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	<title>Comments for The Money Debate</title>
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		<title>Comment on IFAs should complain and petition but also have to offer solutions by Neil F Liversidge</title>
		<link>http://www.themoneydebate.co.uk/?p=1977&#038;cpage=1#comment-11306</link>
		<dc:creator>Neil F Liversidge</dc:creator>
		<pubDate>Sat, 04 Sep 2010 18:13:13 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1977#comment-11306</guid>
		<description>Apologies for the delay in replying; I was on holiday. I could not agree more actually, and I have from time to time suggested  alterations to the FSa as to how it carries on, too varied and numerous to list here. I sent it the latest suggestion today, that the FSA should actually define what it wants to see re&#039; platforms and not force us to play timewasting stupid and dangerous guessing games. I&#039;m all for constructive engagement and to be fair, some people at the FSA do engage on individual practical issues. Unfortunately though when it comes to major strategic matters such as RDR it gives the impression that everything was fixed in advance and its &#039;consultation&#039; was a mere cosmetic exercise.</description>
		<content:encoded><![CDATA[<p>Apologies for the delay in replying; I was on holiday. I could not agree more actually, and I have from time to time suggested  alterations to the FSa as to how it carries on, too varied and numerous to list here. I sent it the latest suggestion today, that the FSA should actually define what it wants to see re&#8217; platforms and not force us to play timewasting stupid and dangerous guessing games. I&#8217;m all for constructive engagement and to be fair, some people at the FSA do engage on individual practical issues. Unfortunately though when it comes to major strategic matters such as RDR it gives the impression that everything was fixed in advance and its &#8216;consultation&#8217; was a mere cosmetic exercise.</p>
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		<title>Comment on April FOS day by Alan Lakey</title>
		<link>http://www.themoneydebate.co.uk/?p=2000&#038;cpage=1#comment-10590</link>
		<dc:creator>Alan Lakey</dc:creator>
		<pubDate>Thu, 26 Aug 2010 16:27:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=2000#comment-10590</guid>
		<description>The FOS has continually claimed &#039;independence&#039; and argued that it is not a consumer champion and does not encourage claims.

This ill-thought out dallying with seedy claims promoters does nothing to dispel such views. Far worse, it confirms in the minds of advisers that they are partisan and therefore unworthy.

The new Chief Ombudsman was formerly in charge of the British Library and one would have hoped that at some stage she would have ingested the meaning of &#039;balanced and fair&#039; from the tomes that surrounded her daily. 

That&#039;s &#039;daily&#039; by the way, not &#039;Daley&#039; as in Arthur.</description>
		<content:encoded><![CDATA[<p>The FOS has continually claimed &#8216;independence&#8217; and argued that it is not a consumer champion and does not encourage claims.</p>
<p>This ill-thought out dallying with seedy claims promoters does nothing to dispel such views. Far worse, it confirms in the minds of advisers that they are partisan and therefore unworthy.</p>
<p>The new Chief Ombudsman was formerly in charge of the British Library and one would have hoped that at some stage she would have ingested the meaning of &#8216;balanced and fair&#8217; from the tomes that surrounded her daily. </p>
<p>That&#8217;s &#8216;daily&#8217; by the way, not &#8216;Daley&#8217; as in Arthur.</p>
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		<title>Comment on April FOS day by Phil Billingham</title>
		<link>http://www.themoneydebate.co.uk/?p=2000&#038;cpage=1#comment-10574</link>
		<dc:creator>Phil Billingham</dc:creator>
		<pubDate>Thu, 26 Aug 2010 11:15:27 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=2000#comment-10574</guid>
		<description>You just could not make it up...

