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Getting closer to your drawdown clientsHow to use segmentation and the PROD rules

to your advantage

THIS IS FOR FINANCIAL ADVISER USE ONLY AND SHOULDN’T BE RELIED UPON BY ANY OTHER PERSON

2 - Getting closer to your drawdown clients

Getting closer to your drawdown clients - 3

What’s inside

4 Introduction and executive summary

6 Defining our terms

10 Developing an evidence-based picture of your current business

14 A ready-to-use segmentation approach

19 Changing customer needs

20 Putting it into action

23 Conclusion: it was always about suitability


Introduction and executive summary

It will come as no surprise to readers of this paper that retirement is a hot topic. More specifically, giving advice to clients near or in retirement is an area of keen interest.

That holds true for the media, for the regulator, and of course, for clients themselves. As advisers, you arguably have more power to help clients at this crucial stage of their lives than at any other.

It may come as no surprise, then, that in their 2019/20 business plan, the Financial Conduct Authority (FCA) clearly signalled their intent with regards to protecting consumers entering and in retirement, and the expectations it has of the industry to help nudge those consumers to act in their own best interests. It’s in the interests of every adviser to make sure that they’re fully up to date with evolving regulatory expectations.

In this paper, we’ll look at retirement income planning with the regulatory landscape in mind. We’ll take the Product Intervention and Product Governance Sourcebook (PROD)

rules on identifying target markets and use it as a regulatory nudge to review and refresh client segments.

We’ll look at how life-stage segmentations work in some detail, and show one framework which we think may be of use: it helps that this is one which the regulator itself has used in the past.

As a guide to segmentation, with a focus on clients in decumulation, we cover:

• what PROD says and what it means;

• a practical way of identifying target client groups;

• what some of those target groups might look like;

• possible paths their retirements may follow; and

• some points to keep in mind for your business.

Following best practice means a lot of what we cover here will likely be second nature to you, but for completeness we have included all the steps advisers have told us they found useful when they’ve segmented their own client books. If nothing else, it will hopefully serve as a useful aide memoire as more and more clients enter this profoundly sensitive and important life stage.

1. www.fca.org.uk/publications/policy-statements/ps19-21-retirement-outcomes-review-feedback-cp19-5


Why segmentation matters

The Retirement Outcomes Review is an integral part of the FCA’s plan brought to life. Ahead of publishing ROR policy statement 19/211 , the FCA commissioned NatCen Social Research, supported by the Pensions Policy Institute, to investigate consumer engagement in investment decisions at retirement. The findings exposed the fact that the majority of non-advised consumers moved into drawdown to get access to their Pension Commencement Lump Sum (PCLS) and not because they were interested in the product in its own right.

Drawdown as a ‘by-product’ is in nobody’s interest.

We hope you find this paper useful.

When it comes to navigating the route to and through retirement, your clients are lucky enough to have a professional adviser to guide them. The respondents in the NatCen research were not. However, the respondents’ behaviour speaks to a common theme, whether advised or non-advised, and that is that people respond emotionally at times when we expect and need them to be logical.

How to engage your clients on an emotional level to ensure they fully understand the implications of the decisions they make in the lead up to, at, and through retirement is at the heart of the advice process.

Helping consumers engage with their retirement income plans starts with understanding the emotional drivers of the people at the heart of those plans – and where advice comes into its own. Segmentation provides a solid and scalable foundation from which to build distribution strategy for your clearly defined target markets.


Defining our terms

PROD, decumulation, segmentation and other words that didn’t exist when you were at school.

This paper is all about demonstrating ways in which you can use the new(ish) PROD rules2 to your advantage in your business. As we’ll see, its focus on finding common threads of suitability in groups of clients is a great entry point for creating and delivering advice propositions which are economic for you and beneficial for your clients.

We’re concentrating on clients at and approaching retirement. That’s for two reasons:

1. it’s a crucial growth area for many adviser firms; and

2. while many firms have cracked the concept of creating distinct service propositions for clients who are accumulating wealth (one for entrepreneurs; one for senior medical professionals and so on), fewer firms make formal distinctions for clients in retirement. Recent research suggests that fewer than 20%3 of firms offer a different investment proposition to retired clients than to accumulation clients.

