution Review

We publish the findings from the first stage of our post-implementation review of the Retail Distribution Review.

The RDR was launched by the Financial Services Authority, the predecessor body of the FCA, in 2006. The rules aimed to make the retail investment market work better for consumers. They raised the minimum level of adviser qualifications, improved the transparency of charges and services and removed commission payments to advisers and platforms from product providers.

While developing the RDR proposals we committed to undertaking a post-implementation review to help us determine the extent to which the RDR was delivering the outcomes it was designed to achieve.

The majority of rules were required to be implemented by the end of 2012. As we are now approaching two years since RDR implementation we have commenced the first phase of the post-implementation review and commissioned external consultants, Europe Economics, to undertake the review so as to ensure its independence.

The first phase of the post-implementation review aims to indicate the extent to which the RDR is on course to deliver its original aims and to flag any immediate issues, rather than definitively evaluate whether or not all of the expected impacts of the RDR have materialised, which will take much longer.

Who is the review aimed at?

This report will be of interest to:

  • Firms operating in the retail investment market
  • Consumer groups and consumers active in the retail investment market
  • Parties interested in the work of the FCA and its performance and accountability

What are the next steps

  • The next phase of the post-implementation review will be published in 2017 followed by a subsequent third phase of the review which will consider the longer-term implications.
  • In the meantime we will continue to monitor trends throughout the post-implementation review period.
  • We will also take action in the following areas:
    • Consumer understanding of advice offered – We are interested in hearing stakeholders’ ideas for better ways to present information to consumers on the nature of advice services offered and advice charges. This work will form part of the FCA’s wider work on the provision of information to consumers, due for publication in Q1 2015.
    • Innovation in advice models – We are keen to remove unnecessary regulatory obstacles that may stand in the way of innovations in advice models. In January, we will publish guidance in relation to sales that do or do not involve a personal recommendation. We also recently launched Project Innovate, an opportunity for businesses wishing to develop new simplified advice or other innovation which benefits consumers.

How can I find out more?

Retail Distribution Review South Africa 2016 #retail #training

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Retail Distribution Review

What is Retail Distribution Review (RDR)?

The Retail Distribution Review (RDR) proposes significant regulatory reform. As with any change in legislation, financial services providers (FSPs) will have to adapt to and change some of the ways in which they do business to comply with new requirements. We provide support to our clients by keeping them up to date with changes, helping them to identify how proposed changes may impact them and providing solutions that can be implemented to protect the integrity of their licence so that business can continue.

This ongoing support gives our clients peace of mind and places valuable client-facing time back into the hands of the FSP, which they would otherwise have had to expend to understand the changes and develop their own systems. As part of our RDR focus, we have previously released RDR special edition newsletters and videos in an effort to continuously keep our clients informed and up-to-date.

FSB Documents


1. The Retail Distribution Review paper

The much anticipated Retail Distribution Review (RDR) paper has finally been published for comment.

2. Will your value proposition stand the test of time?

Masthead focuses on advice: what the FSB proposes about advice services and what you need to do to build a strong value proposition based on your choice of advice services.

3. Define and refine your activities so customers know what they re paying for

  1. Remuneration for financial planning. Masthead explores the FSB’s proposed remuneration structures for services/activities delivered to customers, with a specific focus on financial planning advice. Click to read more
  2. Services Connecting Customer and Product Supplier. The RDR proposals seek to give retail customers confidence in the retail financial services market. Masthead looks at some of the services that connect product suppliers and customers, how the FSB separates the activity of sales from ongoing product maintenance/servicing and how advisors can be remunerated for these services. Click to read more
  3. The end of SIGN-ON bonus. The sign-on bonus ban” has become reality as Board Notice 146/2014 was published on 4 December 2014, incorporating its provisions into the General Code of Conduct (the Code) and amending the Code. Click to read more

4. Re-balancing responsibilities for ensuring fair customer outcomes

Masthead looks at the responsibilities of product suppliers in ensuring fair customer outcomes. Under the current regulatory framework, responsibility for fair customer outcomes, particularly in relation to advice, has largely been placed on financial advisors. The aim of the Regulator is to re-balance this responsibility by requiring product suppliers to get involved. Click to read more

5. Unlock your remuneration potential by defining your customer interactions

Income is the lifeblood of any business. After all, this provides the cash flow. The most pressing question is therefore, How will the RDR proposals affect advisors’ ability to earn a sustainable income, sufficient to meet expenses and maintain current lifestyles both in the medium and longer term?” To answer this question, one needs to understand the different ways proposed for an advisor to be paid, by whom and how this differs between product types. Click to read more

6. How will your status impact your customer relations?

The 55 proposals contained in the Retail Distribution Review (RDR) discussion paper can be grouped into three categories. In previous editions Masthead has focused on activity-based services and remuneration. In this edition, Masthead deals with the relationship or status of advisors under RDR. The reason for this is because relationship and status, together with activities, feed into remuneration under RDR. Click to read more

7. Financial planning criteria and hybrid advice models

Under RDR, all types of financial advisors will be able to offer financial planning or risk planning as a service to their customers. However, there will be competence criteria that they will be expected to meet and conduct standards to which they will have to adhere. Click to read more

8. Masthead submits RDR feedback to FSB after engaging with over 700 IFAs

As part of the consultation process the FSB invited feedback on the paper. So, over a period of about 12 weeks, we helped our IFAs to come to grips with the RDR paper. More recently we ran 20 workshops around the country, with over 700 IFAs attending. We used these sessions, as well as numerous email and telephonic comments as a basis for our input from IFAs. This detailed feedback was submitted to the FSB. Click here to read our feedback.