Who at the FOS thought this was wise...?</description>
		<content:encoded><![CDATA[<p>You just could not make it up&#8230;</p>
<p>Who at the FOS thought this was wise&#8230;?</p>
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		<title>Comment on IFAs should complain and petition but also have to offer solutions by John Blackmore</title>
		<link>http://www.themoneydebate.co.uk/?p=1977&#038;cpage=1#comment-10382</link>
		<dc:creator>John Blackmore</dc:creator>
		<pubDate>Tue, 24 Aug 2010 12:24:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1977#comment-10382</guid>
		<description>How should regulation be changed ? Start again. All regulators since 1987 have been going in the wrong direction - attempting to regulate the advice process rather than focusing on the products which do the damage. Product Regulation is essential and long overdue. Can you imagine being allowed to buy a car with no lights or brakes simply because some stupid attitude to risk program recorded you as high risk ?

My suggestion would be to simply have Independent Financial Advisers - who deal with complex advice on a fee basis having passed Q level 6 minimum. These advisers would have no product involvement - they would simply advise.

The remaining 95% of the industry would sell simple Regulated Products on a commission or fee basis with no further examination requirement.

Any members of the public who did not need or require advice or sales assistance would be able to buy products direct with no commission charge.

Rather than wasting billions micro regulating we should seek to ensure that reasonable sales and advice is given defining mis-selling as a deliberate attempt to mislead for gain rather than getting bogged down in pointless detail.</description>
		<content:encoded><![CDATA[<p>How should regulation be changed ? Start again. All regulators since 1987 have been going in the wrong direction &#8211; attempting to regulate the advice process rather than focusing on the products which do the damage. Product Regulation is essential and long overdue. Can you imagine being allowed to buy a car with no lights or brakes simply because some stupid attitude to risk program recorded you as high risk ?</p>
<p>My suggestion would be to simply have Independent Financial Advisers &#8211; who deal with complex advice on a fee basis having passed Q level 6 minimum. These advisers would have no product involvement &#8211; they would simply advise.</p>
<p>The remaining 95% of the industry would sell simple Regulated Products on a commission or fee basis with no further examination requirement.</p>
<p>Any members of the public who did not need or require advice or sales assistance would be able to buy products direct with no commission charge.</p>
<p>Rather than wasting billions micro regulating we should seek to ensure that reasonable sales and advice is given defining mis-selling as a deliberate attempt to mislead for gain rather than getting bogged down in pointless detail.</p>
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		<title>Comment on One easy way to convince the FSA to &#8216;RDR&#8217; protection by Peter</title>
		<link>http://www.themoneydebate.co.uk/?p=1974&#038;cpage=1#comment-10209</link>
		<dc:creator>Peter</dc:creator>
		<pubDate>Sun, 22 Aug 2010 17:36:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1974#comment-10209</guid>
		<description>Alan, spot on - one slight correction if I may, directly authorised IFAs also benefit from this practice if they are part of a network</description>
		<content:encoded><![CDATA[<p>Alan, spot on &#8211; one slight correction if I may, directly authorised IFAs also benefit from this practice if they are part of a network</p>
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		<title>Comment on One easy way to convince the FSA to &#8216;RDR&#8217; protection by Alan Lakey</title>
		<link>http://www.themoneydebate.co.uk/?p=1974&#038;cpage=1#comment-10144</link>
		<dc:creator>Alan Lakey</dc:creator>
		<pubDate>Sat, 21 Aug 2010 18:49:59 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1974#comment-10144</guid>
		<description>Undoubtedly true. Negotiating an increased payment because of volume, quality or better persistency is quite acceptable - this is how markets work to the advantage of both parties.

The problem arises when the amount of commission payment is such that the insurer is forced to increase the premiums for that company/networks clients.

This cannot be justified unless your argument is, &quot;I can get away with it so why not&quot;? Is it TCF? Is it fair and reasonable?

IFAs are agents of the client and, quite rightly, we position ourselves on the moral high ground. Tied agents can and do get away with these rapacious tactics but they are not acting on behalf of their clients, they are acting on behalf of one or more insurers.