We intend to make this paper thought-provoking, relevant and practical. But before we do, let’s start by defining our terms, so we are all confident we’re talking about the same things.

PROD

The mere mention of MiFID II (the second Markets in Financial Instruments Directive) is likely to elicit a groan from any regulated firm, and to date the PROD rules contained within MiFID II have been met with the same weary resignation.

Introduced in January 2018, their aim is to make adviser firms (described as ‘distributors’ in the rules) provide proof that the products they recommend meet the needs of an identifiable target market, deliver good outcomes, and are sold to the right clients.

These are rules (as opposed to guidance), and as such breaches could result in enforcement action.

The regulator will be looking to see that you are clear on your target market and, using a combination of provider material and your own client information, you can clearly define your distribution strategy.

Importantly, PROD also requires you to identify any groups of clients for whom a product or service is not suitable. This concept of ‘negative suitability’ is new and an interesting departure for the regulator. It also forces you to think more carefully about exactly what each element of the proposition you put together for clients means.

You can see a direct quote of the relevant sections of PROD (generally 3.3.9 to 3.3.12) in the box opposite.

2. www.handbook.fca.org.uk/handbook/PROD.pdf 3. State of the Adviser Nation, the Lang Cat, November 2018


Target market and distribution strategy

3.3.9 R Distributors must determine the target market for the respective financial instrument, even if the target market was not defined by the manufacturer.

[Note: article 10(1) of the MiFID Delegated Directive]

3.3.10 R Distributors must identify the target market and their distribution strategy using:

1. the information obtained from the manufacturers; and

2. information they have on their own clients.

3.3.11 G In identifying the target market and creating a distribution strategy, distributors should consider:

1. the nature of the financial instruments to be offered or recommended and how they fit with end clients’ needs and risk appetite;

2. the impact of charges on end clients;

3. the financial strength of the manufacturer; and

4. where information is available on the manufacturer’s processes, how efficiently and reliably the manufacturer will deal with the end client at the point of the sale or subsequently, such as when complaints arise, claims are made or the financial instrument reaches maturity.

3.3.12 G The target market identified by distributors for each financial instrument should be identified at a sufficiently granular level.


Segmentation

While PROD itself doesn’t mandate any kind of segmentation approach, when it comes to applying robust processes for determining target markets, it’s an obvious starting point.

Segmentation isn’t hard as a concept, but it can be challenging in practice. Here are a few basics to remember. Segments you choose should be:

ATTRIBUTE DEFINITION APPLICABLE TO DECUMULATION?

Meaningful The attributes of the segment should be common within the segment and different across segments.

We’ll aim to demonstrate this in the coming pages but clients in decumulation certainly exhibit a wide range of needs and behaviours.

Actionable You have to be able to do something with the segment. Creating a segment based on something you can’t reasonably measure won’t work.

Basic factfinding will provide sufficient insight to allocate clients to a particular segment and build service propositions for them.

Economic You have to be able to serve the segment sustainably or it is of little use.

ONS shows that (in 2016), around 75% of all UK personal wealth was held by the over 55’s4.

Measurable At the end of the year you should be able to produce management information about how much business you’ve done with a segment and how profitable it’s been.

This is a function of how you use your CRM / back office system, but is certainly possible.

4. www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/incomeandwealth/adhocs/009320individ-ualwealthbyagebandgreatbritainjuly2014tojune2016

Over the next few pages we’ll focus on segmenting clients in decumulation, based on patterns of differing needs. Which brings us to…


Decumulation

One of the least client-friendly terms our industry has ever come up with - at the time of writing ‘decumulation’ doesn’t even warrant its own listing in the Oxford English Dictionary. Nonetheless, it’s a sufficiently broadly understood term for our purposes here.

We’ll take it to mean not the act of actually taking money from a pension, but to indicate clients who have moved from a stage of life where they are accumulating wealth to one where they are intending to live or have started living off the proceeds of the money they’ve accumulated. This will include pensions to be sure, but may also include other savings, equity release and other forms of wealth. In short, clients approaching or already in some form of ‘retirement’ – although that term itself has lost much of its meaning in recent years.

