Open letter to Martin Wheatley, FSA

Dear Mr Wheatley, We are only weeks into the brave new world of RDR, but there already appears to be evidence that it is failing to deliver some of the alleged intended outcomes, particularly in respect of assertions regarding the introduction of factory gate pricing. RDR was largely justified by claims that the removal of commission as a form of remuneration would somehow ensure that mis-selling would disappear and be replaced by products that contained lower costs and charges, thus enabling consumers to afford to direct part of their intended investment to paying for advice from a newly-professionalised species of Independent Financial Adviser. For some reason, the FSA seemed to think that this would be an automatic process and that this concept would therefore be implemented immediately, resulting in improved consumer outcomes. It appears, unfortunately, that lack of supervision and an absence of rules in this respect have conspired to prevent the advent of products reflecting lower distribution costs for providers within this market. On the face of it, it appears that many, or even most, Investment Fund Managers, Pension companies, Savings Bond providers and Annuity firms, may have seen RDR as an opportunity to stop paying commission and to retain additional profits for their shareholders. Can it really the case that this apparent lamentable reluctance to pass any RDR-linked savings on to the consumer has been / is being allowed to happen? The result of this is that consumers are paying twice: Once for the costs and charges that would previously have funded the advice and administration services from IFAs, but are now seemingly being pocketed by greedy providers, and then once again to cover those costs through adviser charging. The RDR was ostensibly constructed to increase consumer protection, consumer choice and industry professionalism, so we call on you, as Chief Executive of the body who created this state of affairs, to see it through in terms of the other side of the equation that was originally presented to the industry. It is incumbent on you to ensure that Treating Customers Fairly and factory gate pricing are not just historical sound bites, but are an integral and compulsory part of RDR implementation. The adviser community have done what was required of them; now it is the turn of the Regulator and the industry’s major players to fulfil the commitments made to the consumer during the long years of consultation and preparation. Anything less is a betrayal of the consumer and of all those who have shown faith in the honourable intentions of the Retail Distribution Review and, furthermore, provides justification for the many thousands of opponents who mistrusted this process throughout.