"If it's not evidenced, it doesn't exist." That's the warning from Ernst & Young's Trevor Newbery, speaking today about FSA regulation at the BIBA Conference.

Newbery warned that if there is no documentation to show the FSA or clients in support of business services, then the FSA will crack down hard after statutory regulation comes into play in January 2005.

"I'm not saying there will be dawn raids, but the FSA could turn up at any moment," added Newbery.

He also warned that moving to an "earned" model from a "received" model would cause a short-term cash-flow problem for brokers.