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The debate about the professionalisation of the independent financial adviser occupational group has given rise to a small, but important, side issue.
In a recent high court decision, it was concluded that professional advice from accountants carry legal privilege.
Following an earlier House of Lords decision, the high court nevertheless decided that the legal advice privilege given to accountants does not extend to advice about tax law. These technicalities will have to be resolved by lawyers.
However, since in practice accountants are the professional group closest to IFAs, then it can be assumed that professional advice from an IFA must carry the same legal privilege.
Equally important, since the future professional development of the IFA sector will take it more along the giving of tax advice, more so than investment advice/planning, this is an issue that can no longer be ignored.
It also raises issues of an IFA’s professional duties to his or her regulatory body, to the FSA (and there must be an implicit duty to the FSA), to the soon to be constituted consumer body and to the administration of justice.
In fact, this duty extends from financial advice to financial planning and can be said to encroach on the relationship between the professional adviser/planner and the financial ombudsman service.
Even if we were to accept the principle of privileged advice, where do the boundaries begin and where do they end?

Reading the devil in the detail of yesterday’s pre-Budget statement from Chancellor Alistair Darling was a further example of how the government continues to march in the opposite direction of pension’s simplification.

At a time when the need for pension’s saving is at its greatest, the government is looking to gain extra revenue from placing tighter curbs on retirement saving.

According to leading independent pensions researcher Dr Ros Altmann, now is the time when attention should be placed on cutting the budget deficit, particularly as low interest rates could further damage pensions and annuity rates.

Reading the fine print in the announcements, Ms Altmann said public sector pension costs would in fact increase even more than the government has predicted.

According to Ms Altmann Table B15 in Annex B of the PBR shows the net cost of paying public sector pensions will rise from £3.3bn in 2008/2009 to £4.2bn in 2009/2010 and £4.8bn in 2010-2011 – a 45 per cent increase.

She added that people should also not be fooled by the pretence of a promised cap on taxpayer contributions to public pensions by 2012.

Examining the detail, she found that as well as the cap only applying to longevity, if pension costs rise due to changes in interest rates or inflation, then there is in fact, no cap at all.

She added that it is highly likely that public sector pension costs will continue to overshoot Budget forecasts as they have done in the last few months.

Ms Altmann has also called for Personal Accounts to be abandoned, not delayed to allow the government to make billions in savings.

Delaying the introduction of the controversial scheme could save as much as £100m by 2012/2013, she said.

Ms Altmann added that while Mr Darling recognised the need in his statement for older people to stay economically active, highlighting measures to help those aged over 65 to work part-time, it would not work in practice unless pension credit rules and age discrimination legislation is changed.

Based on this, she said there was now a “desperate need” for an independent review of public sector pension costs.

What are your thoughts on Mr Darling’s promises? Is a review necessary?

Liz Field, the interim chief executive at the FSSC, is nothing if not bold. She took up the job, at an institution whose very existence it at best uncertain, on a six month contract, tasked with the unenviable challenge of getting it through its review to get its licence back.

It might not be on the scale of deciding where the axe should fall in the public sector, or sending more troops into a seemingly no-win environment, but as jobs in financial services go, it is a tall order.

Now it seems that even if the FSSC does get its licence back, it may still face other challenges. The - current - opposition parties have been distinctly lukewarm about the FSSC, and sector skills councils. Perhaps they are still waiting to see which way the wind blows.

Nonetheless, Ms Field does at least seem aware of the situation confronting her, and the task ahead, which is encouraging. But perhaps more should be done to remind us of why we need a skills council in the first place - just as the industry is gearing up for a dramatic change in its qualification requirements, it is an opportunity for the council to show why it is needed.

Should we be surprised that Anthony Bolton wants to make a comeback into active fund management? It’s all very well having one’s reputation intact, but when someone at the top of their game takes a back seat, perhaps two years out of the spotlight has been long enough.

He has certainly chosen what many expect to be the next big thing: China. The fund will invest in Chinese companies, wherever they are listed, and they will focus more on domestic consumption.

To tie in with the plan, Mr Bolton will move to Hong Kong, and manage the fund from there with more details being announced early next year.

True to style, it is a bold move. He achieved an annualised return of 19 per cent on his Special Situations Fund. The question is, can he do it again? It certainly looks like a similar approach to the one he took at Fidelity - look for opportunities in small companies that are springing up, in an economy that is on the up.

