In May this year I met representatives from the FSA to discuss the range of key messages that we had to deliver to the market. At that time they said September 2003 would be a critical month as their blueprint for the future should be clear. The message then was: you must decide.
PS174 and PS159, CP187 and the latest CP197 set out the blueprint, and now provide the framework for the future. With something in them for everyone in the insurance industry the opportunities offered as a result are immense.
Commercial considerations have prevailed, balanced with the reality that relationships between product providers, other brokers and even within networks, will be crucial in applying regulation to their own businesses.
The level of supervision, monitoring and verification is determined by these relationships and even the FSA forms part of this picture.
For many, the FSA does not envisage establishing a close relationship with the people who run the businesses, but it will expect information so it can decide if it needs a closer look.
Even the smaller firms, defined as having turnover of less than £5m, will have to submit information and undergo confirmations at least every six months. There will be automatic fines for late submissions.
If information is provided on time and is accurate this will go a long way to persuading the FSA that you have embraced the requirement to embed compliance into your firm.
Annual audits for those choosing to handle client monies will also place some of the requirements for monitoring and supervision on to the shoulders of the auditors.
It remains to be seen whether this is good for the industry, as many smaller audit practices may be forced to bring in specialists to do this, or pass responsibility to those that specialise in the field. Many people said that regulation would put them out of business and this may still be true, particularly if they now sit back and do nothing,
However, there are three very convincing options for staying in business while operating to the standards required in the regulated market. These are: becoming an authorised representative; being directly authorised to handle client monies; and opting out of handling client monies.
I would argue that it's not regulation that could drive you out of business, but making the wrong choice of options. And there is still a fourth option - sell up or get out voluntarily - which many will choose.
Whether you choose any of the regulatory routes, you should get used to the fact that there will be a "big brother" watching you somewhere. But the level of interference can be limited by your own actions.
A commitment to good practice with evidence of reporting timely and accurate information, demonstrates you are aware of the risks to your own business. This will then attract a lower level of interference, from the FSA or your principal.
But one thing is very clear, you must decide and act now, as shortly the last piece of the blueprint - the actual authorisation process - will be determined and the true countdown will begin.
Alexandra Peterkin is a director of RW Associates