When the Retail Distribution Review was first introduced by the FSA they declared it was a key component of a consumer protection strategy.
Granted the FSA also pointed out that advice has never been free - consumers have paid for this via commission paid to the adviser.
The FSA also stated that standards of qualifications needed to be increased to ensure advisors knowledge is always up to date a statement thoroughly endorsed by the Association of Mecial Insurance Intermediaires (AMII).
The impact on the IFA and benefits advisers, who were involved in placing any form of business that included investment, has been dramatic and from 2013 they have to change their working practises and levy fees for their advice.
But how far away is the rest of the insurance market and in particular health insurance from a similar predicament?
AMII's view, after consultation with other organisations such as BIBA and from a consensus of their larger employment benefit members, is that this could well work its way out of Europe via the newly formed FCA in the not too distant future.
Indeed at the recent Autumn Conference of AMII Alex Alway, chief executive of Jelf, was on record as saying a review would happen in the next five years.
This may be the case but AMII's view is that it is more likely to be a phased process and the first phase will likely standardise commission. It would ensure a level playing field and potentially eliminate the "commission kickback" dilemma that affects age-related health insurance far more than consumer health insurance at present.
Our view is that transparency of commission on a level basis is the first priority, coupled with raising the bar in terms of professional qualifications to maintain sound advice and treating customers fairly.
This phase is predicted to come in within the next five years with the more onerous nil commission fee-only regulation possibly in eight to ten years time.
However this is more educated speculation than fact as the first indication of more stringent regulation under the FCA seems to be concentrating on conflicts based on incentives and override commission deals and the red herring of "hospitality".
AMII actually believes that within the health insurance arena the subject of hospitality is not a concern for its members or the insurance providers.
So are we sitting on a ticking time bomb or a slow burning damp squib? I am sure more will be revealed in 2013.
Wayne Pontin is chairman of the Association of Medical Insurance Intermediaries
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