Following a survey Dunstan Thomas has recently run, findings point to a potential falling foul of the TCF rules.
53% of the survey sampled are actively revisiting selected clients to assess whether to move them to a platform. 25% are moving only new clients to platforms. Only 20% are re-visiting all of their clients.
Effectively 71% may be in breach of TCF by automating the migration of clients as opposed to assessing the pros and cons of wrap to all clients.