JFSC bitesize feedback for INV.BUS on fees and charges

In 2025, the JFSC reviewed how investment businesses assessed their compliance with legislative and regulatory requirements and how effective their controls were in relation to fees and charges.

NOW, the JFSC have supplied bite-sized feedback on a single page, so you can easily understand our findings and any actions you may need to take.

Our observations identify:

• Good practice
• Areas of improvement
• Key considerations

This JFSC feedback highlights the need for transparency, consistency, and strong governance to protect clients and maintain compliance.

Firms should conduct internal audits against these points to identify and address gaps.

Briefing: Jersey Financial Services Commission (JFSC) Bitesize Feedback on Investment Business Fees and Charges

Overview

In 2025, the JFSC reviewed how investment businesses in Jersey assessed compliance with legislative and regulatory requirements for fees and charges, evaluating the effectiveness of their controls.

This briefing summarises observed good practices, areas for improvement, and key considerations to ensure alignment with regulatory obligations and fair treatment of clients.

Good Practices Observed

• Clear Disclosure in Suitability Letters: Letters included a dedicated, easily identifiable section on fees and charges, supported by straightforward table summaries outlining all applicable costs.
• Robust Policies and Procedures: Comprehensive guidelines clearly outlined requirements and expectations for fees and charges, including references to underlying regulatory obligations.
• Evidence of Disclosure: Firms maintained clear documentary records demonstrating that fees were appropriately disclosed to clients.

Areas for Improvement Identified

• Inadequate Explanation of Third-Party Fees: Suitability letters often failed to clearly explain fees from third parties (e.g., underlying fund providers). In some cases, third-party documents were provided without guidance on how to apply them.
• Inconsistent Fee Reductions: Reductions were applied unevenly due to unclear processes, rationale, and documentation, potentially leading to unfair client treatment and challenges in demonstrating best-interest actions.
• Misaligned Policies and Monitoring: Policies, procedures, business risk assessments, and compliance plans did not fully align with investment business code requirements. Expectations for staff were unclear, and training on specific policies was sometimes lacking.

Key Considerations for Implementation

• Review Template Documents: Regularly assess fact-finds, suitability letters, and other templates to ensure they are clear, comprehensive, and client-friendly.
• Update Policies and Training: Periodically review policies and procedures for alignment with legislative and regulatory obligations related to fees and charges. Provide regular staff training on these requirements.
• Manage Fee Deviations: If allowing exceptions to standard fees or tariffs, establish a comprehensive procedure to govern deviations, ensuring consistent and appropriate application across clients.

READ THE BITESIZE FEEDBACK.

• https://www.jerseyfsc.org/media/hhjabaft/bitesize-feedback-ib-fees-and-charges.pdf
• https://www.jerseyfsc.org/news-and-events/read-our-bitesize-feedback-for-investment-businesses-on-fees-and-charges/

The feedback has been added to the JFSC examination findings and questionnaires page.  

• • https://www.jerseyfsc.org/industry/examinations/examination-findings-and-questionnaires/