Well, now we know. The FSA has deliberated, ruminated and cogitated, and the 'near final' rules and the final approach to appointed representatives (ARs) have been published.
From a network's point of view, the attractions for brokers of becoming an AR seem at first glance to be irresistible. After all, ARs may now handle clients' money, and can conclude and administer contracts of insurance.
So, the nonsensical proposal which might have prevented ARs from dealing effectively with their clients' business once they had advised on, and arranged the cover has, quite sensibly, disappeared. And along with it went some of the less practical ideas which, to be fair, the FSA has shelved.
Some practical issues remain, however, and it seems to me that many of these revolve around compliance - the new 'C' word for the sector.
The experience of many independent financial advisers suggests that the FSA, far from dealing with their compliance under network arrangements (assuming IFAs to resemble
ARs as far as compliance is concerned) has viewed them as 'high risk'.
As a result, the regulator has acted in a far more draconian, interventionist and demanding way towards networks than appears to have been the case with directly authorised firms.
It seems that large numbers of IFAs have decided to abandon their original approach, and apply for direct authorisation.
Now, the FSA is suggesting that it will not take the same approach to insurance brokers, but many remain far from convinced. The huge reduction in the numbers of IFAs in recent years cannot be blamed on the costs and complexities of compliance - but these certainly have not helped.
The other crucial point is that with demographic and other pressures facing brokers - an ageing population of principals, continuously-increasing competition and difficult market conditions - brokers are keen to explore the values of their businesses and the exit routes open to them - either before or following 14 January 2005.
For these individuals, the difference in the value - perceived or actual - of their businesses may be significant, as potential buyers realise that an AR may not be in reality anything more than a 'tied agent'. And how much is that worth?
After all, it is one thing to buy a broker and to integrate the business into your own to take advantage of economies of scale. It is quite another to buy one without its own agencies or in-house compliance capabilities.
