Andy Cook reads between the regulator's lines
Two cheers for the government and the FSA. Nine days ago, the regulator produced the main consultation document for insurance mediation. And it looks pretty good. OK, brokers selling non-investment life protection products will probably have to take an exam, but the rest of the industry will not (see pages 8-9).
The other areas of contention are likely to be: complaints, where the ombudsman is proposed to take over; independence, where some brokers could find it harder to retain the title "independent broker"; and the scrutiny of profit shares and over-riders.
One of the most encouraging aspects is that most brokers will sail through the requirements. GISC accreditation is often quoted within the document as providing an adequate benchmark for many areas of operation.
Of course, some major topics have been left until January. Solvency and details on competency will be covered in the January consultation.
The document is a reflection of John Tiner's personality. At our recent Strategy conference in Newport, brokers were invited to fire questions at Tiner for an hour. And he won many friends for his commonsense style. And this is evident in the consultation.
It is a shame then that Tiner is being tipped to take over from Howard Davies as the FSA chief executive. Better the devil you know...
The Department of Work and Pensions, not to be outdone, revealed its ideas for investigating the employers' liability market. At last, government action on a serious issue, which even (gasp) saw our industry portrayed in a positive light during BBC2's The Money Programme two weeks ago.
I'm glad the government is taking our industry seriously, but these consultations couldn't come at a worse time. Where are intermediaries going to find the time to read all this stuff, think about it, consult with peers and respond? It's a tough year for renewals and many brokers will be working all over Christmas and beyond to find a bit of capacity. And that has to be the priority. Oh, and most companies are filing their end of year accounts too.
Despite the pressures, you must make time to read, digest and respond to these consultations - otherwise you can have no complaints. In between the reading and thinking, please try to have a relaxing hour or two over the holidays, the first half of next year looks as though it will be as frantic as the last six months.