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As the echo of the screams faded away, I could see the IFA’s blood pressure slowly return to normal, the redness of the face decline, the bulging veins in his neck relax and the fists unclench. “OK?” I asked

“No” he shot back. “It bloody isn’t OK. I’ve just had an interaction with the FCA. Total b@@@@@s.”

(At this point, dear reader, if you are of a sensitive nature, I apologise for the bad language but verbatim reporting is my style.)

“Oh,” I said. “What’s the problem?”

The IFA looked at me. “Do you remember an old joke – probably from your schooldays – ‘what’s the difference between an elephant’s arse and a postbox?’ You say you don’t know and I say ‘Well, I’m not sending you out to post a letter then!’. Remember that one?”

“I do,” I replied.

He continued: “Well, if you asked the FCA the same question, how d’you think they’d answer it? In fact, better still, suppose you said to them ‘I’ve got an elephant’s arse and a postbox in front of me, which one should I post the report to you in, because your guidance isn’t clear?’ how d’you think they’d answer that?”

“Er, put it in the letterbox, I guess. That’s just common sense.”

“Ha! I’ve just asked a simple ‘is it a or is it b?’ question so let me tell you how they’d answer. First, they’d  want to know who you are and your FRN – so far, so good. Then they’d want you to ask your question and when you’ve done that, they’d repeat it back to you for confirmation. Still doing OK at this point but now we move into the realms of idiocy. What you’ll get is some b@@@@@s about not being able to answer the question for you and only being able to give guidance because they don’t know your business model so you will have to make up your own mind as best you can. Then they’ll refer to the guidance notes they sent you and they’ll read you what’s written on there: it’ll probably say something like “When returning the report you must post it in an appropriate receptacle. If you are given a choice of receptacle you must decide which is most appropriate for your report.” At this point you will feel your blood pressure rise. You’ll struggle to remain calm and you will reiterate your question, pointing out – again – that the guidance notes are not clear. If you’re lucky your contact will go away and ask a colleague for their opinion – if you’re not lucky, you will go through the same conversation two or three times more before they ask someone else. It’ll be like some mini Groundhog Day.”

He paused, breathed deeply and wiped the sweat from his brow.

“Sorry. So, to continue. You’d wait on hold – long enough to make a cup of coffee – and then your man would come back. He’d apologise for the wait and then, treating you like someone who’s 12 years old and with a sub normal IQ he’d slowly and carefully repeat the words of the guidance putting emphasis on the important bits – like this: “When returning the report you must post it in an appropriate receptacle. If you are given a choice of receptacle you must decide which is most appropriate for your report. So the guidance is clear and that’s why we’ve worded it this way so that you can decide which method bests suits your firm’s model.” So now you say, sarcastically, “So I’ll shove it in the elephant’s arse then” to which you’re likely to get “If that’s what you determine is best for your business model then you must act accordingly.””

He sat back, deflated. “To cap it all, when you finally give up and admit defeat, the pleasant unruffled bloke at the other end of the phone says “Is there anything else I can help you with today?” I can tell you, it took all my self-control to say “No, thank you, that’s all.” instead of blasting away with “Help? What help? You haven’t given me any help.” I mean – I ask you – for God’s sake….”

At this point, it seemed appropriate to make a gentle exit and promise to pop back on another day but what did I learn? FSA, FCA – put whatever label you want on, but as Shakespeare wrote in Romeo and Juliet, “What’s in a name? That which we call a rose, by any other name would smell as sweet.” and, as the French say, “plus ça change, plus c’est la même chose”.


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