Without minimum qualifications, the FSA will find it hard to prove that all firms employ trained and competent staff, says Martin Oliver

There is no doubt that the FSA's consultation papers on regulating the intermediary market are sparking much debate and this can only be healthy for the industry.

But there is one issue close to my heart that I feel has been overlooked by the FSA - minimum qualifications. Many of my peers will no doubt be horrified at the thought of compulsory minimum qualifications, but if the FSA is to achieve its objective of protecting the insuring public and maintaining confidence in the industry, this is something it should be seriously considering.

The FSA says it is the responsibility of each firm to ensure that its people are trained and competent to carry out their job. But what guarantee does the public have of this? Most customers assume that if they contact a broker, they will be talking to someone who is an expert, who has been properly trained and who is competent to advise them. I am sure that in the majority of cases, this is true. But we all know of firms where such standards are sadly lacking. Without minimum qualifications, how can the FSA possibly hope to check that firms are fulfilling their obligations as regards staff competence and suitability to do their job?

Some firms care greatly about their standard of training. Our training material has been praised in many insurers' audits of our business. But I do know that at times in the past our own internal standards did not come up to scratch, and that, as a result, customers were not always being properly advised.

If minimum qualifications were introduced, we would have a comparable level of knowledge across the industry - from the smallest one-man-band to the largest call-centre. Of course there are other practical implications, not least the costs and refresher training, but if we are serious about improving standards and improving competence, this is the road we need to take.

In 2002 we introduced the CII's FIT course for all customer-facing employees - so far we have trained over half of our workforce and have already seen benefits in areas such as complaints and staff turnover.

If minimum qualifications aren't introduced, the FSA is relying on every intermediary making sure its people are competent.

Can we be relied upon to get it right? Will the FSA application process be able to identify who is competent and who isn't, or is it just willing to take a chance that we can effectively self-regulate our own ability? Isn't it better for our industry to be pro-active and prove our ability on a level playing field, rather than being reactive once it's discovered some of us are not as competent as we thought?

Martin Oliver is managing director of Kwik-Fit Insurance Services