Like many of you, I am looking forward to Tuesday 13 July 2004 immensely.

Why, you ask? Well for anyone that has been sailing round the world and unaware, this is the last date the FSA has given for submission of applications for authorisation to guarantee assessment in time for D-day on 14 January 2005.

I already have my 'minded to authorise' letter, which is good news, and Norwich Union can't (yet) take away my agency. This also tells my clients that I will be around next year.

So has it been plain sailing mes ami (it is after all European Law that we are being subjected to)?

I really want to hone in on two areas - the FSA and insurers.

First, the FSA. Anyone faced with a rulebook that occupies 500Mb of disc space has to be having a laugh. Yes I know it's all good sense, but when am I going to get the time to read it and then implement it? This is a worrying concern for all firms.

The guidance to the handbook is a good initiative, but it's a little light in certain areas and whoever can do the job in a few hundred pages will make a fortune.

The contact centre has been helpful, but there has been a lot of confusion regarding online stuff and a sheer muddle when it has come to approved persons. Certain rules are simply impossible to manage, such as those relating to client money.

Software houses will be making the changes, but they then will charge us all for the privilege. There's not much point in having them if they don't work or line us up for fines, is there?

Some compliance consultants are very good but others fill us with horror. They tell you things such as, "never have a non-statutory trust as they can't work".

Try managing client money rules in a commercial brokerage with some retail with a statutory trust.

What really concerns me is the woeful lack of engagement with secondary sectors.

I have many motor dealer clients who are simply (still) not aware as to how serious all this is. Some manufacturers have tried, but the FSA has really failed to tell people that this is important.

It advertised in the Daily Mail and The Times, yet most car dealers are used to reading (or looking at) The Sun or The Sport. Probably the latter are not posh enough for the FSA.

Only 92 secondary firms have had 'minded' letters as at the end of May. That is a shocking indictment.

Property managers and others think it is not for them. Wake up and smell the FSA coffee. Perhaps a stronger smelling brew is needed.

My final observations are regarding insurers. Some have tried (NIG's events being the best) and others simply have not bothered. Not too sure how many NU brokers took the offer of PricewaterhouseCoopers' consultancy at £2,500 per day.

They all have an interest and it would be nice to hear what their orphan policyholder arrangements are.

To say we think that personal lines will disappear from the high street is not very encouraging.

Peter Killmister ACII

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