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The FSA has taken some significant steps both forward and back. But in doing so, they have shown they will listen to reasoned debate. From a policy perspective, there is much in the paper to like; from a cost perspective, there is little.
The differentiation between independent advice and restricted advice should be a point of jubilation for everyone who wants to see the IFA profession recognised, grow in stature, and recruit (that horrible expression) new blood.
For too long it has been entirely possible for consu-mers to be befuddled by slick marketing from organisations that sought to portray their services as being as good as independent. The FSA's proposals in this matter will finally allow consumers to tell the difference between those who are on their side and those who are differently motivated.
The fact that a "restricted adviser" must disclose the bounds of their service in docum-entation - but also orally - makes all the difference.
The new definition of independence is more expansive than the current one but most good IFA firms look beyond the packaged product regime anyway. The complexities of the new remuneration structures will take some time to navigate, as will the proposed end of provider factoring.
For larger firms, networks and support service companies, there is an opportunity to consider how they can help step into this gap. As a nation, we need to restore a savings culture and regulatory proposals that inhibit this are, for me, axiomat- ically bad. Further discussion on factoring options would not be amiss.
Finally, I am delighted the FSA has moved on the issue of alternate assessments and accepted not everyone thrives in an exam hall. Aifa was always committed to helping members find an alternate way to prove they are operating at the new level 4 competency standard.
There is so much else in the paper - the impact on the annuity market, the issues around group personal pensions, the implications for pure protection, etc. With the first response deadline just weeks away, we're in for a busy summer, let alone preparing for the October deadline.
To help firms now, we are launching the Aifa Business Transition Academy. Aimed at those who run and lead firms, this free online resource provides a self-diagnostic to test a firm's preparedness for the RDR and provides an action plan.
We will be calling for members' views to help form our response to the RDR. We have racked up some considerable success in the current proposals and now need to focus attention on the cost issues. Having persuaded the FSA to reduce its regulatory fees by £11.7m, I am optimistic that we will be heard again.
Chris Cummings is director general of the Association of Independent Financial Advisers
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