The five outcomes MAS expects firms to deliver

You will be able to state the five fair dealing outcomes in your own words and say which ones depend on you.

At your firm's training day, someone puts up a slide titled fair dealing. There are five boxes, a lot of text, and a compliance officer who reads them out. Most of the room checks their phone. A year later, half of those people could not tell you what the five boxes said, and yet every case they write is judged against them. This lesson puts the five into plain words and shows you which ones sit with you.

Where the outcomes come from

MAS issued its Guidelines on Fair Dealing to set out what it expects financial institutions to deliver for their customers. The full title says who they are for: the board and senior management. The guidelines are addressed to firms, and the people at the top are responsible for making sure the outcomes happen across the business.

That might sound like it lets you off. It does the opposite. A firm's board cannot sit in your meetings, so the only way it can deliver most of these outcomes is through what its representatives do. When your firm writes a sales process, designs a fact-find form or samples your cases, it is trying to make sure you deliver the outcomes on its behalf.

The five outcomes in plain words

The guidelines state the outcomes in formal language. Here they are as you might explain them to a new colleague, in the order MAS lists them.

The first is about culture. Customers should be able to trust that they are dealing with a firm where fair dealing is at the centre of how it works, not an add-on. That shows up in how the firm pays people, what its managers praise and what happens when sales and fairness pull in different directions.

The second is about suitable products. The firm should offer products and services that suit the customer segments they are aimed at. A complex investment product designed for experienced investors should not be sold to a retiree who has never invested.

The third is about competent advice. Customers should get quality advice and appropriate recommendations from representatives who know what they are doing. This is the outcome closest to the reasonable basis requirement you met in lesson 1.1, Financial advice is a regulated act, not a sales pitch.

The fourth is about information. Customers should receive information that is clear, relevant and timely, so they can make informed decisions. A brochure handed over at the end of a meeting, after the client has already agreed, fails the timely part even if every word in it is accurate.

The fifth is about complaints. Firms should handle complaints independently, effectively and promptly. A client who is unhappy should find a process that takes them seriously and is not run by the person they are complaining about.

Which ones depend on you

Look at the five again from the chair you sit in during a client meeting.

You influence the culture, but you do not set it. You can refuse to push a product because of a sales contest, and the people around you notice, but pay structures and management decisions sit with the firm.

The complaints process belongs to the firm too. Your part is to recognise a complaint, record it and pass it on, which lesson 2.4, Complaints, conflicts and the habits that cause them, covers.

The middle three are different. The firm decides which products to offer and to which segments, but you decide whether a product goes to the person in front of you, so suitability is delivered in your meetings. Quality advice is entirely in your hands. So is clear, relevant and timely information, because you are the one explaining the product and choosing when the client sees the documents. Lessons 2.2 and 2.3 take these three one at a time.

Wei Ling uses a short test when she prepares for a meeting with Hafiz and Nadia, a couple who have just had their first child. Will I recommend only what fits them, not just what fits people like them? Can I show how my advice follows from what they told me? Will they see the documents early enough to read them? If she cannot answer yes to all three, she is not ready.

Read the source, not the slide

Summaries like this one are useful for remembering the outcomes, but they lose detail. The guidelines themselves include explanations of what MAS expects under each outcome and examples of practices it considers good or poor. Those examples are the closest thing you will get to MAS's own view of what fair dealing looks like in practice, and a training slide rarely includes them.

Find the current version of the Guidelines on Fair Dealing on the MAS website and read it through once. Note where MAS describes something you have seen in your own firm or industry, good or bad. If your firm has issued its own fair dealing policy, read that alongside it, because it tells you how your firm has chosen to put the outcomes into practice.

In the activity below you write each outcome as a single sentence in your own words. Use the version you would give a friend who asked what fair dealing means, then mark the ones you deliver yourself when you sit down with a client.

Write each of the five outcomes in one sentence of your own and mark the ones you personally control in a meeting.

Course

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