On the question of factoring, if the FSA could be persuaded to take on board that an overnight banning of indemnity commission or any other variant would constitute and unmanageably brutal transition, then one solution might be a phased transition over a number of years.
For example, in the first year of transition, advisers could be allowed to get two-thirds of the commission on indemnity, with the balance on non-indemnity. In the second year, the maximum allowable on indemnity could be reduced to one third and only by year three would the full amount in respect of any new policies have to be paid wholly on non-indemnity terms. Most people, I think, would find it hard to mount a strong argument against the proposition that, to improve and to stabilise, the industry has to move on from merely selling product for up-front commission. This is one way in which this might be achieved without half of all intermediary firms going to the wall in the process.
Harvest IFM, Bristol