In my first two columns, I highlighted the inadequacies and fundamentally divisive elements of the retail distribution review.
It is easy to be negative and attack a range of suggested changes (no matter how ill considered they may be) without putting an alternative viewpoint and I under-stand that such actions do not assist the argument.
The only valid starting point is financial inclusion. How to insure the uninsured? How to persuade the reluctant to save and how to convince the majority that what they have done thus far is actually inadequate?
Commentators have noted that the death of the door-to-door salesperson disenfranchised a sizeable section of the population. Other people fail to seek out advice from fear or distrust while others do not have the knowledge or even the common sense to look to their future or to family protection.
Education is a two-way process, the means of education has to be made available but the uninformed must also accept instruction. Sadly, too many would rather pursue immediate comforts than spend time and effort on matters such as mortgages, insurance and pensions. This is nothing new although the financial exclusion gap is widening.
Consumers continue to go wildly into unrealistic levels of personal debt and otherwise sensible people ignore dire warnings and evidence and continue to smoke cigarettes. There is only so much that education can do.
For many consumers, the distinctions between independent and tied, good and bad, inexpensive and expensive is illusory. Despite repeated rip-offs, many still hold a form of loyalty to their bank and fall prey to the entreaties of target-driven "customer advisers".
In the prehistoric days before regulation and the informed negativity of newspaper columnists, the financial world was a dangerous place for the unwary. Providers designed opaque and confusing plan structures which minimised the early values of savings plans, leaving a legacy of distrust.
This dreadful aspect was swept away by regulation, as was the direct salesman who was typically unleashed on the poor consumer having completed an obligatory 10-day training course.
The high-charging plans are gone, along with the dodgy salesperson but this victory of sorts claimed an innocent bystander - the door-to-door salesperson from the industrial life offices. Prudential, Pearl, Liverpool Victoria, Royal Liver, Royal London, Refuge and United Friendly all withdrew from this segment and this left the low-earning consumer with no conduit towards financial advice.
The industrial branch plans offered many people an introduction to a simple form of financial advice and enabled them to progress towards appropriate inde-pendent financial advice. It also served to provide the start of a career curve for budding independent advisers. The sector's demise has had repercussions on the financial advice outlets available to the very consumer segment targeted by the RDR proposals. It also depleted the pool of many potential independent advisers.
Consumers get their financial education from independent advisers who are often paid by commission. Primary advice will provide advice of sorts and also some kind of basic product but, like a car with three wheels, it will not meet requirements and will not be as effective as whole of market advice.
Commentators have pointed out the potential for confusion and the nonsense of the suggested adaptation of the word independent.
While the Personal Finance Society untangles its knitting, both the IFA Defence Union and Aifa have been highly vocal in their opposition to the proposals. They have identified the conceptual weaknesses and the bias towards bancassurers best epitomised by FSA director Thomas Huertas's speech to the Institute of Economic Affairs in June.
Many advisers have positioned Aifa as the Neville Chamberlain of the financial services world - upstanding and well intentioned but too quick to compromise and too overly intent on walking the well trodden path of appeasement. Chris Cummings has recently sharpened his teeth but it has generally been left to Evan Owen and the IFADU to take the Churchillian approach.
Independent advisers are often too busy to bother with regulatory mind games and are generally too individualistic to be corralled into some unified force. However, it is essential that on this occasion, all advisers put aside their other pressing concerns and unify to fight the potential catastrophe represented by the RDR.
Alan Lakey is a partner at Highclere Financial Services