“A lot of the work that I do is historic-the maximum sentences change at different points of time. It's really complicated and people get it wrong all the time. That's when having a timeline is really useful.”
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What is an insistent client? An ‘insistent client’ usually describes someone who, after receiving a personal recommendation, decides to proceed in a different way to that advice. For a time, there was no settled meaning, which risked uneven use of the term. On 3 January 2018, through the Conduct of Business Sourcebook (Insistent Clients) Instrument 2017, FCA 2017/66, the Financial Conduct Authority (FCA) set out a definition in COBS 9.5A. Under this definition, an insistent client is a person who: receives a personal recommendation from an FCA‑regulated firm chooses to enter into a transaction that differs from the firm’s recommendation wants the firm to facilitate that alternative transaction Accordingly, the FCA views the concept from the adviser’s perspective, where the firm is asked to execute the very course of action it advised against. This has become particularly relevant in pensions since the pension freedoms came into force on 6 April 2015 (for more detail, see Practice Note: Pension freedoms—an introduction [Archived])....