The Association of IFAs (AIFA) has told the FSA there are plenty of "risk indicators" it could use to determine which firms should contribute lower annual fees.
A good complaints record, encouraging its advisers to join a professional body and voluntarily holding additional levels of capital could all be held as signs of a lower-risk entity, it says.
Additional information the FSA plans to collect on firms' product sales data (PSD) could also be used as an indicator, AIFA policy director Andrew Strange says.
In February, the FSA said assessing individual firms' risk to the market would present it with "significant" operational challenges and costs.
However, last month, it declared it would be "happy" to consider further research in this area after admitting the general consensus was to base individual firms' fees on their likelihood of failing.
The FSA's annual funding requirement, met by regulated firms, is estimated at £455m for 2010/11. It totalled some £414m the previous year.
Currently, the FSA allocates its levies taking into account the total costs of regulating the sectors represented by its fee blocks, and the 'overall' risk profile of the firms in those fee blocks. This second element is determined according to firms' size.
Andrew Strange says: "The FSA should be doing more to ensure riskier firms pay higher fees. I shamelessly admit I don't think the IFAs or mortgage brokers we represent pose high levels of risk.
"We're not systemically big business, we're not too big to fail and we don't hold client money. This is a lower-risk basis."
Strange says there are a number of risk indicators readily available to the FSA.
"Our research shows a lot of IFA firms do hold quite a lot of money, because they choose to do so for business purposes. That's a good indicator.
"If you look at fines in the mortgage industry and cross-reference that to the number of firms in the AMI membership, it is hardly any, so is being a member of a trade body a good risk indicator?
"The FSA could even look at the products firms are recommending. If you are an IFA recommending stakeholder pensions with regular premium business, that is very different from recommending massive lump sums with high-risk investments."
Keith Richards, group distribution development director at IFA support provider Tenet, says the FSA should introduce a separate sub-class solely for IFAs.
"Tenet supports any move to base IFA firms' fees on their risk profile," he says. "But the bigger issue is that IFAs should be in a sub-class of their own."
Richards says IFAs should "not have to share a sub-class with higher-risk firms" because they could be penalised unfairly, as he says happened recently following the collapses of Keydata and stockbrokers Pacific Continental and Square Mile Securities.
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