I was intrigued by the debate between Grant Ellis and Gary Dixon (7 November, Insurance Times) regarding the cost of compliance and the role networks can play.

Last summer a focus group comprising network members and Willis representatives was created to drive this issue. With appropriate support there is a lot that our members can do themselves by working through the structured, step by step approach we have developed.

Critical is the inclusion of their own staff in compiling appropriate parts of their compliance plan internally.

In doing this, they are engaging in the whole process of understanding how a compliance environment works, how it applies to their operation and making it their own.

This will surely put them in good stead when it comes to taking the next steps of implementing FSA requirements.

All of our network members are already GISC registered, nevertheless we cannot be complacent. Despite John Tiner's assurance that GISC members will be given "due credit", we do not yet truly know how this will manifest itself.

While GISC membership is an excellent start point, it would be dangerous to assume this alone is going to be sufficient.

For example, GISC has said that of 1,200 visits, it found a general lack of records of training, complaints procedures, explanation of service and product information.

So it simply is not enough to produce a manual that ends up gathering dust and bears no resemblance to the true day to day operation of the business.

Mark Radburn
Managing director
Willis Commercial Network