The FSA has been busy recently from Sir Callum McCarthy warning us that the current pension distribution environment can’t go on, to the speech by Sarah Wilson on treating customers fairly at a recent conference.In the political party conference season, many journalists often comment on the number of times that a particular word or phrase appears during a speech. As I read the speech by Sarah Wilson on TCF, one word in particular jumped out at me from the page. No fewer than 55 times the word “product” was mentioned, yet the word “advice” only merited a single mention. This troubles me, as we seem to have a regulator who talks about suitability but focuses on products almost to the exclusion of advice as a topic, let alone a priority. This should be no surprise as it has taken several years to reach even draft definitions for generic advice. It seems to me that if we are to prevent the sale of unsuitable products then the best way forward to emphasis the benefits that flow from the holistic approach, and to move away from a product- centric approach. To regulate advice is no easy task and needs a rethink over how advisers can be encouraged to take the steps to develop their knowledge and or validate it to the chartered financial planner level. If we are to consolidate this separation of product and advice, then we need to ensure that the level and value of the advice is acceptable to the public at large. This idea of separating advice and execution is not new, Ron Sandler suggested it some time ago, but for it to succeed we need the ombudsman on board and I feel that until the Financial Ombudsman Service is under the aegis of the FSA, we will fail in any attempts to make low-cost advice available where it is needed most. Sir Callum McCarthy focused on the churning problems that were well aired in Ned Cazalet’s report earlier this year. Since then, Standard Life’s Trevor Matthews has suggested that net positions should be reported. In other words, if you receive 1m in premiums but lose 500,000 to transfers, then you should report net sales of 500,000. I would go further than that. If the transfers are internal, they should be reported as a transfer and new business and not just as new business as is currently is the case. We need to know just how much new money is coming into circulation. Without this information, we would not know if any real impact is being made on closing the savings gap. Cazalet’s report should have stopped the merry-go-round in the group market, but it did not, simply underlining the fact that, as long as commission is payable on transfers, etc, this churning will continue. The providers could stop it all tomorrow, perhaps by only paying commission where the terms are improved for the members, that is a reduction in the annual management charge to less than 1 per cent. When making speeches we have to remember that a reputation is easily damaged and that we all need to share the objective of getting as many people as possible to financial independence. Giving them the impression that all saving is futile needs to be avoid at all costs. Publishing transcripts and then putting them on general release may be good for the ego but does it really help the public, I think not.