The ABI is sticking to its initial reaction that implementing CP170 will cost £100m, despite reactio...
The ABI is sticking to its initial reaction that implementing CP170 will cost £100m, despite reactions reported by the FSA suggesting that mock documents modelled on the proposed new rules are seen as clearer than existing Raising Standards alternatives.
The FSA says in its Consumer Research 18 document, which compliments CP170, that its own "new design for disclosure documents was generally found to be clearer and more customer-focused than the Raising Standards KFD."
"The different format, more direct style and plain English set it apart from the Raising Standards document, which was perceived to be more conventional with a long narrative and rather too many bullet points," CR 18 says.
The ABI says this is to be expected because the research compares apples with oranges.
"Raising Standards KFDs work within the existing rules," an ABI spokeswoman says.
"If you remove the constraints, then you can improve anything."
Commenting on the general findings of the consumer research, she says it is "not a great surprise", but that the ABI "needs to study the research project in greater detail" before passing final comment on CP170 by the 2 May deadline for responses.
She also points out that CR18 also says in its conclusion that "Raising Standards KFD was generally felt to be an improvement over the standard KFDs in use at the time of the research".
This point is crucial the ABI says on the issue of the cost of implementing new rules.
The association still questions whether the £100m cost – its own figure – justifies changing the rules "if all we are doing is making something look a little bit better."
FCA consultation response
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