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other professions; and it should be an opportu- proposed. We believe that this will only serve to I am far from clear whether, taken as a whole,
nity for the FSA to introduce proportionate further confuse consumers at a time when they these proposals will do anything to improve
regulation, confident that advisers are Treating need simplicity and clarity more than ever. I do customer access to advice or to rebuild shat-
Customers Fairly and cognisant that reducing appreciate the legal complexities thrown up by tered consumer confidence in the financial
red tape allows advice to be delivered more MIFID, regarding the term 'advice'. I am how- services industry. We believe that technical
economically to a much wider section of the ever reassured by the FSA's declared intent to knowledge alone is seldom sufficient.
UK population. consult the industry on this issue. Experience is equally - if not more - important
Almost two and a half years on from when We also welcome the clarification over the in delivering better outcomes for consumers.
the FSA first set out to tackle a number of level of professional qualifications that will be The average IFA in the UK is in their early 50s,
issues affecting retail distribution I think we are needed in future. But there remain two major and many of them have more than 30 years'
entitled to ask whether the proposals concerns. Firstly, why do we need another regu- experience in business, and perhaps even more
announced recently actually address these fun- lator in the Independent Professional Standards importantly, in life itself.
damental issues and whether the future state Board? Double regulators will inevitably – as To my mind the FSA has also missed two
represents an improvement on today and if so, night follows day - lead to double costs. other huge opportunities. Is consumer experi-
at what cost? Secondly, we are very worried about the dead- ence of the regulated advice process and its
line for upgrading qualifications and the lack of associated steps - fact finds, IDDs, KFIs, suit-
Definition of advice any provision for experienced advisers. On this ability letters - itself a barrier to access? Does it
Sesame welcomes the clear definition of advice. issue I would urge the FSA to think again. actually put off the consumer from seeking and
If consumers are to have confidence then they re-seeking advice on what they need to do to
need to know who is on their side. And the Competence protect their families and to safeguard their
changes to remuneration, albeit that we have We have always acknowledged the need for aca- future wealth? My own instinct is that it does.
still to examine the detail, are entirely consis- demic qualifications, but we still believe that Today in the UK, it is still easier to obtain cred-
tent with this aim. We also welcome the cre- experience and the ability to apply knowledge it than to buy an ISA or pension - and it is long
ation of a sales channel. We understand that are really important. Likewise, we believe that it over due that action was taken to reverse this
some customers do not require holistic advice is essential that the FSA allows a practical, non- state of affairs.
and we also appreciate that the costs of inde- academic route to establishing adviser compe- Secondly, given our commitment to raise
pendent advice cannot be justified for all trans- tence - otherwise many experienced advisers standards and to treat customers fairly, I believe
actions. will be lost to the profession. it is essential that a statute of limitations be
However we are far less enthusiastic about Whilst we welcome those changes which established for the advice profession. Our posi-
the "hybrid" sales advice category that is being contribute to enhancing professional standards, tion is clear: we fully acknowledge the FSA's
Let’s be
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