The Personal Finance Society (PFS) is seeking clarity from the Financial Services Authority (FSA) on whether advisers will need extra qualifications on long term care (LTC) insurance to remain independent post-RDR.
Under current rules, anyone wishing to advise on long term care (LTC) insurance policies must have passed an appropriate examination.
However, unlike pension transfer advice, advisers in the LTC market do not need to be granted specific permission by the FSA to carry out the activity.
With LTC insurance classed as a retail investment product, the PFS is concerned about the impact of RDR.
Fay Goddard, chief executive of the PFS, said: "My question to the FSA is that, if it [LTC insurance] is an investment product that falls under adviser charging rules, are you saying to be independent everyone has to do the qualification?
"Or is it like pensions transfers, where you need a special permission and qualification?"
Last year, following consultation with the FSA, the PFS published a guide to the requirements advisers need to meet to stay independent post-RDR.
However, with many questions still unanswered, Goddard confirmed the organisation is working on a follow-up to the guide and has been in further conversations with the FSA over the past few months.
She added: "We've flushed out key areas where we want more guidance, including the use of centralised investment propositions, which is dependent on an ongoing FSA review into the area."
"The other area is specialist referrals and specialisms within firms. I'm still not comfortable we've got clarity on that and the position they were taking. I think it would be detrimental to consumers."
Under its interpretations of the rules, firms specialising in certain areas of advice would run the risk of falling under the restricted banner.
For example, a firm focusing its business on investment advice, with no advice on life products or personal pensions, would not be permitted to call itself independent.
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