Ever tried reading Finnegans Wake or Moby Dick? How about Les Miserables, or maybe an FSA consultation paper...?
Like each and every FSA paper preceding it, last week's effort on proposals for its regulatory fees and levies for 2010/11 was a tough old read.
If you haven't yet had the pleasure of going through it, we've pulled some of our favourite bits to see if you can make head or tail of them. Please do let us know what you think, or perhaps whether it's "just us".
Otherwise, the campaign for clearer, jargon-free FSA communication documents starts here. Let's begin...
1.43 We propose that inward-passporting authorised payment institutions providing payment services from UK establishments are offered a discount to reflect our limited role as host state.
That one was just a taster. It gets a lot worse.
3.6 We proposed that the straight line recovery policy should be flexible enough to accommodate a targeted recovery of costs within a fee-block, on an exceptions basis, where such exemptions can be justified.
We get the gist of this - we think - but isn't there a simpler way of saying it? Perhaps the next bit will clear it up?
3.6 (cont.) This exceptional moderation can be either side of the straight line recovery and would be achieved by applying a premium or discount to the rates applied to the tariff data for the specific permitted business firms undertake within the fee-block where recovery will be moderated from a straight line.
Thought not. Moving on...
11.17 Firms already authorised under FSMA and allocated to fee-block A1, except for credit unions, that provide payment services by virtue of their part IV permissions will be charged fees based on the MEL tariff data as supplied to calculate fees on in fee-block A1. This basis for tariff data was confirmed in PS09/8.
13.15 The additional levies for FinCap/CFEB mirror the FSA fees structure and are applied to the tariff-bands that we have introduced for each fee-block following the strategic review, as explained in Chapter 3. We have applied the straight-line recovery model to all fee-blocks, without moderating the line to put a premium on the high impact and systematically important firms. This is because the moderation is intended to take account of our enhanced supervisory costs, which would not affect CFEB.
I haven't seen a paragraph this poorly written since my A Level history paper.
13.15 Firms which make pre-payments of their FSA fees by 30 April because their previous year's FSA fees (excluding the FEES 7 levy) were £50,000 or more, as set out in FEES 4.3.6, will make pre-payments on the same terms of their FEES 7 fees.
Can it get any worse?
17.5 The total costs incurred by us in arranging the authorisation process and preparations for regulating reclaim funds post-authorisation comes to approximately £170,000.
No further questions, your Honour.
There are many more examples, but frankly we're feeling a little sleepy. Maybe you have come across even worse examples in the past. Please do enlighten us.
Anyway, let us know your thoughts and, if we get enough responses, maybe we'll pen a really, really long letter to the FSA to let them know how we feel!
Thanks for reading.
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