With the RDR consultation process closing last week, the industry had one final chance to convince the FSA of the merits of their various causes.
Despite the RDR already spanning well over three years, there is still a huge amount up for grabs for the various competing interests who have all submitted new responses to the regulator.
Heavy pressure is being applied on the FSA by the banks and insurers to reduce the qualification requirements for certain tied advisers down to QCF level three. They argue that those advising on a limited range of products through a simplified advice process do not need the same qualifications as other advisers.
A justified criticism of the last RDR consultation paper was that there was a gaping hole on how to service low to middle-earners, apart from a last- minute decision not to scrap basic advice which appeared more the work of the Treasury than the FSA.
But looking back at the way that the banks in particular have behaved in recent years, for instance, on certain structured product sales which could well have fitted into their definition of simplified advice, the big concern with watering down qualification requirements is can the banks be trusted?
One important development from the consultation process is the Personal Finance Society giving its backing to work-based assessments as an alternative to examinations.
For too long, the FSA has ignored the many industry voices who have campaigned for genuine work-based assessments as an alternative to examinations. The regulator has been concerned about whether an awarding body would be willing and able to draw up and conduct work-based assessments. Hopefully, the detailed PFS proposals will allay their fears and offer a solution to many advisers unhappy about taking examinations.
Perhaps of most concern at present is the worry that the FSA is preoccupied with sounding and appearing tough on all issues. This political posturing may make them a few fair-weather friends in the media and Parliament but could do massive damage to the industry and consumers.
With little over three years until the RDR deadline, huge efforts are being made by the majority of advisers to meet the expected requirements.
The FSA should be doing more to encourage advisers to upskill rather than focusing all its attention on scaring the industry with arbitrary deadlines.