While this makes for interesting reading, I cannot help reflecting on the motives behind some of the comments. There seem to be three possible motives – to cause consternation, to focus attention on those areas of business where the writer is aware that practitioners need to improve their practices or to deflect the attention of the regulator to other business areas.At the end of last year, the FSA published its findings from a review of the supervision of appointed representatives by retail networks. Comments were made on networks having appropriate controls and using a risk-based approach to ensure that appropriate levels of supervision are exercised for particular firms. Needless to say, these comments might also be applicable to all directly-authorised firms. These concerns suggest that the FSA has found that network firms need to take greater care in the way they organise their business activities but the fundamental issue both for the regulator and consumers is the manner in which the customer-facing part of the business is being conducted. Advisers must follow an effective business process but they must also be satisfied that the process ensures that regulatory matters are given proper regard and that customers are dealt with properly. The firm that can deliver superior quality at point of sale is a winner in every respect. Its risk model will be able to demonstrate that high-quality standards are being met and will also underline where any failings are occurring. Costs could also be reduced as a result of lower levels of business monitoring. If the objective is for more advisers to do business to a higher standard, what steps need to be taken to get to that position? The FSA identifies factors in its findings and associated factsheet. Procedures have already been mentioned as a fundamental requirement and good management information will help identify areas of strength and weakness. Networks in particular can prevent future problems by operating a rigorous vetting process for any firms applying to become ARs. I would suggest that the key factor, however, is to ensure the proper training of all staff involved in delivering the service. Each individual must have a full understanding of their role and responsibilities. Only then can they deliver the quality that will minimise regulatory risk and maximise customer satisfaction. The requirement for advisers to hold appropriate qualifications is fully understood but the FSA also requires ongoing competence. A competency framework should extend to all roles within a firm and staff should understand the steps they need to take to meet the requirements. Ongoing training of advisers and supervisors is of key importance to a great many firms and networks. For firms which are not of a sufficient size to develop in-house modules, reputable organisations are developing learning opportunities.