It does include many things that some IFAs will not want to deal with in managing their businesses through a downturn.
The timetable for the exams will be tight, with until the end of 2012 to get to level four or roughly the old AFPC but no regulator was going to accept a minimum standard at a lower level. The fact this requirement will apply not just to the independent sector but also to other advisers is to be welcomed. At least the pain will be shared.
The increased capital adequacy requirement – roughly a doubling to £20,000 – is not going to be welcomed by IFAs, yet we believe most IFA businesses will be able to cope and that it could have been much more onerous.
In addition, the regulator is still pressing ahead with customer-agreed remuneration but in a less prescriptive way. Actually, out of many RDR recommendations, Money Marketing believes this may eventually change the way the market operates and give some protection from those who would inaccurately blame all the industry’s ills on commission.
Would we have implemented the RDR now? Probably not. If Money Marketing were the regulator, we might have set some targets and goals but, until we saw how the economic situation developed, no firm timetable. But we would say this – it could have been much worse.