Biba's proposal for a new-style hybrid trust account has been submitted to the FSA, and discussion are now set to begin with insurers and the ABI. The proposal, on the face of it, is a bold step and the precise details are being closely guarded. If Biba is to get the backing of the ABI, which will be essential if the FSA is to be persuaded to re-consult, it will need to persuade insurers that the proposal will provide adequate protection to insurers' monies.

So far, the ABI has refused to be drawn on the merits of Biba's proposal, saying only that it wants to ensure that the "most practical regime is in place". Individual insurers have said that the proposal is a "good place to start", but are also keeping their counsel on whether it would be an acceptable move.

What is clear is that insurers are keen to come to a practical solution on the issue of client monies. This is a positive attitude, but the FSA will need more than mere goodwill if it is to be drawn to act.