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Pet hates of a file reviewer – Part II

8 April 2019

Readers of Professional Paraplanner will no doubt recall my article on this subject. It contained our top 12 pet hates, in reverse order. It was half in jest and a bit in earnest. Since then we have identified a few more grumbles related to file checks, so we thought it was about time for a sequel! This time, the emphasis has shifted a little and is now almost entirely earnest – with not a lot of jest! 

Find the needle – part one
In the dim and distant past, before we all started pretending that offices could be ‘paperless’, file reviews used to be done on actual paper-based files. Everything the file reviewer needed – client agreements, illustrations, research, suitability report, etc – was right there for the taking, easily found and nicely contained in a neat cardboard folder of some sort.

In this digital age, we, as external file reviewers, usually have relevant client files presented to us as soft copy – files loaded up to Office365 or emailed or made available by whatever other secure mechanism we agree with the adviser firm. While this does not provide the same tactile experience as a good old paper file, it does have the advantage of enabling file reviews to be done remotely rather than on site.

However, we often find that files are provided from the firm’s back-office system, the system that is intended to result in that long dreamed of paperless office but which usually fails miserably to deliver that result.

Many, if not most, of those files are in PDF format. This is not a problem per se but can create difficulties for reviewers when the PDF has been created in a non-searchable format. PDF files can be created with varying levels of ‘security’ by using optional settings in the save menu. Making the file non-searchable and non-editable means that we cannot readily find particular pieces of text in the document using the normal Ctrl F function, a frustration at the very least when, for example, the suitability report is often 40-50 pages long. And, if we do find the desired piece of text, we cannot copy paste that text into our file check feedback to support our findings.

Find the needle – part two

Sometimes firms combine multiple client documents into one massive PDF document. We have even seen the whole of the client file stored in this fashion. Of course, such documents only have one filename, so it is not possible to tell what is in there until you look through it. Is the fact find there or elsewhere? What about the research? And the combined PDFs are usually several hundred pages long. If it is searchable, we have a fighting chance of finding what we need… eventually. If it is not searchable, then not only does it take a very long time to find the needle in the haystack, but we are not certain that the needle is in the haystack at all! And with a cryptic filename, we might not even know we are looking in the right haystack.

Find the needle – part three
Sometimes firms believe that the best way to give ATEB access to client files for review is by letting the file reviewer use their back-office system – either on site or remotely. That sounds very sensible… but it isn’t.

Sure, our access to client data can be controlled and data protection rules satisfied. And every piece of evidence we might want to see is bound to be there on the client record… somewhere. However, in practice, we find that ‘somewhere’ can be anywhere and nowhere. If the document exists, we need to know how and where to find it. If it is not there, we can spend a fair amount of time in a pointless search for it.

And, despite having fast broadband access, a back-office system that runs pretty smoothly and quickly onsite, usually runs very much more slowly for the remote reviewer whose access is via several layers of security and software. With remote access, eveything runs at what might generously be described as a very leisurely pace. It would be an exaggeration to claim that there is time to make a cup of tea while a document opens remotely but there is certainly time to count up to 10, 20, 30 … or more!

No point supplying documents simply for ‘good measure’ (the kitchen sink approach), we need documents that give the full picture succinctly. We sometimes see multiple documents with no explanation as to which one is the right one to check. For example, a second (almost identical) SR with an important change on page 25 but no sign posting to this, or several illustrations with no indication of which was actually provided to the client. We look for a succinct ‘snapshot’. ATEB has a standard format for requesting files – one that we have used for 20 years that allows us to get to the nub of the advice rapidly. Ill-thought-through systems (sometimes designed by the software supplier) create additional work for everyone. The software tail should not wag the efficiency and compliance dog! There is a risk that supplying too much distracting information or information in a poor format will result in the file reviewer missing something important.

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