The insurance industry is all too aware it needs to polish its tarnished image after the pensions mis-selling scandal in the 90s. That loss of reputation is one of the driving forces behind the creation of the pan-industry self-regulator, the General Insurance Standards Council. Another is the Government's threat to impose Financial Service Authority regulation in its stead.

But the recent exposé in Insurance Times of an intermediary that has, by its own admission, charged policyholders excessive fees, begs the question whether the GISC's form of self-regulation is good enough.

Staffordshire-intermediary Lloyd Manley has admitted over-charging fees to at least seven working men's clubs during the past two years, of up to £700 in one case.

The intermediary has been subject to the rules of the ABI code of monitoring throughout that period. If the GISC had been up-and-running, Lloyd Manley would still not have had to submit audited accounts.

Even if it had been one of the intermediaries chosen for a spot visit, there is no guarantee the overcharging would have come to light.

Since Insurance Times published the story, four separate investigations have been launched into Lloyd Manley. Yet there is no guarantee the full story will be uncovered.

Groupama's investigation may never be published; and the rules of the ABI code of monitoring prohibit the body from publishing its findings. GISC, which will take over, says its regime too will be corrective rather than punitive.

The public, and the Government, will expect better protection than that. And if a voluntary regime does not deliver, the FSA will be the only option. The industry has to get it right by itself -– it's time to get tough.