Open Invitation to Mr Sants To Respond To This Question
Although I don’t expect a reply from Mr Sants personally at least I’m going to attempt to bring this QUESTION in to the open.
Like many operators in the securities industry I first learned of RDR from my firm in late 2009 when challenges and stipulations started being made about our abilities to give advice and trade in a business that as it turns out I feel that I have been part of since I was around 5 years old when I first bought shares through my grand-father (26 shares in Rio Tinto Zinc) in 1962 via Hoblyn & King, Stock & Share Brokers.
Since 1980, when I joined the old firm of Beardsley Bishop, I have done around 40,000 investment trades on behalf of individual investors and I’m pleased to say that so far not one single investor has made a complaint about my investment ethos, my attitude to risk pertaining to their affairs and throughout every trade has been settled satisfactorily.
One of the interesting aspects to the debacle known as the Retail Distribution Review is the concept that all advisers sell “Product” or plurally “Products”. This may be the case for many advisers (IFA’s & bankers maybe) selling schemes, investment products (or packages) but I fail to see how stocks and shares can be classified as such. For clarity “s&s” are instruments NOT products Mr Sants! Like many instruments (think of fishing rods or horse reins) they do NOT necessarily require ‘advice’ to use or transact.
By now Mr Sants you have probably switched off or passed this INVITATION to your laborious sidekick who, whilst responding to a client (who in fact wrote to you personally), recently suggested that INTEGRITY can be obtained through EXAMINATION. This is another example of nonsense eminating from the corridors of North Collonade.
Most private stockbrokers like myself like to think of ourselves as ‘guides’ in assisting investors (we call them ‘clients’ whilst many elsewhere have ‘customers’ and it’s clear the FSA only supports the notion of ‘customers’) in buying and selling securities (“s&s”). Essentially we are bookies suggesting to racegoers from time to time the timing of when to get on or off the proverbial ‘horse’. We give opinions and rarely trade on firm ‘advice’ as ‘suggestions and recommendations’ are the market norm in what is a always a moving environment.
Sadly we have no products to sell which is why I feel that the Retail Distribution Review is so sadly misaligned under a cloud of miscomprehension. The sheer title of this doctrine suggests that there is a wholesale attempt to pass off ‘products’ to unassuming ‘customers’ (RETAIL) across the entire market.
As you can gather Mr Sants I’d like to challenge this assumption as well as FSA’s incisive appetite along the lines that the PUBLIC that you profess to represent are demanding for a new world order in British financial ‘advice’. I’ve been told by peripheral people (there are too many) in the industry that I am deemed to be at Level 3 for purposes of RDR but before responding to this claptrap I’d like to ask you again, WHAT LEVEL ARE YOU AT MR SANTS?
You see, I think this question is a worthy one. It seeks to get to the root of the problem. A problem as it turns out that might just be of FSA’s own making. There is miniscule evidence to suggest that private investors dealing directly on the exchange or their brokers have been responsible for the credit crunch and yet those responsible for creating products and selling them on to investors (did I mention synthetic derivatives products being sold by the likes of JPMorgan & Goldman Sachs?) are conveniently being let off the hook by a regulatory process that has clearly got its knickers in a twist.
Have you answered the question yet Mr Sants? Of course NOT! After all you are a regulator and answerable to no-one NOT EVEN the government that you pretend to represent. You do as you please and direct operations along with your many chums who have vested interests in the RDR doctrine. You pay yourselves large salaries, obtain large fees from the banks and participate in large bonus schemes. You see you are just like the investment bankers really that you pretend to admonish.
Have you decided yet? WHAT LEVEL ARE YOU AT MR SANTS? You don’t appear to understand the question do you Mr Sants? Well, let me rephrase it, WHAT IS THE LEVEL THAT YOU HAVE DEEMED TO HAVE ACHIEVED AS THE CHIEF REGULATOR IN UK? The answer is NOT CEO of FSA by the way. I’d like to hear WHAT LEVEL ARE YOU AT MR SANTS? Of course you can’t tell me because there isn’t a LEVEL is there Mr Sants? Just in the same way I can’t explain why I can’t remember ever achieving the RDR levels of 1, 2 or 3. What are they by the way?
I can’t help feeling that there’s a rotten piece of a pigeon at all levels. Can you explain to me in your succinct language how I’ve achieved Level 3 please Mr Sants? You see, I don’t see that I can have achieved even a Level 3 without any form of submission, examination and/or invitation. LEVEL 3 is one of the great mysteries of my life in the City of London. I just can’t get my head around a process that deems me worthy of proffering advice one minute and at the very next holds a loaded revolver to my head, presents me with a large bill and expects me to take an exam so that I can place myself on a pedestal only to see the legs sliced on a regular basis. Call me a cynic Mr Sants but I suggest that someone is after my business.
Oh by the way I did PASS the CISI Integrity test online and was pleased to see I obtained a B grade. I’ll have another go very soon, pay the £20 application and let you know if I can press the wrong button to achieve the A grade pass. After all I wouldn’t want to find that the pedestal legs have reached the ground just yet.