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Summertime – and the consulting is far from easy

It is summer and there is a definite temptation to allow a touch of frivolity to creep into this column.

For example, I have invented a new pastime called the Management Consultants Game in which you try to string as many consecutive nouns together in a manner which can still make sense (as defined by a management consultant).

“Human resource strategy development policy group action plan” is the sort of thing that I have in mind, although I rather hopeI made that one up.

But stern duty calls. Summer is not about garden parties and messing about on the river…it is about consultation documents.

From my time as a televisionregulator, I know there is nothing more that regulatory bodies like doing than issuing consultationdocuments at a time which allows them to go off down the beach but leaves the likes of me perspiring overa hot computer.

We have had the welcome news that N2 – the date on which powers finally get moved to the FSA in their entirety – will not now happen for another 12 months. While elephants would be hard put to match the gestation period of the new authority, I suspect we are past the point where an extra six months here or there matters.

What undoubtedly does matter is that the continuing flow of documents emerging from the authority for consultation are sufficiently spaced and give sufficiently long periods of response that those whose livelihoods will be affected by them can prop-erly analyse the proposals.

Half-baked consultation is no good at all.Give it its due, the FSA does take consultation seriously. This may be scant consolation as I embark on ano-ther summary of key points from another CP but it is better thanthe alternative.

One of the most significant exercises on which the FSA will embark in the autumn is that of categorising all businesses in an appropriate risk category. This is the process set out in A New Regulator for a New Millennium. For many IFAs, this could mean they are deemed low risk.

Certainly, it would be hard to argue that a firm which does not hold clients&#39 money and where there is tight control by an owner or proprietor should be highly rated for risk unless it is dealing in some very esoteric products.

The regulatory response to apparent risk need not be exclusively directed at interfering with the way in which a firm operates. There may be better ways of addressing concerns through consumer information, consumer warnings or some other mechanism like that.

I hope the outcome of all this assessment will be regulation which does not try to second-guess the businessman.

It will require a conscious culture shift by the regulator to adopt a different mindset.

But I am pleased to say that some of the noises coming from Aifa members suggest the process has begun and that, some monitoring visits at least are “new FSA”.

Of course, this process is not yet uniform or complete. We will continue to pass on accounts of where the process goes wrong. But there are some positive signs to takeinto the summer break.

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