But his decision is a big risk. It is all very well being one of the most successful fund managers in the business, but he has his own reputation to match by coming back into the game.

This is obviously something he would be aware of, but the risk of failure is perhaps not as offputting as a long, if comfortable, retirement stretching ahead of him.

For all the wailing and gnashing of teeth over the decline of self-cert, I think it is important not to lose sight of the over-riding problem.

The fact is, that some advisers encouraged their clients to go for self-cert, and exaggerate their income. This was illustrated by a BBC documentary, which found a number of advisers doing this.

From my own experience, someone I know, who was so spectacularly irresponsible with her finances she will probably carry tens of thousands of pounds of unsecured debt with her for the rest of her life, simply saw self-cert as a way for her to get a mortgage.

She did not have any conceivable sort of steady income, but had decided that she wanted a house and this option was her way of doing it.

I realise that she may not be the average person looking for a mortgage, but it is precisely this kind of activity that lay at the bottom of the chain of the credit crunch, and subsequent recession.

The problem is, a number of advisers may have become reliant on the sizeable commissions available through self-cert, and clearly their business models will have to change. But many successful self-employed people will say that it is important to have several lines of business, in case one goes down.

And for the mortgage industry, it should consider adapting, and finding another way to cater for fluctuating income levels, which I’m sure many self-employed document for themselves.

Is the primary problem with pensions politicians themselves?

If we took the politics out of pensions from the time when the Labour government came to power in 1997 we would have a system that incentivised both individuals and employers.

The system that the Labour government has created is this: individuals don’t want to save for their retirement and employers only want to offer the bare minimum.

Since 1997 we have had pensions simplification and the tide of the economic crisis means we now have pensions complication. The Prime Minister Gordon Brown, who was Chancellor of the Exchequer in 1997, removed tax credit on share dividends in a move many have argued wiped billions of pounds off the value of pension funds.

There has been a new pensions minister or secretary of state at the Department for Work and Pensions every year and they can’t make the tough decisions that are needed even if they wanted to.

Pensions are a long-term product, and they need long-term solutions and taking the decision-making away from politicians who are trying to climb the greasy pole would result in more people saving and untangling the mess the pensions system currently is.

The primary problem with pensions in the UK at the moment tough action needs to be taken. Over the past 15 years a number of issues have developed that could take up to 25 years or more to resolve.

This includes: the state pension and the role of means testing, golden public sector pensions especially for well paid civil servants, increasing the state pension age because of increased longevity and constantly changing legislation.

Experts and specialists don’t have a high profile career that they need to protect in the same way, so can make very difficult and painful decisions about the future of the pensions. Politicians who want to get elected and retain their careers can’t make difficult decisions. There are millions of people employed by the public sector who don’t want their pensions threatened.

If we had an independent body that looked at pensions objectively - full of specialists with real decision-making power - and I am sure that we would not have had the whole system undermined by politicking and Members of Parliament whose future as far as pensions are concerned is secure.

The latest figures released by the Treasury on Child Trust Funds show the product has gone from strength to strength since its official launch in 2005.

According to the government, currently two thirds of parents have opened new schemes, £2bn being held in the accounts overall.

There has also been a £10 increase in the average amount paid into accounts every month.
So, while the Treasury can take heart in the relatively strong take up of CTFs, the proof certainly will be in the pudding – what will the first receivers of the trust fund do with their new found riches?

Will they pour the funds into their education, or perhaps towards a deposit on a first home, or even a life-changing experience of an overseas trip?

Or will the local waterhole down the road benefit most or perhaps lost in some “must-have” items from Topshop?

As successful as CTFS have so far been, we must remind ourselves that the products are relatively untested when it comes to the end result, and we have at least another decade to find that out.

Will CTFs change the savings attitude of the UK’s population?

Are we doomed to pass our “buy now pay later” culture on to the next generation, or will the events of the last two years have an effect on today’s children.

If the Tax Incentivised Savings Association had their way, all adults would be locking their funds away in a child trust fund-like vehicle for adults to encourage more people to save for their retirement.

Will CTFs incentivise the next generation into saving responsibly or are we to become a trust fund nation, locking our funds away as the only means of paying for our homes, or retirement?

You cannot fault Chancellor Alistair Darling’s timing: Just over a week before Halloween he has proposed to split Northern Rock, Jekyll and Hyde style, into a “good” bank and a “bad” bank.

