Are we, I wonder, wrong in that assumption? I will outline our stance on the interim paper and ask a few associated questions.
Money Marketing has suggested that an increase in exam requirements to around diploma level is probably the lowest level the FSA is going to accept.
We think that collectively IFAs who wish to remain IFAs will have to get studying although there are some practical ways of assessing standards so it won’t all be exams. However, given that my first questions are:
1) Do you believe that in a timescale of around five years it will be possible for you and advisers in your firm to get to what is effectively AFPC level?
2) Should the newspaper have supported grandfathering?
3) Is Alan Lakey right when he argues that some IFAs would have to do exams almost for the sake of it and not for the benefit of clients particularly if they specialise in say mortgages and protection?
Money Marketing has suggested that most advisers should not be too concerned about a system that sees them agree the level of payment with their clients although we accept it may require some changes in processes.
3) Do you believe that placing the onus on providers to come up with systems around factory gate pricing the industry can drive out commission bias and can your systems cope. Or would you bring in another system?
Money Marketing always argued that the requirement to get to the professional financial planner level in a few years and the threatened use of capital adequacy to push advisers to this level would have forced many good advisers out of the industry.
4) Were we correct to argue this or are you upset that the top tier of professional financial planner has probably been removed?
5) Do you think that chartered status can continue to be strongly promoted without regulatory coercion or indeed regulatory incentives?
Money Marketing has argued that the time is ripe for some regulatory consideration of what exactly multi-tied and indeed bank based advisers are providing in the post depolarisation world including what is disclosed to their clients/customers. We have not yet decided whether we support the suggested sales/advice distinction.
6) Do you think that the distinction between sales and advice is a fair one or is it impossible to call where the dividing line falls in the advice process? If they are not to be stripped of their title ‘adviser’, is there something else multi-ties should have to do to make sure they are not – as they are so often accused of doing – passing themselves off as IFAs.
I would be very grateful if you could post your views either for publication or if you feel you do not wish to put your head above the parapet to my email at firstname.lastname@example.org.
This is not Money Marketing surrendering its editorial line entirely to the readership but it helps to know as we work our agenda going forwards. We do strongly think that advisers must engage with the FSA on this, now that the FSA has decided not to light the threatened bonfire of the IFAs.