June 2009

The Financial Services Authority invites comments on this Consultation Paper. Comments should reach us by 30 October 2009.

You can send your response by electronic submission using the following form or by emailing us at the address shown.

Alternatively, please send comments in writing to:

Dr Aileen Jones
Retail Policy and Conduct Risk Division
Financial Services Authority
25 The North Colonnade
Canary Wharf
London E14 5HS

Telephone: 020 7066 4894
Fax: 020 7066 4895

E-mail: cp09_18@fsa.gov.uk

It is the FSA's policy to make all responses to formal consultation available for public inspection unless the respondent requests otherwise

Note: You can take a printout of your response before clicking the 'Submit to FSA' button at the end of the form, but this will only print the visible text on screen, and you may have given longer answers. After submitting your response, the form will clear, but when we acknowledge receipt of your response by email, we can return to you a copy of your full submission as received. Check this box if you would like to have a copy of your submission returned:

Submission Details









as an individual
as a representative of an authorised firm
as a representative of a professional firm
other (please specify):

 

Do you agree with our proposal to widen the range of products to which the new independence standard will apply?

 

Do you agree with our proposals for a new standard for independence that requires firms providing independent advice to make recommendations based on a comprehensive and fair analysis of the relevant market, and to provide unbiased and unrestricted advice?

 

Do you agree with our proposals for new disclosure requirements for firms?

 

Do you think we should introduce a mandatory form of words for firms to use when explaining restricted advice? What might this look like?

 

What are your views on removing this GPP exemption?

 

Do you agree that we should not create a new regime for simplified advice processes, but continue to work as needed with firms and the industry?

 

Do you agree that the professional standards set out in Chapter 5 should also apply to simplified advice processes?

 

Do you agree that we should retain Basic Advice, and require those offering Basic Advice to disclose that they are providing restricted advice?

 

Do you agree with our proposals on Adviser Charging for firms that give advice?

 

Do you agree with our proposals on Adviser Charging for product providers?

 

Do you agree with our proposals on Adviser Charging for vertically-integrated firms?

 

Do you agree with our proposals on the disclosure of adviser charges?

 

What approach should we take to the remuneration of individuals giving investment advice?

 

Do you agree that Adviser Charging should be applied where individual advice is given on GPPs? Do you think that the principles of Adviser Charging should be applied to non-advised GPP business, and if so how?

 

Do you think changes are needed to the way that we regulate wrap platforms and fund supermarkets?

 

Do you think that the principles of Adviser Charging, or any other alternative approaches to remuneration, should be applied to non-advised services?

 

What are your views on this model Code of Ethics as the basis for further PSB/FSA consideration and consultation?

 

Do you have any comments on this approach to CPD for investment advisers, including comments on any changes that it would involve to current practices?

 

What consumer detriment, if any, would arise if we implemented the RDR proposals for the sale of retail investment products and took no action on regulating the sale of pure protection products under ICOBS by retail investment firms? We would welcome any evidence on this.

 

Do you have any comments on the cost benefit analysis?