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It again highlights the potential problems the FSA could have in getting these plans past the European Commission and worries that much of the work and debate will add up to nothing or be fudged through EC pressure.
It warns that the plans for mandatory higher qualifications could be seen as creating an anti-competitive market for advisers and suggests the regulator's plans for "sub-optimal" primary advice could sit awkwardly along-side Mifid requirements for suit-ability. These can join worries already expressed about how the remuneration changes will go down in Brussels.
The paper questions if terms such as professional are appropriate as it could imply other types of adviser are unprofessional and suggests there needs to be greater recognition of the differences between a chartered financial planner and certified financial planner.
It also calls for clarification over how the prudential requirements will work for firms with a mix of advisers and the fact that the difference between the qualifications between a GFA and PFP could, in some situations, be very low, highlighting again the FSA's fixation with remuneration as the most important differentiator.
We hope the paper will be carefully digested in Canary Wharf and will act as a catalyst for advisers to make their voice heard in the consultation.
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