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Figure it out

A client from an Australian bank asked me how the regulated UK mortgage and general insurance markets are bedding in. I shared with him the numbers of directly regulated mortgage firms.

However, when I told him that the number of individuals acting as appointed representatives for mortgages is not available, I could hear the disbelief in his voice.

I also told him about the results of the FSA’s mystery shopping exercise six months after the start of mortgage regulation. In 82 interviews, the initial disclosure document was not given to the client in 35 cases and, in a further 10 cases, the document was not given up-front at the first meeting with the client. More than 25 per cent of people interviewed were not given a key facts illustration.

Why are these results so poor? Is it because the documents cannot be attractively designed with clever and appealing use of colour and terminology? Is it because the customer is already overloaded with information? Maybe it takes too long to explain clearly what the docu- ments mean? Is it because KFIs are ridiculously long or because they contain too many errors? Or is it because mortgage brokers did not know that these documents needed to be produced?

We know that regulation has increased the cost of transacting mortgage business to over 100 a case. The transitional costs of mortgage regulation are estimated to be more than double the FSA’s original estimate. But the litmus test is whether the cost of regulation has increased consumer confidence and trust and if so, by how much?

As for general insurance – from pet to home and contents cover – there are thousands of product distributors and advisers who are blissfully unaware of the need to comply with FSA disclosure rules. General insurance is an area that the FSA is bound to look at closely once remaining wrinkles in mortgage regulation are ironed out.

It may be that the overriding principle of Treating Customers Fairly and the new financial promotion regime expected in 2007 will be used by the regulator to tighten compliance procedures further in the general insurance market.

Although the FSA is acknowledging that many general insurance distributors are not compliant, it is certainly not seen as a high priority for, after all, I am not at much financial risk if my vet recommends one type of pet insurance or another.

My client and I moved on to talk about the numbers of investment advisers and how it seems strange that it is not known how many whole-of-market advisers and IFAs there are, as they are not counted by the regulator even though IFAs must offer their clients a fee option.

I began to wonder if he believed that I knew what I was talking about. In my 25th year in an industry which I am passionate about, I have gathered a little knowledge. I find that most advisers who have dealt with clients face to face are passionate about the industry as they see how effective financial planning helps improve people’s lives.

I would like to see many more employees from product providers spending time as financial advisers so that they understand how the smaller things, such as speed of underwriting, claim handling and correct details on correspondence, matter to people.

Thinking back to when I started, I realise that the distribution options look remarkably similar to when single ties were known as a direct salesforce.

Thankfully, IFAs have increased their presence as the dominant distribu- tion channel. That knowledge has helped my client decide that his bank’s products will only be available through IFAs.


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