Let&#039;s put a stop to differential premiums for IFA business before the FSA does it (and worse) for us.</description>
		<content:encoded><![CDATA[<p>Undoubtedly true. Negotiating an increased payment because of volume, quality or better persistency is quite acceptable &#8211; this is how markets work to the advantage of both parties.</p>
<p>The problem arises when the amount of commission payment is such that the insurer is forced to increase the premiums for that company/networks clients.</p>
<p>This cannot be justified unless your argument is, &#8220;I can get away with it so why not&#8221;? Is it TCF? Is it fair and reasonable?</p>
<p>IFAs are agents of the client and, quite rightly, we position ourselves on the moral high ground. Tied agents can and do get away with these rapacious tactics but they are not acting on behalf of their clients, they are acting on behalf of one or more insurers.</p>
<p>Let&#8217;s put a stop to differential premiums for IFA business before the FSA does it (and worse) for us.</p>
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		<title>Comment on IFAs need to find something at least close to unity by John Blackmore</title>
		<link>http://www.themoneydebate.co.uk/?p=1897&#038;cpage=1#comment-10121</link>
		<dc:creator>John Blackmore</dc:creator>
		<pubDate>Sat, 21 Aug 2010 12:54:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1897#comment-10121</guid>
		<description>Thanks Evan - you really are a Brick - but as you have realized I never could spell</description>
		<content:encoded><![CDATA[<p>Thanks Evan &#8211; you really are a Brick &#8211; but as you have realized I never could spell</p>
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		<title>Comment on Nic Cicutti has hold of the wrong end of the elephant by Lacey Jones</title>
		<link>http://www.themoneydebate.co.uk/?p=1967&#038;cpage=1#comment-10024</link>
		<dc:creator>Lacey Jones</dc:creator>
		<pubDate>Fri, 20 Aug 2010 06:18:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1967#comment-10024</guid>
		<description>But the networks you mention are alleged to be at the leading edge of loaded premiums - more commission via the back door? Back to the good old &#039;dirty multi-ties&#039; as you call them?</description>
		<content:encoded><![CDATA[<p>But the networks you mention are alleged to be at the leading edge of loaded premiums &#8211; more commission via the back door? Back to the good old &#8216;dirty multi-ties&#8217; as you call them?</p>
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		<title>Comment on Let&#8217;s hope Sesame Bankhall&#8217;s profitability is contagious across the sector by John</title>
		<link>http://www.themoneydebate.co.uk/?p=1964&#038;cpage=1#comment-9967</link>
		<dc:creator>John</dc:creator>
		<pubDate>Thu, 19 Aug 2010 15:35:52 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1964#comment-9967</guid>
		<description>I don&#039;t see how one can ever get a true measure of the sector perfomance when, as you say, it is made up of so many small or individual self-employed financial advisers. The liklihood is that it will always seem to underperform because of this.</description>
		<content:encoded><![CDATA[<p>I don&#8217;t see how one can ever get a true measure of the sector perfomance when, as you say, it is made up of so many small or individual self-employed financial advisers. The liklihood is that it will always seem to underperform because of this.</p>
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		<title>Comment on A white elephant no more? Nest may survive by Aos Roltmann</title>
		<link>http://www.themoneydebate.co.uk/?p=1956&#038;cpage=1#comment-9724</link>
		<dc:creator>Aos Roltmann</dc:creator>
		<pubDate>Tue, 17 Aug 2010 08:12:37 +0000</pubDate>
		<guid isPermaLink="false">http://www.themoneydebate.co.uk/?p=1956#comment-9724</guid>
		<description>Doh! Have you actually read anything Tom McPhail (of Hargreaves Lansdown fame) has ever said about NEST? He is one of its biggest advocates.</description>
		<content:encoded><![CDATA[<p>Doh! Have you actually read anything Tom McPhail (of Hargreaves Lansdown fame) has ever said about NEST? He is one of its biggest advocates.</p>
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