AIFA says the FSA's planned 30-month time limit for new advisers to qualify is one "arbitrary number" in a paper it says raises more questions than it answers.
In CP10/12 Competence and ethics the FSA proposes to apply one overall time limit of 30 months within which an individual who joined the retail advice sector after 30 June 2009 must pass all modules of their necessary qualification.
The paper states: 'We have chosen 30 months as this reflects the upper range of previous time limits. All activities within the TC source book will be subject to the same limit.'
But head of policy at the Association of IFAs (AIFA) Andrew Strange says the time limit is "arbitrary".
"It is absolutely possible to do a qualification in 30 months but where is the justification for picking that arbitrary number? We just appear to have it now, without any evidence for it.
"Also there are lots of different exams out there, so how long it takes an adviser to complete a qualification will largely be down to the individual and the type of assessment."
He says today's paper also seems out of sync with previous FSA criteria on qualifications.
"Historic rules required individuals to pass examinations within two years of starting an activity, and were based on a QCA Level 3 equivalent qualification.
"I therefore question whether a 30 month period to complete a QCA level four qualification is appropriate."
Elsewhere in the paper, the FSA hinted it could takeover the mandate to update qualifications standards from the Financial Services Skills Council (FSSC), and force a review of qualifications standards every three years.
Strange says this is another example of the FSA taking steps without showing evidence for intervention.
"The FSA admits in the paper that there is not even a market failure analysis to support a three year review of standards."
On whether the FSA should take control of standards from the FSSC Strange says duplication should be avoided, and he questioned whether the FSA has staff with the right skills to manage qualifications.
"If there is a duplication of the FSSC's work there is a duplication of cost. The FSSC already has qualified staff to deal with standards. The FSA would have to recruit similar staff if is took over the role."
He says a paper which "raises more questions than it answers" will not give firms the regulatory stability they need.
"For example, the TC source book was scaled back in 2007, with a view to remove it altogether this year. Now we have this u-turn in which more emphasis is placed on the TC source book.
"This is not going to give firms the regulatory stability they need."
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