Is it measure for measure's sake?

Unless we can be clearer about the outcomes desired in and express these in more concrete terms, then no amount of measurement of internal processes will improve the situation. Again, it seems, regulation is defaulting to its comfort zone of ticking boxes and measuring process that it hopes will deliver decent results. Well, unfortunately they may not.

It is much more uncomfortable for a regulator to major on outcomes rather than processes — certainly beyond the generality set out in the six consumer outcomes so far. FSA has provided indicators of outcomes and principles which firms can apply rather than get into too much detail. Being realistic, this is just the right start, especially given the complexity of possible outcomes across the sector. Perhaps they should do more of this, rather than prescribe too much more on management information.

To achieve its necessary comfort factor, the FSA could then focus more on mystery shopping as a key supervisory tool – as after all it does focus on the outcome for the consumer and is probably quite fun in a way.

However, perhaps the lesson in all this is one that is also emerging in the retail distribution review. That is the importance of quality. If this is to be a trusted and professional advice business we need quality people, quality judgement and quality management. And quality is an inside out characteristic.

We cannot invent sufficient proxies for quality, but we can identify and recognise quality outcomes. We need to move to a new level and neither carrot and stick nor any amount of clever measurement will provide a magic trick.

David Jackman is director of Resources Compliance