Disclosure laid bare

CP11/3 proposed amendments to the rules on how to draft key features documents and illustrations in order to make them compatible with Retail Distribution Review proposals and the gradual integration of personal pensions and self-invested personal pensions. But the sheer complexity of the proposals and COBS 13 – which most of them involve amending – raised concerns even within FSA ranks as to whether the work that goes into most regulatory disclosure in the retail market is really worthwhile. Adam Samuel suggests a re-think.

Adam Samuel BA LLM DipPFS MCISI Barrister Attorney may be contacted at AdamSamuel@aol.com. His book, ‘Complaints and Compensation: a Guide to the Financial Services Market’, is available from his website, www.adamsamuel.com.

It is difficult to be against certain things in regulation: training and competence, ethics, management information and disclosure. Yet a certain scepticism is in order and is even starting to affect the FSA’s pronouncements on these subjects and no more so than on disclosure. Every piece of consumer research shows that material laboriously prepared for consumers in accordance with highly complex requirements is either not read or not understood.