The regulator intends to make it compulsory for platforms to allow assets to be re-registered off their platform no later than December 31, 2012.
The move to full re-registration is not as simple as flicking a switch and the costs and time required to implement this are not insignificant.
Platforms may say they are well on the way through their various committees and groups and an agreement on standards but there is nothing like a deadline to focus minds.
Any complaints from platforms about costs and practicalities should be set against the huge RDR costs that small IFAs are facing – something most platforms have gone out of their way to support.
The RDR is likely to offer platforms plenty of new power through their ability to be a conduit to advisercharging from their cash accounts. Making re-registration a top priority is the least they can do in return.
As expected, the FSA’s views on unbundled charges have created the biggest split in industry opinion.
The FSA is currently considering banning all payments between providers and platforms in the interests of transparency.
The regulator must be careful that, in striving for greater transparency and an improved outcome for consumers, it does not achieve the opposite due to heavy-handed regulation.
It may be that providing rules and guidance on unacceptable practices and tightening disclosure requirements is a more sensible route.
It was worrying to see the FSA water down its disclosure requirements for restricted advisers, who will no longer have to use a mandatory disclosure script. This could offer restricted advisers the potential to mislead consumers about the services they are providing.
It is also regrettable the FSA has decided not to look further at standardised factoring. A one-page letter from the Office of Fair Trading stating it may have competition concerns should not be the end of the argument.
However, the most eye-catching part of last week’s RDR papers was the huge increase in estimates of costs to advisers.
As we move towards the RDR deadline the FSA must keep central in its thoughts the huge burden it is placing on smaller firms and ensure it acts in a pragmatic and sensible way.