It says there is no reason why implementation should wait until the final deadline of 31 December 2012 for certain measures.
For example, it says that adviser firms should put in place ethical and behavioural professional standards as early as possible, even if it takes longer for the qualifications to be attained.
The feedback statement says: “A staggered implementation of some of the RDR propositions appears to be sensible and appropriate. This is particularly the case where we anticipate that industry solutions will prevail where there are no apparent reasons why implementation could not be as early as mid-2009.”
The FSA has set out a rough timetable for implementation as follows. For professional standards, it intends to consult on the FSA acting as interim Professional Standards Board in 2009.
In 2010, it expects to establish an interim PSB and establish the case for the creation of an independent PSB with statutory powers or retaining it as part of the FSA.
In 2010, it also intends to finalise appropriate competencies for different roles and agree how existing advisers should be tested. All new entrant advisers will be required to obtain new qualifications in 2010.
In 2011, the PSB will establish a code of ethics and behaviour and will start monitoring advisers. By the end of 2012 all advisers must have passed competency tests – though it is possible that some will be able to continue subject to appropriate oversight.
For remuneration, the FSA aims for the new rules requiring independent advisory firms to set their own charges to come into effect in 2011. By 2012, new rules requiring product providers to no longer determine or price commission into product come into effect.