What Treating Customers Fairly Means to Raymond James
Raymond James Investment Services (Raymond James) fully endorses the principles of Treating Customers Fairly (TCF) and believe that they coincide with the Raymond James Financial Vision to be a premier financial services firm providing the highest level of value to clients.
Raymond James considers fair treatment of customers to be fundamental to our business. It is our overriding objective to ensure investors are fairly treated and to do so we strive to create the right corporate culture both within Head Office and our entire branch network that allows for fair consumer outcomes to be consistently delivered.
Raymond James keeps in mind that we have differing responsibilities to three sets of clients:
- Independent Contracting and Professional Partner wealth managers and
- Firms using our Wrap Platform
In essence, as a means of Raymond James accomplishing our responsibilities to the investor clients, we must also treat our wealth managers and wrap firms fairly who in turn directly provide services to these investors.
Raymond James places great value on independent thinking, objective advice and individual solutions and personal choice is held as a fundamental building block of business success. Raymond James has a clearly defined target market, and Raymond James wealth managers in turn have identified their target investor clients. We ensure that the products and services offered are designed to meet their needs accordingly. Clients receive, either from Raymond James directly or through wealth managers, clear and frequent communications. We do not centrally manufacture products, so wealth managers are free to work with investors to identify individual needs, provide quality advice and develop appropriate solutions to fit each client’s personal goals. Raymond James ensures we provide the highest level of service with integrity to wealth managers as they do to their clients. Wealth managers can be confident that Raymond James does not create any unreasonable post sale barriers for them or their clients to change products, change firms or make any complaints.
Raymond James’ Approach to TCF
Raymond James has always sought to balance the commercial independence of our independently owned branches with the regulatory reality of Raymond James being viewed as one firm by the FSA. Raymond James provides investment management and advice services to investor clients of branches. We believe that TCF does not only relate to this investment management and advice, but also to the administration services provided to all investor clients of both branches and firms using our wrap platform. Raymond James must therefore be satisfied that TCF is being addressed at multiple levels within the firm. We continue to measure and test that our performance meets our advertised standard. We also work closely with wealth managers to gain their valuable feedback.
Raymond James has formed a TCF Executive Committee comprised of members of our senior management team who analyse our approach to TCF and address any gaps. The six members of the committee are responsible for ensuring they are incorporating the principles of TCF within their business units in their normal day to day roles, but they also play an active role in the TCF Executive Committee which collectively analyses quarterly Management Information findings and gives direction as to how TCF will continue to be embedded into the business.
Raymond James believes we have a unique proposition and many aspects lend themselves to delivering fair treatment to the investor clients and wealth managers. For example:
- Raymond James presents an unbundled pricing structure, with costs reflected for the different services we provide. A Schedule of Fees and Commissions (SOFAC) is provided to each investor as part of the account opening documentation. Therefore, investors can understand the services they are paying for and the relevant costs. In addition, Raymond James discloses to wealth managers the full trail terms we receive from fund companies. Trail can be rebated to the investor’s account or paid to the wealth manager, all properly disclosed in the SOFAC so the investor understands the total cost of the service.
- Raymond James allows in specie transfers on and off the platform and has done since inception. Raymond James does not charge to transfer assets onto the platform. Raymond James charges a reasonable administration fee to transfer assets off the platform, which is disclosed on the SOFAC and is below our costs for such efforts.
- We do not allow intermediary firms using our platform to own shares of Raymond James, thereby alleviating this potential conflict of interest.
The dual requirements of ensuring the TCF outcomes can be evidenced for investors as well as wealth managers are equally important for Raymond James. We feel this approach harbours a culture of fair treatment throughout our organisation.
Through the leadership of the TCF Executive Committee, Raymond James has undertaken a comprehensive process to ensure we consistently deliver the six consumer outcomes set out by the FSA and that we can evidence our clients are treated fairly. The TCF Executive Committee will continue to be the driver of TCF within Raymond James reporting to the CEO. When we see opportunities for further enhancements, we will implement them wherever possible.