by David Hollingworth, communications director, London & Country


With the consultation period on responsible lending coming to a close it was not long before the next element was here to consider. This time CP10/28 Distribution and Disclosure is the topic and thankfully it is far less contentious than its predecessor. The proposals certainly suggest changes although I


expect that the broker market will largely fi nd the proposals acceptable and in many cases sensible. The move to bring nomenclature in line with that used in


the RDR in terms of advisers offering an ‘independent’ or ‘restricted’ service is unlikely to create too much concern. Those not offering a fee charging option are unlikely to have found the ‘whole of market’ description to be one that caused concern with clients. However that rather technical differentiation will be a thing of the past if the proposals are accepted. It is proposed that the qualifi cation requirements for


advised and non-advised sales are to be the same. This is likely to be of greater concern to some lenders and will mean that additional training costs will be incurred. Any worry over this is likely to stem from the fact that


increased cost is likely to eventually fi lter through to product and be met by the customer. However it does create a level playing fi eld and should be perceived positively by broker and consumer alike. One change likely to receive attention will be the


requirement to make a statement as to whether a recommendation will include deals that are only available direct or not though any good broker should have been doing this already. This will ensure transparency to customers that direct deals will or will not be included in the recommendation process. Overall there is a lot here that should be met with more


than a degree of approval and FSA has heeded the responses to the initial discussion paper, doing away with some of the more controversial suggestions. In summary, it’s impossible to read the report without feeling that all in all much of it is very sensible.


to intermediaries. ‘Whole of market’ and ‘tied’ labels are to be thrown out in favour of Retail Distribution Review labels ‘independent’ and “restricted”. The independent label will also be allowed for brokers who don’t charge a fee to their customers – a change from the current status quo. Though many brokers themselves seem pleased to be able to call themselves independent without having to charge a fee,


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