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It notes that providers and distributors have differing but related responsibilities for TCF and should work together more closely. Providers should design products with greater care, provide higher quality information, monitor distribution channels more effectively at a high level and undertake better post-sale analysis of product performance. The FSA is calling on intermediaries to examine providers’ information more carefully to ensure products are suitable. The FSA states the contents of the TCF paper are not intended to imply that a firm must take on the regulatory responsibilities of other firms in the distribution chain. It is easy enough if you are Aegon with Origen and Positive Solutions or if you have ARs or multi-tie deals but what about the future relationship between providers and the 9,000 IFA firms that would rather not be swallowed up by a provider? In my IFA days, it was not uncommon for poor product information to be sent to me by providers so I would provide my own product explanations and “sales aids” to help the client understand what they were being advised to do. The paper gives examples where providers have offered guidance to advisers when issuing adviser financial promotions and the adviser has ignored the advice. Are providers going to whistleblow to the regulator if they see mistakes by IFAs? I doubt it. Will IFAs complain when providers are not being fair? You bet they will. TCF is important and we should take notice of the relevant papers issued. We have until December 29 to respond to the latest FSA TCF paper. The FSA will publish its feedback statement in March 2007.