Why Face to Face Guidance may be impossible.

Face to face   I didn’t know what to expect from the Life Planning Association, whose meeting I attended on Wednesday as a guest of Wladek Koch.

What I got was an insight that makes sense of why I believe Face to Face communication is both the most vital and most dangerous means to communicate.

After a number of sessions we were asked to break into groups of four to discuss something or other.

Our group contained two vocal people,myself and one other, a woman who spoke very little but who connected with all of us with the intensity with which he listened. She seemed eager to hear every word but I noticed she was studying the faces of each person as he spoke.

The conversation turned to face to face advice and she remarked quite brilliantly that we had all said much more by the tone of our voices , our facial reactions and our postures than we had with words.

“Could we have understood our positions as well on the phone?” I thought

C-clearly a high percentage of the data she was imputing was visual and all this would have been lost

“Could we understand our positions as well on a webcam?” . I remember a lecture at college called “the tyranny of the cinematic eye” when a play write explained that when he directed a film, he imposed a single view on his audience, when he directed a play, the audience saw what they chose to look at.

The lady explained that she thought it impossible for genuine conversations to happen without opinion being given and that the opinion was often expressed through something so subtle as a sidelong glance.

For this lady, advice was inherent to face to face conversation. The idea of face to face guidance was simply too two-dimensional for the kind of conversations she engaged in.

For her, the only way to neuter advice was to reduce the intensity of the communication by reverting to webcam,telephone, even on line chat. These mediums promoted information over opinion and though less effective, did at least de-risk the process.

Our group conversation turned, as so many pensions conversations do, to the question of guidance.

That day we had been shown the Queens Speech where the agenda for the guidance guarantee is laid out in the DWP’s Pension Bill.  No mention of face to face advice is contained in the DWP’s press release so I’d got on to my Treasury Maven Jo Cumbo, who’d phoned the Treasury Consultation Group and got this back

So no plans to change from Face to Face guidance.

George Osborne famously could not distinguish Advice and Guidance and it seems my expert life planners considered it impossible not to give advice, at least face to face.

The reality is that we almost always take away from every face to face conversation we have, a clear impression of the position of the other. Where we cannot get a sense of that position is where such barriers have been put up, that we get angry and frustrated

“I couldn’t get through to him”, “she was giving nothing away”.

I suspect that if these were the reactions we got from a face to face guidance meeting, we would think the meeting a failure- no engagement had occurred.

But compare

“we were really on each other’s wavelength”,  “I sensed she was on my side”.

These would be statements of success to most people but they are also deeply concerning to a Regulator.

The simple truth is that Face to Face establishes an emotional bond between two people- trust! The bond is established as much by how you listen as what you say and you listen with your eyes as much as your ears.

What people hear is not information, it is emotions like “concern” “disinterest” “distrust” or “trust”, these are what can be read face to face.

George Osborne was right- there is no such thing as Face to Face Guidance.

We are always advising, if we did not , we would not be having a face to face conversation.

The DWP can, once they take over the reins of the guidance process , go one of two ways.

1. They can push the guidance recognising that guidance really only happens in a non-emotional (eg non face to face environment) and push for these guidance sessions to be delivered in an emotionally sanitized environment (phone,Skype, on-line decision trees etc._ or

2. They can push face to face, (which will be far more expensive and have far more impact). But they need to recognise that whatever rules they apply, as soon as an emotional bond is created – advice will be delivered.

I have said before that I consider that advice is about “delivering a definitive course of action”.

Advice is a recommendation of what to do.

As the lady in the group session demonstrated, you can give advice without opening your mouth. No amount of meeting records can document what people saw, what people heard and how they heard it.

There is no defence for someone who tries to give guidance but is heard to be giving advice, for in the complex ratiocination of a face to face conversation what is meant as guidance is heard as advice.


If the FCA/DWP/Treasury want to regulate the delivery of guidance, they need to avoid Face to Face. Otherwise they must accept that whatever they want to be delivered as guidance will be taken as advice with all the pitfalls that entails.

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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3 Responses to Why Face to Face Guidance may be impossible.

  1. Steve Gay says:

    Hi Henry – this is another one of your blogs that made me think so hard my brain hurt (no jokes please). You are right that the non-verbal issue makes things very problematic (‘a nod’s as good as a wink’). It is easy to monitor compliance with scripts and recordings – but F2F offers so many opportunities to stray over the line that it implies risk of censure beyond most firms’ tolerance. But where is ‘the line’ when customer satisfaction depends so much these days on the qualities of authenticity and empathy, and where it is human nature to build trust in a relationship through the willingness to share trivial indiscretions.

    Is it possible to ‘sell’ without persuading. Is it possible to ‘persuade’ without recommending? Is it possible to ‘recommend’ without advising? And being a ‘guide’ (One who shows the way by leading, directing, or advising …according to the online dictionary) hardly clarifies matters for the person in the street, and feels a bit slopy-shouldered (which is probably why the Chancellor didn’t want to use it).

    Curiouser and curiouser it is, as we head down the Chancellor’s rabbit hole.

  2. Anne Caborn says:

    We’re lovin’ this article. The other issue is that face to face gives us a false sense of bonding and that devious advisers can manipulate our response. Would you write a guest blog on this for Money Fight Club?

  3. henry tapper says:

    Thanks for these two kind comments (all comments welcome- including unkind!)

    Stephen- you’ve captured the dilemma beautifully. We really need to better understand these risks or we’ll be having arguments about what was said and what was meant and what was heard but but not said or meant- till the cows come home.

    The decision trees were absolutely useless- they were a policy success- nobody read them and no-one sued!

    But then there was no money at stake!

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