Cummings says that it should not be up to the customer to second-guess what qualifications they can expect from such advisers.
He says: “If you are sitting in front of a client offering advice, it is not for the client to try to second-guess what level of qualification or professionalism that you have or how you are going to get paid.
“Everything should operate on the same benchmark, no matter what type of adviser you are. QCF level four and adviser charging should apply right down to the basic level.”
Cummings adds that more work is needed to ensure that basic advice helps the millions of people who are currently under-advised.
“Basic advice works for certain people but it is not the great leap forward to serving the majority of the population who are left under-advised at the moment.
“I think we need to do some more work around simplified advice. The FSA should look at similar models in Italy, France and Germany where they have the Mifid regime but seem to cope better with a more simplified sales process.”
Cummings is broadly supportive of most of the RDR’s proposals claiming they show the FSA has listened to the IFA community’s views.
He adds that the workplace assessments will stave off a mass exodus of advisers from the industry.
He says: “Restricted advice paints such a clear picture for consumers. If that is not a clear blue flashing warning light to consumers then I am not sure what else the FSA can do. A lot of this is how it gets supervised and translated into action but, in terms of setting the ground rules, I do not think the FSA could have found a better word than restricted to differentiate from independent.