Retail Distribution Review

Written evidence submitted by John Blackmore

Executive Summary

The minimum qualification for an Independent Financial Adviser should be Degree Level - CII level 6. The minimum qualification for Sales Advisers should remain as now – Financial Planning Certificate. Sales Advisers should be authorised to sell from an approved list of regulated products or product types with approval being provided by the FSA. The majority of Sales Advisers are not capable of obtaining CII level 4 and even if they were there is not sufficient demand in the market for complex financial advice for all current adviser/sales people.

Grandfathering is essential.

Submission.

1 Improved education cannot be argued against. The level of qualification required, however, needs to be appropriate and commercially based.

2 The proposed solution of CII level 4 for all could hardly be more inappropriate. It is not demanding enough for Advisers and yet it is unnecessarily complex for Sales Advisers.

3 Independent Financial Advisers offering complex advice need to be qualified to a far higher standard and Sales Advisers to a much lower level.

4 The sale of simple products does not justify complex and demanding qualifications and advice in complex areas should not be allowed by those with nothing better than "A" level qualifications.

5 90 – 95% of all current "Advisers" are really Sales people who provide advice as part of the Sales process.

6 The market does not need all current Retail Adviser/Sales people to be able to provide complex advice. There is insufficient demand for complex advice.

7 Increased qualifications will result in higher charges to the public with few if any ex Sales people being willing to provide low level inexpensive advice.

8 If CII Level 4 is imposed on all, the failure rate will be unacceptably high. I do not believe that many of current adviser/ sales people are capable of obtaining CII level 4 and many, like myself, are too close to retirement to reasonably asked to pass new examinations.

January 2011