December 2009

1 January 2009 The Financial Services Authority invites comments on this Consultation Paper. Comments should reach us by 16 March 2010.

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

If you wish to respond by letter, please send your comments to the person named at the end of each section and set out below:
Section 2: Professionalism – Jeremy Evans
Section 3: Corporate pensions - Keith Matthews
Section 4: Applicability of RDR proposals to pure protection advice – Emma Thomas.

If you are responding in writing to all sections, please send your comments to Jeremy Evans, at:

Financial Services Authority
Quayside House
127 Fountainbridge
Edinburgh
EH3 9QG

Tel: 0131 301 2164
Fax: 0131 557 6756
E-mail: cp09_31@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):

Section 2: Professionalism

Do you agree, for the reasons outlined above, that the internal model is the least costly and the least complex to establish and will achieve broadly the same outcome as an external PSB?

 

Are there any additional criteria that should be included for the initial and ongoing recognition of professional bodies?

 

Do you agree that the arrangements described will deliver the required increase in the quality and consistency of professional standards across investment advice sectors?

 

 

Do you agree that updating the FSA Register with further information about advisers’ qualifications, and introducing practising certificates for advisers, will contribute to the restoration of consumer trust and confidence?

 

 

Do you think the arrangements described will support the aim of beginning to improve the reputation of retail investment advice?

 

 

Can you provide evidence of any other qualifications meeting all three of the stated criteria?

 

 

Do you agree that option iv is the most pragmatic solution and do you agree that these proposals will provide advisers with transferable evidence of their qualifications?

Section 3: Corporate pensions

 

Do you have any comments on our analysis of the current GPP market?

 

 

Do you agree with our proposals for applying the principles of adviser charging to the GPP market? If not, please say why.

 

 

Do you have any suggestions for the fairest way of allocating consultancy charges among different members of a GPP, allowing for different ages, different contribution levels, whether an initial member or a subsequent new entrant and any other relevant factors?

 

 

Do you have any comments on the CBA outlined in Annex 2 to Section 3?

Section 4: Pure protection

 

Please provide any analysis or evidence you may have on the application of professional standards
(professional conduct, qualifications and keeping
knowledge up-to-date) to pure protection advice, both:
a) where it is provided by an investment adviser; and
b) where it is provided by an adviser who does not advise on investments.