Sesame Bankhall Group is calling on the FSA to consider a standard factoring scheme.
In its response to last week's RDR consultation paper, the newly-formed adviser giant urges the FSA to consult the OFT on the benefits to consumers of allowing an industry-wide factoring facility.
As part of the FSA's proposals for adviser charging, providers would no longer be able to offer factoring services. It says the move is necessary as part of attempts to extinguish provider bias
Critics maintain this could have a hugely detrimental impact on regular premium business.
"We agree any discussion over remuneration should be between the adviser and their client, but this should not lead to the removal of factoring support by providers," Sesame Bankhall Group executive chairman Ivan Martin says.
"We believe this enables millions of people to benefit from expert guidance and thereby enhance their financial wellbeing."
"If recent economic events have taught us anything, then it is our need to reinvigorate the UK's savings culture, so that we can transform the fortunes of the British people and discard our nation's dependency on debt."
Martin also criticises the FSA's assertion regular savings constitute only a small proportion of the market and the impact of a ban on factoring will therefore be limited.
"The fundamental point is the regular savings market should be far larger than it is today and we need to encourage growth rather than restrict it further," he says.
"The FSA is right to be concerned about any potential consumer detriment, but removing factoring will simply result in fewer people accessing advice, which in our view is detrimental to the wider public interest."
In last week's paper, the FSA said it will be "more flexible" in its outlook on how unqualified advisers should be assessed. It said it would consider methods including practical assessment, e-learning and course work after earlier suggesting only written and oral testing would be suitable.
But Martin says some form of work-based assessment remains the best way to assess advisers' competency.
"We have consistently argued for the introduction of work-based assessments as a common sense solution that recognises the wealth of knowledge, skills and experience that already exists within our profession," he says.
"The FSA's greater recognition of alternative assessments as both a transitional and ongoing route for competent advisers is therefore a step in the right direction.
"However, with the continuing imposition of the 2012 deadline we are increasingly concerned about the lack of detail, which is making it very difficult for advisers to determine their approach to professional qualifications."
Martin adds: "The clock is ticking and there is no clear plan on alternative assessments; no new examinations and updated study materials; and the "no regrets" CPD gap filling requirements are also yet to be fully defined."
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