  1. How advisors really feel about RDR
    In this video, Ian Middleton, managing director of Masthead, gives more insight into how advisors feel about RDR.
  • Advisor reaction to RDR objectives
    Masthead has been hosting RDR sessions around the country since mid-January. These sessions focus on sharing the content of the RDR discussion paper and gathering input from advisors. The input gathered will be submitted as Masthead’s feedback to the FSB in early March. In this video, Ian Middleton, managing director of Masthead, shares some thoughts, reactions and observations that have come out of the sessions thus far.
  • The impact of RDR on consumers, advisors and product suppliers
    Ian Middleton, managing director of Masthead, tackles the burning question everyone is asking: What are the impacts of RDR?” He provides a concise overview of how RDR is likely to affect consumers, financial advisors and product suppliers.
  • Is Retail Distribution Review (RDR) out to get advisors?
    In episodes 1 and 2 of Mastering Compliance Special Edition. Masthead looked at the way the FSB categorises the activities of advisors. In this video, Ian Middleton, managing director of Masthead, focuses on why this is important and comments on whether RDR is ‘out to get advisors’.

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  • Retail Distribution Review Discussion Paper #internet #retailer

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    Retail Distribution Review Discussion Paper

    By Paul Kruger on 11 November 2014

    While the general expectation is that this document’s sole intention is to replace commission with fees, it is far more encompassing than that. We publish below some of the aspects contained in the management summary, and will dwell on these in more detail over the next few weeks.

    The review was undertaken in response to the fact that, despite the significant progress achieved through the Financial Advisory and Intermediary Services (FAIS) Act in raising intermediary professionalism, improving disclosure to clients and mitigating certain conflicts of interest, significant concerns about poor customer outcomes and miss-selling of financial products remain.

    This paper outlines a number of key risks inherent in the current distribution landscape, including distribution relationships and intermediary remuneration models that contribute to poor outcomes and miss-selling, and puts forward a number of proposals aimed at addressing these risks. The review outlines a more proactive and interventionist regulatory approach; it proposes a shift away from a purely rules-based compliance approach to one that also sees the introduction of a set of structural interventions designed to change incentives, relationships and business models in the market in a way that supports the consistent delivery of fair outcomes to customers.

    Key structural changes include placing greater responsibility on product suppliers for ensuring the delivery of fair customer outcomes through their chosen distribution channel; limitations on the types of remuneration that intermediaries can earn and from whom, designed to address conflicts of interest; and enabling customers to understand and compare the nature, value and cost of advice and other services that intermediaries provide. These changes should also support the development of more competitive markets and the development of more transparent and fair products.

    Structure of the paper

    Chapter 1 outlines the context, scope and objectives of the RDR.

    Chapter 2 describes the current financial services distribution landscape in South Africa, which is characterised by a wide and complex range of distribution models. The paper describes the current distribution landscape from three perspectives: Types of service provided by intermediaries; types of relationships between intermediaries and product suppliers; and types of remuneration earned for the services concerned.

    Chapter 3 outlines risks and benefits of the current distribution landscape. It highlights that aspects of the current distribution landscape pose risks not only to fair customer outcomes, but also to intermediary sustainability and supervisory effectiveness.

    Chapter 4 sets out a range of specific regulatory policy proposals to meet the desired RDR outcomes. A total of 55 specific proposals is put forward for discussion and comment. The proposals aim to rationalise the complex distribution landscape outlined in the paper, in order to address the various risks the paper highlights. The proposals are grouped around:

    • The types of services provided by intermediaries to customers and product suppliers respectively, proposing an activity-based approach to categorising these services.
    • Rationalisation of the range of relationships between product suppliers and intermediaries. Proposals under this heading also address the responsibility of product suppliers for advice and intermediary/outsourced services provided.
    • The types of intermediary remuneration models that should apply to the revised sets of services and relationships proposed, including measures to deal with conflicts of interest in the provision of financial advice.

    Chapter 5 outlines the implications for the regulatory framework in order to give effect to these proposals. The changes will be implemented in a phased manner; some changes will be carried out within the current regulatory framework, while other changes will be implemented as the Twin Peaks legislative framework evolves.

    Lastly, Chapter 6 provides some concluding comments and maps out the way forward, including some comments on transitional measures.

    We strongly suggest that the paper be read in its entirety, rather than selectively. In view of concerns about changes to the current remuneration model, though, we publish below a brief summary to allay some concerns:

    Proposals relating to intermediary remuneration

    Greater clarity on the activities that make up advice, intermediation and outsourced services respectively, as well as on whose behalf the services are rendered, creates the foundation for a clearer set of principles and rules for intermediary remuneration. To achieve the desired RDR outcomes, it is proposed that the future regulatory framework for intermediary remuneration should meet the following criteria:

    • Intermediary remuneration should not contribute to conflicts of interest that may undermine suitable product advice and fair outcomes for customers. As part of this aim, intermediary remuneration should not undermine reasonable customer benefit expectations or inhibit customers’ access to their savings (such as through early termination charges designed to recover commission costs)
    • The regulatory framework should recognise the range of services available, the related remuneration for these, and whom may pay or receive it
    • All remuneration must be reasonable and commensurate with the actual services rendered
    • Remuneration structures should strike a balance between supporting ongoing service and adequately compensating intermediaries for up-front advice and intermediary services
    • Ongoing fees and/or commission may only be paid if ongoing advice and services are indeed rendered
    • An intermediary may not be remunerated for the same or a similar service twice
    • All fees paid by customers must be motivated, disclosed and explicitly agreed to by the customer
    • The different types of services and fees should be readily comparable by customers; and
    • Remuneration structures should promote a level playing field between different types of intermediaries providing similar services.

    We are attending the FSB’s Insurance Regulatory Seminar today, and will be conducting information sessions to report back on the practical aspects. More detail to follow soon.