Will ending commission kill off the adviser?

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The FSA and the government are desperate to force all IFAs to charge fees to clients, despite clear and overwhelming evidence clients do not like to pay fees and are not prepared to pay fees. What do people think of the FSA's proposed enforcement of mandatory fees on clients. The cynical side of me is forced to address the question, who will be left to provide advice to ordinary clients when most of the IFAs have been driven out of business? The answer is, of course, the big banks. Ian Pagdin, Woolhouse Douglas IFA, Sheffield.

Richard Howells, Bankhall Investment Associates Limited, Cheshire

Dear Ian,

It would seem logical to agree expecting clients to pay upfront fees for financial advice will not be widely adopted. However, we must look at the reasons behind this and rather than offer objections we should seek to offer some solutions.

The purchasing behaviour of the consumer reflects value in their eyes at the back end of the advisory process, for example when the client can see investments are growing or insurances have paid out. With this in mind the market needs to find ways of clients remunerating advisers at a point at which they become willing buyers. To encourage this we should look at ways where fees can be taken from the fund value or where fees can be taken on an ongoing basis and be linked to the service being provided to the consumer or the outcome being realised.

In addition, we would support government support in educating the consumer about the value of receiving financial advice. This would help to change the perception of the adviser and the advisory process in the eyes of the consumer and may create a greater and more positive propensity to pay for the service they receive through an upfront fee. In terms of who might win if the government were to impose upfront fees on consumers, the banks in isolation will not begin to dominate the advisory landscape.

The intermediary market has shown consistently it provides the service the investing consumer wants. Those same consumers will find their way to IFAs as they will positively discriminate against receiving their financial services advice from a bank whose reputation for delivering consistent advice and service simply is not well established. In short, the intermediary will remain strong by shifting its proposition and remuneration structure to suit the needs of the market and to comply with legislation and regulation.

Stephen Young, Sesame, London

Dear Ian,

Evidence shows commission-based purchases remain the most popular method of paying for advice among consumers so any move to abandon commission has the potential to disadvantage a great many customers in the absence of simple, affordable and compelling alternatives. ]

Sesame has yet to see any definitive evidence that the payment of commission leads to poor advice and does not believe there is a systemic commission bias. Reforms that help articulate the value of advice and the costs associated with it clearly and unambiguously are needed. It is the role of regulation to encourage a dynamic and healthy market that enables consumers to engage with it.

Sesame believes the retail distribution review offers a genuine opportunity to create diverse and innovative ways of encouraging consumers to do so, as long as the means of paying for advice is built upon two fundamental principles. Advice must be affordable to any consumer who wants it and remuneration is about helping consumers buy, not restricting how advisers sell. Consumers should have a right to choose to pay for advice however they want to, including through commission.

Robin Gordon-Walker, FSA, London

Dear Ian,

The retail distribution review is looking at the distribution of retail investment products and services, not mortgage and general insurance products, although we have said if the industry wants to apply any changes more widely we will need to consult those sectors.

The retail distribution review discussion paper sought to alter the debate from one about commission versus fees to one about whether product provider influence on remuneration could be eliminated while enabling remuneration to be deducted from the product with the customer's agreement. The RDR paper was intended to seek industry views and no decisions have been taken. We will publish an interim report soon to update the market and we intend to publish the feedback statement and decisions in October.

Fay Goddard, formerly of the Association of Mortgage Intermediaries, London

Dear Ian,

The FSA has not made any firm proposals to prohibit commission, although there is clearly a growing desire to encourage firms to move to fee based offerings. The retail distribution review discussion around the definition of fees and consumer agreed remuneration allows commission provided the amount is agreed upfront.

There is a slow but steady move towards fee-based advice, which will continue. Any regulatory intervention is likely to incentivise firms to adopt a fee-based service rather than mandate them. An outcome that will see IFA firms operating a remuneration model that serves the needs of their clients while supporting their, sustainable, long-term businesses is the preferred outcome. Consumer choice remains at the heart of the matter and there is a desire from the consumer to have the choice of paying for advisory services through commission along with those who prefer to pay for service by fees. Commission structures should be simplified to remove any possible perception of bias towards a particular product. The commission structure and payment of must be clear, transparent and unbiased.

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