Those familiar with Robert Louis Stevenson’s novella will recall that the good Dr Jekyll relied on a potion to transform him from the evil Hyde; as time went on the two became increasingly inextricable to the point that evil Hyde was the dominant force.

I certainly hope that Northern Rock has not passed this point of no return, but I do wonder what magic potion Mr Darling has up his sleeve to separate the good from the bad in banking.

If Mr Darling’s plan goes ahead the government will break up the bank by the end of 2009 and to begin privatising the good half in early 2010. The split would allocate around £10bn of low-risk mortgages and £19bn to £20bn of retail deposits to the good part to sell off.

Northern Rock’s remaining £55bn mortgage book and additional unsecured loans and Treasury assets would be held in a government-controlled asset company, eventually to be wound-down or sold off.

In the meantime the UK government will plough an additional £8bn into Northern Rock to fund the split. The bank will be allowed to increase its mortgage lending from its current level of £4bn to £21bn in 2011 – a significant leap, but still much lower than the bank’s pre-recession level of mortgage lending (£29bn in 2006).

The plan won approval from the European Commission, although Neelie Kroes, EU competition commissioner, wisely imposed some limits on Northern Rock’s ability to write new business as a penalty for the £27bn in state aid it has already received.

Several companies have already expressed their interest in the Dr Jekyll side of the bank, including Richard Branson’s Virgin, which recently applied for a banking licence.

Time will tell whether this split is plausible, or whether the “bad” in the bank will pass through the financial system like the monster from 1980s horror flick The Thing, which transferred from human to human undetected until it was too late.

I am off to Bucharest for Halloween this weekend, but somehow I doubt the home of Dracula will be able to dish up anything more hair-raising than Mr Darling’s proposal. Let me know what you think about the future of Northern Rock.

While I do not want to cause national grief on the scale of that seen when Robbie Williams left Take That it is with great regret that I inform the IFA community that this will be my last ever blog.

Having spent the last five years working in financial journalism I have decided on a career change.

The last two and a half years of my career have been spent at FT Business. Some of the more astute of you may have noticed that this has coincided with the greatest financial crisis in the last 60 years.

It was not my fault! Like many journalists in this field it is a sphere that I found myself in rather than it being a life long dream but any preconception that I had about this being a boring field, with boring people, quickly dissipated.

While the last two years have been exciting, sometimes very stressful, they have certainly not been boring. I feel quite privileged that I have been at the forefront of what my daughter, and hopefully one day my grandchildren, will be studying at school.

There have been many occasions where I have felt that I have been at the centre of events. I was at the extraordinary general meeting up in Newcastle when the Northern Rock board and shareholders were desperately trying to save their bank. I reported on the Treasury Select Committee when the naughty school children Mssrs Stevenson, Hornby, Goodwin and McKillop were hauled in front of the Treasury Select Committee like naughty school children.

Having attended several committee meetings in the past it was (where sometimes several members of the committee are not even in attendance) it was a shock to find it was standing room only in the public gallery. Normally bored-looking journalists have a row of seats to themselves.

I don’t want to bore you with more anecdotes but having reported on everything from the collapse of Lehman Brothers, the merger of Lloyds and HBoS, to Santander extending their market share in the UK I wondered what your outstanding memories are of the last two years and are we indeed out of the woods yet?

The City Regulator has finally come round to acting on the widespread scandal that is self-cert mortgages. But, in so doing, it must be careful it does not throw out the baby with the bath water.

Financial Adviser has reported on a number of occasions the case of the West London bus driver who claimed to be on £80,000 a year, but the only question he wanted answered by a senior manager from a leading lender was what information he passed on to the tax man. Strangely, on the way back in to London, the lender suddenly became like the three monkeys - did not hear, did not see and could not recall the question.

The real danger in the FSA’s precipitous decision, taken without any consultation or discussion, is that the regulator, knowing something was wrong with the self-cert market had to be seen to be doing something and will take the easy way out and try to penalise the innocent along with the guilty.

There are two potential guilty culprits in the self-cert market. First are those borrowers who set out to inflate their incomes in order to get a loan, even if they intend in all honesty to cut back on their budgets in order to meet their repayments. These are people the regulator has to save from themselves.

