AIFA responds to CP166

AIFA does not spend time defending the current regime in its documented response to CP166, instead focusing on the changes put forward by the FSA and pointing out what it considers to be inconsistencies or weak points in the proposed regime. The main concerns expressed concern "checks and balances", "terminology", "multiple ranges", "suitability", "capital investment and advisers", "appointed representatives" and "initial disclosure documents". Appointed reps are an addition to AIFA's comments since its initial reactions, because, it says, it missed a key fact buried in the FS...