I'm in the game of clear, concise and effective communication and, as client-facing advisers, so are you. The FSA, on the other hand, continues to struggle with its unwritten obligation to use plain English.
This week's FSA consultation paper on data collection was a case in point.
When the FSA writes about its plans for firms to disaggregate their revenue streams in RMAR forms, one wonders why it doesn't simply state it wants firms to break down their sources of income.
When I later asked Peter Smith, the FSA's head of investment policy and a thoroughly nice, knowledgeable chap, to explain why he wanted firms to go into so much detail, he said: "We could have specified data sets more granular than those we are consulting on..."
I had to call an actuary (Not really. I would never call an actuary).
The FSA has previous here. Not only did it win the Plain English Campaign's 'Kick in the Pants' award last year (no, really), we at IFAonline have also pointed out the regulator's often-incomprehensible use of, well, words.
Highlights from our exposé (OK, hardly), taken from its proposals on regulatory fees last year, included:
This exceptional moderation can be either side of the straight line recovery and would be achieved by applying a premium or discount to the rates applied to the tariff data for the specific permitted business firms undertake within the fee-block where recovery will be moderated from a straight line.
Firms which make pre-payments of their FSA fees by 30 April because their previous year's FSA fees (excluding the FEES 7 levy) were £50,000 or more, as set out in FEES 4.3.6, will make pre-payments on the same terms of their FEES 7 fees.
Our piece prompted one IFAonline reader to observe: "No wonder a great many IFAs don't read consultation papers."
To be fair to the FSA, this week's paper was more digestible than previous documents, so perhaps the suits at Canary Wharf have finally listened to the pleas of those it regulates.
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