The second group of culprits are the lenders who quite often re-direct legitimate would-be prime borrowers to their sub-prime arms on the most dubious of grounds for the express purpose of imposing higher repayment charges on them. These are the lenders, many of them household names, who often turn a convenient blind-eye to the discrepancies on application forms only to revive them when the borrower defaults on the loan.

It is at this point that the regulator and the Financial Ombudsman Service should intervene and prevent these rogue lenders from using their bulging wallets to bully misguided borrowers. They should be allowed to get away with bad behaviour.
The innocent victims in all this are the genuine self-employed who have not yet established a three-year or more record of accounts with which to confirm their earnings; or those who have other earnings, apart from salaries and wages, which they intend to use to fund repayments.

By all means, punish the fraudulent and greedy, including those who would sell any product to anybody as long as there is a decent bonus, but protect the innocent.
In the final analysis, taking financial advice from a professional is always the best guarantee. This must be the backdrop to the new ethical dimension to financial services post-recession.

Remutualising failed bank Northern Rock would be a mistake and it should be sold off to enable hard working taxpayers recover the costs of propping up an emblem of the failures in the banking system.

Last week the Building Societies Association in a 40-page study said that remutualisation would strengthen competition and create a more diversified financial sector.

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Everyone who arrives home tired on a Friday after a long working week will no doubt despair at looming deadline for the pension age shifting up next year.

Currently, from 6 April 2010, the minimum age at which pension benefits can be taken will jump from 50 to 55, except on the grounds of ill-health and for certain occupations.

But no surprises that this goal post may yet be moved if the Tories have anything to do with it.

According to the Daily Mail, David Cameron has plans up his sleeve to accelerate the changes if the Conservative Party forms the next government, in order to make retirement more affordable.

As it stands, the state pension age for men and women will rise to 66 in 2026, age 67 in 2036 and age 68 in 2046.

But if Mr Cameron has his way, voting cards at the ready, the skip from 65 to 68 could be accelerated, although no new timescale has been given.

But what will this shift in age mean to financial advisers?

According to Scottish Life next year’s change will create “significant” planning issues for IFAs who have clients currently between the ages of 49 and 54.

It warned this group will find they will have their access to their pensions restricted if they do not act soon.

The provider has already created what it terms as an “instant expert” support pack in preparation for the age change.

Is accelerating the rise in state pension age a good idea? And are advisers prepared to adapt to the changing needs of their clients if this happens?

After attending an adviser meeting yesterday I have a new found respect for small IFAs and the compliance challenges they face.

There is a lot of talk in the industry about the compliance burden, but it was only when I tagged along to the Berkshire IFA group yesterday that I understood the extent of the obstacles small advisers are up against.

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I have been preparing for this week since the start of the year. “What is so important to a financial journalist about this week in September that it has been weighing heavily on their mind since January?” I hear you ask.

“Is it the fact that from 7 to 13 September it is Financial Planning Week?”

As dedicated as I am to financial services I am afraid I cannot say that is the reason I have been building up to this date for the last nine months.

No, the fact is on 2 January my partner and I discovered we were going to be parents for the first time this year - and needed to get our finances sorted!

Following visits to the appropriate medical professionals 12 weeks later we discovered our “due date” was 6 September.

That date has passed and the fact I am writing this blog is proof I still have a bit more waiting to go.

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The retail financial sector is rightly concentrating on the retail distribution review, even if the long-term future of the City regulator in its current structure, is in serious doubt.
The Tories have already signalled reforms if the party comes to power and Labour, no doubt, is becoming privately irritated with chairman Lord Turner’s tendency to ‘think aloud’, however radical his views.
But, as chief executives tweak their business plans and some product manufacturers keep their fingers crossed that they will still be in business come 31 December 2012, the issue of professionalism and qualifications continue to raise its ugly head.
However, in the hurly burly of this heated discussion, what is not mentioned, at least in polite circles, is the system of awarding organisations and if they are fit for the retail environment visualised by the RDR.
Financial Adviser has raised the question of merging the existing organisations – the ifs School of Finance, the SII and the CII, along with the IFP – under a single umbrella, a reformed Financial Services Skills Council, with the curriculum, examinations and qualifications branded by the new Awards body, and the merged organisation providing the preparation for the exams.
How those exams are undertaken is still up for discussion; they can either be terminal, with examinees undertaking a time-based exam without aids, for the Q4 level qualification, while carrying out supervised course work over a set period of time combined with assessment for chartered status.
It makes sense. The Q4 level qualification is a test of knowledge while chartered status is the application of that knowledge up to and including principal level.
In other words, to run your own IFA business the principal must have obtained chartered status.
So far it looks as if those who pull the strings in retail finance, from the City regulator to the big providers and national and network IFA practices, have closed the debate.
They have decided what is best for the industry, even if a large number of people are yet to be convinced.
Of course, any such discussion must look at the powerful and highly efficient individuals at present heading the various organisations.
Sandy Scott at the CII, Ruth Martin at the SII, Gavin Shreeves at the ifs School of Finance, and Nick Cann at the IFP, are all more than capable of heading up any such body.
But it is not about individuals. The December D-day for the RDR can be a moment of far-reaching change, a radical over-haul of the way financial advisers/planners obtain state-sanctioned qualifications.
It means at the very least the re-structuring of the formal process of obtaining qualifications and structuring the studying process.
This will leave the professional standards board free to map out the disciplinary procedures at the heart of building consumer confidence, of establishing one set of sanctions, a single complaints system (over and above the financial ombudsman’s service), set guidelines for dealing with whistleblowers.
If nothing else, senior people in the sector, including the FSA, should give this proposal serious consideration.