Within that cohort we’ll find distinct groups of clients - it’s a wide-ranging group and one which certainly shouldn’t be treated as an homogenous whole.

Now we’ve defined our terms, let’s look at the process of segmenting your decumulation clients with reference to the PROD rules.


Developing an evidence-based picture of your current business

We’ve already suggested that clients in decumulation are a sufficiently diverse group to make a segmentation exercise worthwhile.

Intuitively we all know that the needs of a very affluent 80-year old with some age-related cognitive impairment are very different to those of a fit and healthy 64-year old who is concerned about income sustainability.

However, to date, segmentation exercises have tended to focus largely on client portfolio sizes and fees, not customer needs. It is common, for example to hear advisers say that “I use product or platform X for my affluent clients and product or platform Y for my less affluent clients.” But in truth, portfolio size is a poor proxy for client needs - one client may be relatively modest in terms of affluence but have complex affairs, whereas another may have a million in the bank and be straightforward.

Finding the detail

The richest source of information you could hope to have is already in your business: your back office or CRM system and your financial planning and cashflow modelling software. Applying a multi-layer approach to interrogating the rich data in these systems will produce a fuller picture of the size and shape of the different segments within your existing book. If you’re not sure how to go about this we suggest speaking to your software provider - all the major providers to the advice sector are always keen to ensure firms are getting the most out of their systems.

The exact method you choose to interrogate your client data is up to you. As a starting point, data layers you could choose include:

• age

• profession

• expected path to retirement (phased/part time work)

• risk appetite

• portfolio size and by extension recurring fees

You’ll note that portfolio size is in the list - it is a reasonable aspect to consider but isn’t the whole story. We include a fuller checklist at the end of this paper.

This process will also help you to determine client groups for whom a particular solution isn’t suitable, which as we know is just as important under the PROD rules.


The challenge for advisers, as you will be only too aware, is ensuring customers’ immediate income needs (planned and unplanned) are met while maintaining a sustainable income through the entirety of their retirement.

Drilling down to decumulation

Why do we believe there’s a need to create or consider multiple segments for clients in decumulation? We believe that customer needs in decumulation differ widely but do form consistent patterns. One thing they are not is simple, or consistent. Yet the route through retirement is often simplistically presented: sometimes in diagrams like the one below; sometimes in what’s often referred to as the ‘U-shaped

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OPTIMISING WEALTH

BUILDING WEALTHSTARTING WEALTH LATER LIFE

retirement’. These simplified treatments are useful to frame debates, but of course they are far from an accurate depiction of reality.

This graph below, for example, shows a slow and controlled depletion of assets and reduction of complexity once the client has reached retirement. For many, that’s their intended path. For some, that’s indeed the reality. They’re the lucky ones. Life rarely follows even the best laid plan to the letter.


Those planned and unplanned changes to income requirements, if mapped to a life-stage diagram like the one opposite, would show a very different story of spikes in complexity and marked changes in income requirements. Similarly, if we were to map capacity for loss throughout that period, we’d see it change quite dramatically – although the client’s stated risk profile may remain consistent.

Any or all of these can inform segmentations. As you may have worked out, the process of segmenting clients is one which isn’t straightforward and can be time-consuming.

Some factors advisers tell us they include in their client conversations about decumulation:

• Their main expenditures.

• Their main sources of income.

• How they want to spend the bulk of their time e.g. regular travel abroad or to see family.

• Whether they want a lump sum at the start of retirement e.g. to clear a mortgage.

• Whether they may want to replace one or more cars regularly, or cut down to one shared car.

• Whether one or both will continue to work at all. And for how long.

• Whether passing money to children or grandchildren (either during retirement or on their death) is a priority.

• Whether they are likely to want to downsize their property or move into a retirement complex in the future.

• Whether they want to set aside money for long-term care.

Happily, though, there are tried and tested approaches you can take - let’s look at one now.


