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Simplification is the key - Centre for Policy Studies

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provider influence, <strong>the</strong>reby improving <strong>the</strong> prospect of adv<strong>is</strong>ers acting in <strong>the</strong>ir<br />

clients’ interests, but does not address <strong>the</strong> fundamental problem that a one-off<br />

payment <strong>for</strong> advice (an alternative to factoring) can put people off seeking it;<br />

(iii)<br />

imposing blanket requirements on qualifications (QCA Level 4 will become <strong>the</strong><br />

benchmark), with no grandfa<strong>the</strong>ring (even if an IFA has many years of<br />

experience).<br />

The RDR <strong>is</strong> expected to improve professional<strong>is</strong>m and public trust in <strong>the</strong> industry, but it<br />

leaves behind a generation harnessed with moribund, over-priced retirement savings<br />

products 96 and does little to help modest savers. The RDR <strong>is</strong> also unlikely to change <strong>the</strong><br />

reality that banks currently do not want <strong>the</strong> costs and r<strong>is</strong>ks associated with retail<br />

d<strong>is</strong>tribution of, and giving advice <strong>for</strong>, long-term savings products.<br />

When fashioning <strong>the</strong> RDR, <strong>the</strong> FSA tried to come up with proposals that will improve both<br />

<strong>the</strong> quality and quantity of financial advice available to consumers. 97 “Quality” has<br />

probably been addressed successfully and <strong>the</strong>re will almost be clear blue water<br />

between “independent” and “restricted” advice; as <strong>for</strong> “quantity”, <strong>the</strong> RDR <strong>is</strong> set to fail.<br />

4.8 Consequences of <strong>the</strong> RDR<br />

Some industry estimates suggest that up to 30% of <strong>the</strong> 30,000 IFAs are expected to<br />

leave <strong>the</strong> sector upon RDR implementation, 98 making end-2012 a “cliff edge” date, both<br />

<strong>for</strong> those within <strong>the</strong> industry and <strong>the</strong>ir (typically elderly) clients, who will <strong>the</strong>n be without<br />

an IFA relationship.<br />

One reason <strong>for</strong> <strong>the</strong>se unintended consequences appears to be <strong>the</strong> FSA’s m<strong>is</strong>conception<br />

of what an IFA’s role really <strong>is</strong>. Today many IFA’s offer advice as a gateway to sales<br />

comm<strong>is</strong>sion ra<strong>the</strong>r than as a service in its own right. If following <strong>the</strong> RDR <strong>the</strong> IFA <strong>is</strong><br />

required to give higher quality advice and to charge <strong>the</strong> customer <strong>for</strong> it directly, <strong>the</strong>n<br />

many customers who cannot af<strong>for</strong>d th<strong>is</strong> will drop out of <strong>the</strong> market or choose to buy<br />

simple products direct from banks and o<strong>the</strong>r d<strong>is</strong>tributors. As a result, <strong>the</strong> number of<br />

adv<strong>is</strong>ors <strong>is</strong> likely to drop, and <strong>the</strong> population <strong>the</strong>y serve (and encourage to take on<br />

pension and o<strong>the</strong>r savings contracts) will decline.<br />

Indeed, it will accelerate a trend that has already developed; in ten years time <strong>the</strong>re may<br />

be only a few thousand genuine advice-giving IFAs left. They will be focused on <strong>the</strong><br />

96<br />

97<br />

98<br />

Such as FSAVCs with no access to a 25% tax-free lump sum at SPA.<br />

Objectives laid out by Sir Callum McCarthy, FS Chairman, in a 2006 speech at Gleneagles.<br />

A fur<strong>the</strong>r 15,000 tied or multi-tied adv<strong>is</strong>ers are estimated to operate within banks.<br />

34

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