At last the cat is out of the bag with Openwork. Its new chief executive, Martin Davis has finally admitted that post 2012, his business model might not work.

In this week’s Financial Adviser, Mr Davis says that we will return to a polarisation of the intermediary market, and his multi-tied business model will struggle.

Aside from at least getting clarity on the matter, it does allow for some discussion about what the RDR is really about. Read More »

I am thinking about submitting the interim report about the compensation payments into the Equitable Life debacle to the Plain English Campaign.

I almost cried when I read the latest report - the fourteenth in the last 10 years.
The 33 page report, Equitable Life ex-gratia payment scheme: Interim Report, earlier this week was almost incomprehensible in its content.

Written by former judge Sir John Chadwick, it highlighted several ways to calculate how much compensation the Equitable Life policyholders could get by using complex algebraic formulas.
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The Bank of England and members of the Monetary Policy Committee released their quarterly inflation report yesterday.

On the upside, the report pointed to easing market conditions and improvements in household and business confidence. Another positive indicator was the modest recovery of the housing market, which had a knock-on effect for house prices.

On the downside, the MPC reported that credit conditions remain tight as banks repair their balance sheets. Read More »

Forecasts of an extended sizzling summer have again been wide of the mark meaning the barbeques can once more be returned to the darkest recesses of the garden shed.

But while we endure yet another somewhat overcast August, are the storm clouds dissipating over the property and mortgage market?

According to recent figures from the Land Registry, the department of Communities and Local Government and the good old reliable mortgage lenders appear to suggest that the inexorable slide in property prices could be almost at an end.

Furthermore figures from the Bank of England show that mortgage lending is starting to pick up slightly and even commentators on the buy-to-let market believe the worst is over.

Following on from the news that Bank of China is entering the churned up wasteland that was once the UK mortgage market, super mutual Co-operative Financial Services has announced that through Britannia’s Platform brand it aims to become the “intermediary lender of choice”.

Obviously to become a lender of choice, the lender has to be willing to lend. So I was just wondering what exactly was the experience of the mortgage adviser at the moment.

Is there an increase in enquiries? Are these translating to offers being made on properties and mortgage applications being accepted? Are borrowers still having to jump through hoops or is there a willingness to lend?

Are we set for an Indian summer or is this just the eye of the storm? Even some commentators are unwilling to make predictions - but seeing glimmers of hope in the gloom of the mortgage market is perhaps something to hang onto.

Are high street bankers above the law?

I ask because no matter what the public throw at them, no matter how much their greed and cunning are exposed, no matter how incompetent they prove themselves to be or even how much they are shown to be bullies and thugs in pin-striped suits, they still go on pretending to be mis-understood.

Here are the people who stood on the burning deck sipping their Pimms and wallowing quite in the mess they have made of the economy, and instead of apologising to the country and volunteering to do community service – since effectively their gross mismanagement of the banking sector is (or should be) a commercial crime – they are paying themselves even bigger bonuses. Read More »

The ripples of the RDR are likely to be felt for some time. But what appears to be a consistent message is that the number of IFA firms will change.

The latest organisation to suggest this is IFA Promotion/Unbiased.

Already, it has seen the number of IFA branch addresses decrease by 7 per cent and the number of registered individuals drop by 9 per cent in the last 12 months.

