Association of Professional Compliance Consultants

The body for compliance consultants who advise firms regulated in the UK.

The APCC is active in enhancing the professional standards of compliance consultants and is recognised as a trade body by the FCA and other regulators. This provides our members with significant benefits in terms of direct access to the Regulators as well as business leads.  The APCC often works in conjunction with the FCA to pilot or test new initiatives, and we also provide with valuable feedback on specific subjects as requested by them.

Association of Professional Compliance Consultants

Member login

Home › Forums › Ask another member a question › Aggregated costs & charges disclosure › Reply To: Aggregated costs & charges disclosure

25th August 2020 at 4:38 pm #2833
abryant@corylus-compliance.co.uk
Participant

I completely agree that COBS 6.1ZA.11 requires all costs incurred to be disclosed, regardless of the payment method. The query related more to the interpretation of 6.1ZA.14 50(10) which refers to illustrating the effect of overall costs and charges on the return of the investment. i.e. If part of the charge has been paid direct by the client, it won’t have an effect on the return. So, the table of total charges would include the direct fee, but the section of the disclosure that illustrates the impact of those charges on the return (the RIY) would disregard the direct fee.
This is the specific aspect that I have certainly seen interpreted 2 different ways