The GISC has hit back at the FSA's proposals in its CP160, criticising them as "below" current good business practice.
GISC said the proposals "set a duty of care significantly below that currently regarded as good practice".
GISC added: "In [our] view it was unfortunate that the FSA was not able to publish its paper RM5 on Threshold Conditions prior to the closing date for consultation on CP160, as it would have been helpful to comment on CP160 in that context."
GISC said the work being undertaken throughout the market in meeting GISC's requirements provides a "solid foundation" on which firms can start or continue building their compliance with the FSA's requirements.
Its reponse said: "The industry has already invested considerable time and effort in identifying standards and levels of protection which will be both beneficial to customers and at the same time practicable to implement. We believe that FSA should consider the merits of the approach which resulted from this work and of using it to inform the development of draft rules for consultation based on its statutory objective to 'provide the appropriate degree of protection for consumers'".
