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Regime has been under threat since inception

The FSA&#39s plans to scrap polarisation are just the latest attempt to dismantle the regulatory regime which has been under threat since its inception 14 years ago.

The concept of polarisation first appeared in the statute books in 1986 as part of the Financial Services Act. It had been proposed by the Marketing of Investments Board Organisation Committee, consisting of civil servants and industry figures and chaired by Sir Mark Weinberg. Polarisation came into force in 1988.

Even before its birth, there were those railing against it. In 1987, the Office of Fair Trading called the proposed regime anti-competitive but it was overruled and polarisation was implemented.

In the early 1990s, the Securities & Investments Board proposed ditching the regime in favour of multi-ties, with the big banks advocating the change, but it was decided to retain the status quo.

In 1999, the current review was kicked off by another OFT report, making the same conclusions it did 12 years earlier although it proposed depolarising investments but not pensions. This time, the winds had changed.

The FSA asked the now defunct economic consultancy London Economics to see if there was a case for change. It produced an economic report, which argued for change.

This led to phase one of the review which decided in March 2001 to depolarise stakeholder and direct offer promotions but stipulated that everything else was still up for grabs until phase two later in the year.

Last October, the industry believed the regime had been reprieved again when the head of the FDDSA review David Severn hinted at gap filling.

Now change seems inev-itable with the FSA wanting a complete overhaul by the end of this year.

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Guide: 10 required letters — what to send, to whom and when?

This guide from Johnson Fleming will take you through the required communication and also give ideas for additional actions that will ensure your auto-enrolment project is a success. The topics in this guide include: the letters you need to send out; what to send and when; the importance of employee engagement; and what to consider as additional communication.

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