A ready-to-use segmentation approach

The Experian model

Viewing decumulation clients through the lens of Experian’s Financial Strategy Segments can provide important context to aid overall understanding of your own client segments.

Here we provide a breakdown of three key Experian segments which describe common features of those UK adults who are 55+ and who are likely to have sought or are likely to need advice.

To illustrate the range of issues which set decumulation apart and highlight the need to apply a robust approach when segmenting client books, we’ve expanded these three segments to bring to life some potential planned and unplanned changes to their financial requirements.

We’ll summarise the segments first, then for each give a bit more detail. We’ll suggest two potential futures for each segment: one positive and one more challenging, and round each off by giving some brief thoughts on what kind of service proposition may be most appropriate – though this of course is completely down to you.

A little about Experian

Experian is best known as a multinational credit reporting agency; it is one of the companies which calculates and holds individuals’ credit scores. In the course of its activities, it also creates data and segmentation models, including one specifically aimed at financial services. This model is known as the ‘Financial Strategy Segments’ model or FiSS, and is based on Experian’s own data and a 220,000 strong client survey from YouGov.

In the FCA’s Occasional Paper 31: Ageing Population and Financial Services , the researchers opted for Experian’s segments to expand on the regulator’s own segmentation of UK adults. Experian was described as using “2,500 data variables to give a picture of UK consumers based on needs and wants, attitudes and aspirations towards financial products and services […] combining key socio-economic and demographic characteristics to classify UK adults into 15 segments and 55 distinct financial lifestyle types”.

1 ESTABLISHED INVESTORS

Wealthy households who have accumulated substantial assets and are confident in financial management.

2 CAREER EXPERIENCE

Confident older owners in comfortable homes with above average incomes that reflect their responsibility and experience.

3 GOLDEN AGE

Fortunate elders on gold-standard pensions with money to enjoy now, and choices in the future.


1. Established Investors

Our first segment consists of older families who enjoy an excellent financial position. They’ve achieved professional success and have higher than average incomes or asset holdings. Their holdings are carefully managed, and they value expert insight.

Their pension funds are sizeable. Many have a personal pension or a Self Invested Personal Pension; some have final salary schemes. They may need expert advice on inheritance tax matters.

Before investing they consider the latest financial news and the wider economic outlook. They’re happy to take calculated risks for greater returns. They see the internet as a useful tool and like to access accounts and manage their day-to-day finances online.

Our established investors, then, have some cushioning which means that they are a very attractive segment for planners and advisers. Their liquid wealth makes them attractive for a fee model which is based on a percentage of assets under advice, and even in scenario two there is available wealth to cover medical requirements and still consider inter-generational planning.

Services firms might want to consider offering this segment include:

Cashflow forecasting – there’s clearly wealth here, but it isn’t limitless, and even affluent clients value knowing how their assets will decline over time. A good line of sight on potential inheritance planning will give this group great peace of mind.

Family advice and trust planning – in scenario two particularly, it is likely to be beneficial for all concerned to bring the family group in as a client. This may involve trust work, and dealing with three generations. Again, this promotes the orderly transmission of wealth and will give the settling couple or individual peace of mind.

Ongoing financial planning – keeping a very close relationship on an ongoing basis with this segment is important. In scenario two, a skilled planner versed in later-life planning may well notice the early signs of impairment and start to make preparations for the financial side of a difficult situation.

Scenario 1 - PositiveBoth are in good physical and mental health and remain so.

They pay off a significant outstanding mortgage at age 60, which is retirement age for them.

In addition to their core and leisure income needs, and provision for long-term care in their 80s, the

extra ad hoc income requirements of paying for grandchildren’s

university fees and deposits for first homes are well planned for.

The orderly transmission of wealth to the next generation is

a key concern.

Scenario 2 - ChallengingAs scenario 1 – but two years into retirement their third grandchild

is born with a life limiting condition. They therefore need to access extra income to support their

daughter’s family by plugging the salary gap left by her stopping

work to look after her child – it is unknown how long they will need

to do this for.

Ten years into retirement, one of them starts to experience Lewy

body dementia which brings forward the need for long-term

care planning.

They need to review their plans for leaving an inheritance.


