Nervous times indeed when Chris Blackham pulls his punches and tugs his forelock (Comment, 1 December): obviously "fair analysis" of FSA is a more dangerous pastime than "fair analysis" of insurers.

The recent FSA letter about 'Conflicts of Interest' is yet another example of it spawning a generic hypothesis of malpractice, with absolutely no evidence of harm or detriment.

The only outcome will be to (i) invoke time-consuming and non-productive regimes within regulated firms; (ii) give the FSA a contrived and artificial stick with which to beat firms; and (iii) create wanton supervisory activity to justify FSA jobs and foster FSA self-importance. Consumer benefits? Zero to negative.

Chris understates the urgency and importance of lobbying for change of regulation and control of the regulator.

It seems to me that the industry suffers because chief executives have no time to attend to non-productive, bureaucratic regulatory detail.

Their response has been to protect backsides by unleashing all-powerful compliance departments that are responsible for more expensive and debilitating "gold plating" than even the FSA could prescribe ... leaving pious and hypercritical FSA spokespeople to opine that "firms over-apply the rules".

Entrepreneurs make the world go round; bureaucrats stop it in its tracks. The old adage "Those who cannot, teach" has become "Those who cannot, regulate" and is heading towards the worst case "Those who cannot, comply".

More captains of industry should put their heads above the parapet and scream that what is happening is inept and damaging enterprise and consumers; without pulling punches. It is time for FSA to Treat Insurance Fairly (and Competently).

Neil C Harris, MSc, FCII
Chartered Insurance Practitioner

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