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TISA responds to FSA platform consultation

September 28, 2012

TISA response to CP 12/12: Payments to platform service providers and cash rebates from providers to consumers

TISA has warned that significant questions remain concerning the FSA’s stance on banning cash rebates. Operating costs for market participants could also rise sharply if multiple share classes for pre- and post-ban business are introduced and the potential for errors could also increase.

In its response to CP 12/12 TISA acknowledges that the paper displays a much better appreciation of the way the market works. However the Association has voiced its concern that the paper continues to address the rebate issue in a way that assumes the current market is not working well for consumers.

Malcolm Small, TISA Director of Policy says:

“It seems that the direction of travel to ban cash rebates has now been set. Nevertheless there are a number of areas that require clarification. For example, a number of our members are nervous about inadvertently breaching rules on when unit rebates become ‘client money’ and have asked us to establish a committee to focus on this aspect.

“Our biggest concern however is the capacity of the industry to deliver the necessary changes to implement a ban on cash rebates in, effectively, a year’s time. With PRIPs, MiFiD 2, FATCA, RDR and other material all required in the development schedules for 2013, we would argue for the ban, if enacted, to commence in 2015. This is not a universal view, with some market participants suggesting it could be done in time. Operational prudence and avoidance of execution risk do, however, suggest this might be wise and, given the helpful delay to enable re-registration to bed in, would not be without precedent.”

The full response from TISA is available online at www.tisa.uk.com

Ends……

For further information, please contact:

Malcolm Small, Director of Policy, Mobile: 07989 500771 Email:malcolm.small@tisa.uk.com

Issued on behalf of TISA by Cauldron Consulting, contact Steve Radford – Tel: 020 3178 7238, Mobile: 07889 903786 Email: steve.radford@cauldron-consulting.com

Notes for Editors

The Tax Incentivised Savings Association (TISA)
TISA is the premier industry funded body in the UK retail savings and investment industry. By engaging with member firms, government, political parties, regulators and consumer groups TISA’s ultimate goal is always to further consumers’ best interests. It seeks to improve the range, features and quality of savings and investment schemes available whilst encouraging more people to save for their financial security and peace of mind.

Uniquely, TISA is able to articulate the opinions of the whole savings and investments marketplace through its membership comprising over 120 member firms involved in the supply or distribution of products. TISA’s remit extends across the broad spectrum of savings vehicles & services and centralised investment propositions.