Scenario 1 - PositiveThey’re mortgage free when the

breadwinner reaches 60, and retire at that point.

Once retired they put in place their plan to downsize to a smaller

home in the country, which frees up considerable capital to cover core

income requirements until State Pension age, as well as leisure and ad-hoc income needs for

several years.

Scenario 2 - ChallengingBefore they’re able to put in place their plan to downsize, their son’s

marriage breaks down and he moves back in with them. They can’t downsize as they need to

accommodate their son and his children when he has them on

alternating weekends.

They still want to enjoy their retirement so need to look for alternative sources of income to cover their core and leisure

requirements in the short-term, including equity release.

2. Career Experience

This group is in the second half of their working life. They often rely on a single salary and are working towards paying off their mortgage while building their savings. They are well-educated and have above-average jobs. Many are in professional, middle-managerial and technical roles.

They are making steady progress with their savings. While they don’t have large amounts put away, they continue to increase their reserves when they can.

Their pension fund is growing gradually. Most have an employer’s pension; some have a final salary scheme, but more have a contributory scheme. They are relatively comfortable with risk and take some interest in personal finance generally.

Our Career Experience segment, then, has much less cushioning than our first segment, and may be typical of clients that advisers would class as the less affluent end of their book. Nonetheless, they do have assets, and certainly can benefit from the services of a good financial planner. They’re an example of how a client not yet drawing income can still fall under a decumulation segmentation.


Risk-governed investments – although Experian is silent on this, it is likely that this segment will be heavily invested in cash, and possibly under-risked. Offering a carefully risk-profiled investment portfolio, with the time horizon still available, will give a better potential for growth without causing undue concern.

Cashflow planning – Illustrating retirement outcomes in a relatable, visual manager will be potentially transformational for clients in this segment.

Fee for service model – this segment has a lower asset value than our first segment. While advisers will likely look for some element of ongoing percentage-based remuneration if they are looking after the investments, it may be that charging a fixed fee for annual cashflow forecasting (as an example) is more sustainable for both parties.

Equity release – in scenario two, it’s likely that in addition to continuing work, the client may need to release some equity from their main residence. It is worth considering either developing this specialism in-house or partnering with an equity release specialist to ensure this complex transaction is demystified and made less stressful for the client.


Scenario 1 - PositiveAmple funds and timely planning

mean a smooth path through retirement with all core, leisure, and ad hoc income requirements

more than met by allocated savings and investments.

A relationship with a trusted financial adviser means tax-efficient gifting to family and

adequate long-term care provision is in place to meet all eventualities.

Scenario 2 - ChallengingAn undiagnosed course of

Alzheimers leads to unexpected behavioural changes. These

include a sudden and irrational mistrust of a previously trusted

adviser, unplanned tax-inefficient withdrawals and risky investments.

Whilst the overall impact of these unadvised investments does not

materially damage their long-term retirement goals, the client is

withdrawn and no longer engages fully with their financial adviser or the advice given. It takes several

years to get the relationship back on track.

3. Golden Age

Our third and final segment has generous pension income to enjoy and manages its considerable assets with care. They’re likely to read editorials and newsletters that give investment advice and address retirement issues. They may well be self-directed investors currently but are likely to have sought advice about how best to invest their assets in the past.

They had good careers in professional and managerial jobs and have high levels of professional qualifications.

While members of this segment appreciate their good fortune, they are aware that no amount of money guarantees security, and that care needs requiring significant funding may arise in the future. They want to invest their money with these possibilities in mind, ensuring they leave their options open.

This segment is similar in some ways to our first one. However, they tend to be older, and to assume a higher level of knowledge and ability in managing investments. Most advisers will be familiar with clients who feel their own skill and knowledge is equal of that of their adviser. How you feel about dealing with clients of this type is another matter! But certainly there is the potential for achieving improved outcomes with careful management.


Later life planning – a specialism in later life and end-of-life planning as accredited by SOLLA5 may give clients or prospective clients peace of mind that an area which will be hard for them to navigate can be professionally managed.

