I am not going to get into “so fare-well then” mode just yet. I am still too busy and have plenty of loose ends to tidy up, FSCS costs and cross-subsidies, for example.
I was glad to see in last week's Money Marketing that there is a hint of FSA contrition about the scale of the increases which the industry suddenly has to contend with. Better, clearer consultation is promised. No bad thing. The fees papers have been remarkably lacking in the sort of hard fact with which one needs to tangle before drawing up a realistic budget. They have been process-focused but IFAs need to chew on something more tangible than process.
Second, PII. There is now scarcely an insurance or investment intermediary in the entire European Union who does not believe that firms should be allowed to mix and match capital and PII to a prescribed level rather than be forced to acquire a stated level of PI. All that remains to be done is to persuade the EU that 100,000 intermediaries cannot be wrong. By next April, the EU will have to have reviewed PI requirements affecting intermediaries. We need to get our retaliation in first and persuade the officials in Brussels that this is a subject of such urgency and significance that their review should end in legislative action, not a beautifully crafted report.
Third, the consultation on the FOS. How can we ensure better industry input into FOS decisions where their impact has wider implications for the sector? Comments must be in by the start of October. Fourth, the menu and the implementation of depolarisation. Have you decided how to use the menu to the advantage of your business? The process is expected to start in January and while there is at least six months' lead time, there is no time to waste.
But I do want to make a brief response to John Lappin's (as usual, trenchant) editorial questioning the future approach for Aifa. Representative bodies do not have a free hand in selecting their model. All have to adapt to the times in which they live. The IFA Association lived in the world of the SRO and SIB. Aifa is a creature of the very different FSA world. Each model adapted to its particular environment.
Just as IFAs have to look outward to their clients, so representative bodies have to consider the attitudes of those whom they seek to influence. The approach and arguments have to be pitched in a way which convinces the sceptical rather than rallies the faithful. Whoever my successor may be, he or she will have to understand how to engender the right response from the external audiences and this is not to say that the current Aifa approach is necessarily right. The environment is changing and Aifa must change with it.
One thing I can promise my successor is that I will not be intervening from the sidelines. Garry Heath was ready to give me his thoughts and wisdom when invited to do so. He never stuck his oar in unbidden. For that I will always be grateful. I want my successor to be able to say the same about me.
Paul Smee is director general of Aifa