OUR PROFESSION

CONSULTATION RESPONSES

 

 

Our Profession

Consultation Responses

 

The Association of Independent Financial Advisers

Response to Consultation Paper 07/19 Regulatory fees and levies: policy proposals for 2008/09

 

AIFA is the trade association that represents UK regulated independent financial advisers (IFAs).  Membership of AIFA is voluntary and on a corporate basis.  AIFA currently represents over 80% of IFA firms in the UK.

IFA firms are the leading distribution channel for retail financial products in the UK, generating over 65% in monetary value in 2006 and are the major sector advising and arranging private pensions in the UK.  As such, IFAs represent a dominant force in the maintenance of a competitive and dynamic retail financial services market.  

AIFA welcomes the opportunity to respond to this consultation and is largely supportive of the proposals relating to our section of the market.  In particular, the notion that those who are returning RMARs promptly and accurately should not effectively subsidise persistently poor performers is fair and worthy of further consideration. 

 

Consultation questions

Q1: Do you agree with our proposals to charge a special project fee for

Solvency II work in 2008/09?

Yes.

Q2: Do you agree with the proposed introduction of application fees for Part

VII insurance business transfers and do you believe the proposed amounts

are reasonable?

We have no comment.

Q4: Do you agree with our proposed clarification of how we apply our policy

on firms acquiring businesses from other firms?

Yes.  The clarification is helpful.

Q5: Do you have any comments on the proposed consequential amendments

to the MEL definition?

We have no comment.

Q6: Do you have any comments on the consequential amendment to delete

the reference to Approved Persons after permission is given?

No, other than it is logical and necessary.

Discussion questions

Q3: Do you agree in principle that we should introduce an application fee

for Part VII banking business transfers?

We have no comment.

Q7: Do you agree in principle that it is appropriate to levy an administrative

charge on firms that are persistent in reporting poorly completed RMARs?

Yes.  We agree in principle that this is appropriate action provided firms have been made aware of any shortcomings and been given every opportunity to correct behaviour.  We agree that it is unfair that other fee-payers should subsidise persistently poor performers.  Any charge should be proportionate and reflect the true cost of dealing with administrative problems.

Q8: Do you agree in principle that it is appropriate to recover our additional

MiFID transaction reporting IS system development costs from the specific

firms that will benefit from the modified reporting arrangements and

therefore the reduction in their own costs?

Yes.

 

 

AIFA

January 2007

 

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