Here is why. Whatever has happened in the industry, I do not believe the regulator is a busted flush. If anything, the political pressure for more regulation may become intense.
Advisers may hope that with all the trouble coming not just from Northern Rock but from global investment banks, they will escape the under the radar, with the retail distribution review put on the backburner and TCF allowed to gather dust for a little while.
Yet it might be better to strike a different note on TCF. Advisers have rightly criticised aspects of the initiative. I still have suspicions about how it could be used by the regulator at a future date but that probably does not add up to an argument not to get involved now. If anything, engaging with TCF lessens the risk of unfair retrospection.
Many advisers resent the implication that they are not treating clients fairly. They claim that there is no need for the initiative. But I take a different view. I do not see why engaging with TCF is a particularly sinister principle. Is there anything wrong with considering your processes, your client communications and your advice from time to time?
Obviously, time is an issue. Advisers will say they are very busy advising and running businesses. However, I think that a convincing argument could be made for advisers to use the opportunity to look at their businesses again. It does not mean stopping thinking for yourselves. It also does not mean that those of you who make a point of watching what the regulator is up to, in case it strays into unfairness, should stop doing so.
The RDR remains a great challenge and despite the important and welcome change of tone, I cannot help thinking that FSA watchers must be vigilant at least until the next paper is published this month.
But for a number of reasons, TCF is one issue on which I would not necessarily fight. I think that going to the meetings with the FSA on TCF, engaging with what it is about and seeing if your advice business and clients can benefit while getting the regulator off your backs for a while might be a good thing.
If you think I am wrong or that I am in danger of teaching you to suck eggs, email me and let me know.
John Lappin is editor of Money Marketing