Memorandum from Mr Blair Cann, M Thurlow
& Co (Ins) Brkrs
I have submitted views on these issues before
to both the FSA and in the trade press. Now that certain of the
matters at issue have been clarified I am extremely anxious to
contribute again, albeit especially in one area which is in my
view potentially highly damaging to the industry. I have served
in the life and pensions industry for 48 years; I was an employee
during that time of Commercial Union Life and CGU Life and I have
been an Independent Financial Adviser (IFA) for over eight years.
My concern is the RDR and specifically the proposal
that the basic qualification to be allowed to practice should
become a "level 4 qualification" ; in current terms
this means IFAs would need to acquire the Advanced Financial Services
Certificate (AFPC) in order to continue their employment in this
industry. This is what could reasonably be described as a serious
exam, currently comprising several modules and covering a wide
range of specialist knowledge including trusts and taxation (compulsory)
and pensions and several other possibilities from which a choice
can be made.
The average age of an IFA is some 57 years (this
was the figure a few years ago) and the imposition of such a regulation
will undoubtedly drive out a number of IFAs who will feel quite
reasonably that their days of attending the exam room are over.
This is I believe a view widely held within the IFA community.
The upshot of this measure if it goes through-I believe the FSA
have stated that "grandfathering" is not an option although
they have referred the issue to another agency for further recommendations-will
be that a large number of IFAs who have served their clients well
and with the utmost integrity, in many cases for 20 or 30 years,
will finish up being debarred from continuing their professional
careers. I believe this to be an outrageous outcome. Few will
deny the FSA the right to get rid of incompetent or unscrupulous
advisers; the FSA however has no right or mandate to get rid of
decent, capable advisers and this aspect of the RDR needs to be
revisited. I should stress that I have no personal axe to grind
as I already hold the AFPC and as far as I can see will be unaffected
by a change in basic educational requirements. I am personally
acquainted with many however who will be.
My views on the other issues can be expressed
I feel in other outlets such as the trade press. On this issue
however I take great exception and am anxious to express them
to you.
December 2008
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