The single regulator or the absence of a single regulator? The FSA was meant to sweep away the alphabet soup of regulation but those of you struggling with the GISC and the MCCB can but only mutter: “Plus ça change mais c'est la meme chose.”
The decision to keep general insurance and mortgage advice out of the FSA must have been a relief for the North Colonnade. It has enough on its plate without extending the boundaries of regulation where no one has extended them before. IFAs who find that minuscule percentages of their business fall within the remit of a second regulator are those who have the short straw.
The GISC problem is compounded because its remit is defined by reference to a 1982 statute drafted when Sib was still a gleam in Jim Gower's eye.
It is not surprising that nonsenses arise such as those waiver of premium contracts for pensions that fall in different regulatory regimes, depending on which option the client selects at any given time.
However, there is some movement on this front. I think we are almost there in agreeing that IFAs who offer these waiver of premium contracts, in connection with pensions, will have no need to be registered with the GISC.
The FSA and the ombudsman will be able to field any possible consumer problems without involving the GISC.
Of course, if any IFA sets up a business exclusively and entirely devoted to the selling of waiver of premium contracts then they will have to register with the GISC. I do not think it will be killed in the rush.
The GISC has also indicated to us that it has no wish to duplicate FSA regulation on IFAs and is working out with us which of its rules can effectively not be applied for those with FSA authorisation.
It is also considering a special low fee for those advisers whose income from general business falls below a given point. We are arguing with it over that level but it seems to have agreed the principle. It is all messy and makes more sense as a bureaucratic device than in the real world but we have to lump it and will do our best to ease the pain.
It is holiday time and my beach reading, as recommended to several FSA officials, is The Death of Gentlemanly Capitalism by Philip Augar. It tells the story of what happened to Stock Exchange firms when precipitate regulatory intervention shifted the market structure over-night and shows how much money was lost as a consequence.
I can't quite put my finger on it but isn't there some kind of a parallel in our sector?
I am putting off my thoughts on Sandler until next month when there will be more to say. We are in touch with the inquiry team, in particular over arranging for them to see IFAs so that they can understand first-hand their business. I am also delighted that Ron Sandler has agreed to be guest of honour at the Aifa dinner on November 15.