The statement particularly recognises the contributions made by AIFA, AMI and AFB as three of the seven key trade-body responses, accepting the trade bodies' calls for implementation to be delayed from October this year until April 2009.
Andrew Strange, Policy Director, AIFA, said: "We're pleased that the FSA has listened to our calls for a delay in the implementation of the new proposals. It's not quite the year-long delay we were looking for, but April gives our member firms more time to adapt to the different regime, and focus on existing deadlines like TCF, and current market conditions. CP07/23 was not a well publicised consultation, and there are significant changes for IFAs that have not opted into MiFID, as well as all mortgage and insurance advisers. Whilst the extended deadline is welcome there is still work for firms to complete prior to April.
"In our submission, one key issue we highlighted was that of ‘material outsourcing', which had possible ramifications on firms using compliance consultants, lead generators and even packagers. After our submissions, and meetings with the FSA, a welcome concession that existing contractual outsource arrangements will not be included until they are changed has been agreed. This is a notable win for small firms that prepare themselves prior to April and just grandfather across indefinitely any contractual outsourcing
"We are also pleased that we have avoided bringing in extra responsibilities for mortgage and GI firms through a potential CF10 function. There was significant ambiguity on this point in the original consultation and we welcome the clarity in the Policy Statement.
"AIFA acknowledges that there are a number of further areas of work for firms, primarily relating to the concepts of compliance, audit and risk functions, and also conflicts of interest management. Because AIFA has been engaged with these issues for some time we are already well underway with our work on these topics and will be releasing a series of dedicated factsheets for member firms between now and early 2009."