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More people need care because they are living longer and advances in medical science mean that people with a disability or an illness that was considered a death sentence 20 years ago now live.

Life expectancy in 1948 was 66 while today it is 78, according to the government’s long awaited report into funding adult social care in England, entitled Shaping the Future of Care Together.

The impact of increased longevity not only has an effect on the elderly, but the taxpayer who has to foot the bill through higher direct taxes and council tax now or in the future.

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Sifting through yesterday’s 176-page White paper, the Treasury’s latest attempt to pinpoint the causes of the credit crunch, it is difficult to discover anything new. Much of the missive is regurgitated from previous consultations, with heavy emphasis on Lord Turner’s March 2009 report.

However, the Treasury does have one clever trick up its sleeve. The paper announces plans to create a new Council for Financial Stability (CFS) this autumn, consisting of the Treasury, Bank of England and the FSA.

This financial triumvirate sounds remarkably similar to the existing Tripartite Authority. Indeed the Tripartite Memorandum of Understanding between the Treasury, the Bank of England and the FSA “sets out the role of each authority, and explains how they work together towards the common objective of financial stability in the UK”.

According to a Treasury spokesman, however, the difference is clear. Unlike the Tripartite authority the new Council will exist in law, making it accountable to Parliament and the Treasury Select Committee.

He explained: “We will be replacing the existing structure of the Tripartite where we meet strictly on an ad-hoc basis and never publish any minutes of our meetings and never report to Parliament about what we’re doing working as a group.

“Currently the criticism of the Tripartite is that they’re shadowy—people don’t know what they’re doing. Now they will be formalised, and just like the Monetary Policy Committee they will have formal minutes.”

Well, this is one of many criticisms of a system that has fallen victim to a severe media thrashing over the past year. If you type the words ‘Tripartite authority’ into Google you are inundated with headlines blaming the three-pronged system for the credit crunch.

I suspect this new council is Alistair Darling’s attempt at a rebrand. After all, some of the world’s most powerful organisations have only found success after a name change: Google began life as Backrub, while Pepsi’s original moniker was Brad’s Drink. Before Nintendo became famous it was called the MaraFuku Company (imagine the fun kids would have had with that).

So perhaps the Treasury is following the lead of successful examples and updating its image, but I’m still not convinced that the proposed ‘Council for Financial Stability’ is a sufficiently inspiring title. Maybe the Treasury should follow the lead of Ukrainian village Oktyabrskoye. The Telegraph reports that villagers want to rename the town after their hero: Michael Jackson.

Living Time’s Offer More Options campaign has come on leaps and bounds in the last few months with a 1000 IFAs backing it.

For those who do not know, the aim of the OMO campaign is to extend the choice of retirement income options available to the thousands of consumers who reach retirement age each year.

Dave Harris, managing director of sales and marketing at Living Time, said: “These supporters clearly recognise the market could deliver better results to retirees, particularly at a time when tens of thousands are ‘choosing’ to lock in to the uncertainties of 2009.

“But most importantly, by backing the campaign they are taking some responsibility for helping to drive those improvements.”

Mr Harris revealed this week that the Offer More Options campaign had reached its next stage, with meetings arranged with a number of the big players in the retirement space in an attempt to engage a larger part of the sector.

Just a couple of weeks ago Financial Adviser revealed that Aviva intended to offer its internal customers other providers’ annuities to ensure that its customers have access to the most appropriate solution.

Legal & General announced this week it had widened its direct annuity proposition to encompass enhanced annuities.

Annuities have traditionally been an IFA specific product but these latest developments and the resulting impact of the RDR could signal the start of some big changes in the industry.

So if the industry does start to Offer More Options, with providers offering competitors products and others providing a direct proposition is this another threat to the already embattled adviser community?

The RDR report - the one which says ‘This is really what is happening’ - has finally landed. While the full remit, and repercussions are being discussed elsewhere on the site - an initial look at it makes interesting reading.

There is much to digest - not least on commission, a professional ethics board, and qualifications - but perhaps the most crucial part of it goes to the very heart of what it is to be a financial adviser.

How independent are you? The paper says there will be two categories: independent and restricted advice. If an adviser has a restricted number of companies it can recommend products for, then it will have to say so in discussion with the client and then in writing. This is whether the adviser works for a bank, or a multi-tie operation.

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