Access to discretionary management – this segment may well value professional investment management. In scenario two above, having assets away from client control (whether on an advisory or discretionary basis) would potentially help mitigate some of the distressing impacts of dementia.

Family advice – again, in scenario two, a good relationship with the generation below, even if they aren’t clients, is likely to be very useful. Trust planning will also be vital here.

5. societyoflaterlifeadvisers.co.uk/


Changing customer needs

Achieving a better understanding of and relationship to your client book by breaking it down into target groups is far from a one-off effort. The changing needs of investors who are approaching or in retirement should make it a continual part of your business process.

Vulnerable clients

As the population ages there will be increasing numbers of customers managing retirement savings later into life. Is your service proposition primed to accommodate the likely increase in physical and cognitive impairments of clients?

Research into cognitive impairment and decision making shows that our thinking processes change as we age, and that some cognitive biases and heuristics are often more prevalent in older people. This is especially pronounced in people aged over 706.

6. Timothy A Salthouse: What and When of Cognitive Aging (2004). Referenced in FCA DP16/1 essay Behavioural insights into the ageing mind.

How are you drawing on existing – and continually developing – insights to customise communications for older clients? How are you reviewing your older clients’ user experience, where they are showing signs of cognitive impairment?

How can you best frame and present choices and financial information to older people given what is now known about how their brains work and the decision paralysis that can come about when presented with too many choices?


Putting it into action

We hope these final pointers may help with putting into action what’s been covered in the previous pages.

Target market

Here’s an action checklist for confirming or improving understanding of your existing client book and as the basis for discussions on serviceable target markets of the future.

Firm up the definition of your target clients – who they are and what they need. Are you comfortable with this status quo or are you considering a new target, or a broader or narrower range? This is the time to consider in detail what that might involve.

Think through the nature of the services you want to offer to your target client group(s). Do they differ? Are the segments truly distinct?

Having identified your target client group’s needs, review what investment proposition or propositions are most appropriate in terms of meeting those identified needs. Should you manage them yourself? Is discretionary management appropriate? Do you need a different investment approach to the one you use for accumulation? What level of ongoing governance will be best suited to this segment?

Repeat point three to review product provider and platform solutions.

Is everyone in your business bought in? Genuine buy-in is much more likely where people have had the chance to fully participate and be heard.

Keep good records. Capture all stages of the process so everything is documented.

Review the results on a regular basis to take account of ongoing change – complete with challenge and debate.


Checklist of layers to define segments

Age

Profession

Life stage

Investment experience

Accumulation or decumulation

Planned path to retirement (phased)

Current income requirements

Future income requirements

Attitude to investment fluctuation

Capacity for loss

Financial position / Portfolio size

Recurring fees / Cost to service

Defining and refining the service and proposition for each segment

• What frequency of client reviews best meets this segment’s needs?

• What level of ad-hoc support is this segment likely to require?

• What frequency of communication best meets this segment’s needs?

• What form of contact/interaction is this segment most likely to engage with?

• Does this segment require specialist services to meet its needs?

• Is this segment still cost effective to service at the level it requires?

Ensuring ongoing suitability: meeting fluctuating income needs over the course of the retirement income journey

• What investment proposition best meets the income needs of this segment in early retirement/ mid retirement/ late retirement?

• What are the tax planning requirements for this segment in early retirement/ mid retirement/ late retirement?


Breaking down a client book to help establish clear target markets and define or refine the services and propositions to meet the needs of those markets, doesn’t replace the need also to establish and evidence individual suitability.

But it’s a sensible starting point for ensuring you’re both adhering to and can easily evidence that you’re adhering to PROD rules. The added benefit is that the segmentation exercise may provide valuable insight for where and how you can grow your business to meet the needs of future generations.

Conclusion: it was always about suitability

We hope you’ve enjoyed this paper and have been able to find some usable insight and approaches for thinking at a more segmented level about how you offer services to clients either in or approaching decumulation.

This is one bit of bureaucracy that could just provide that timely prod to look again at how you’re future-proofing service provision and product selection so that they continue to best meet the changing needs of your retirement income clients.

Royal London 1 Thistle Street, Edinburgh EH2 1DG

royallondon.com

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