Commenting on the consultation paper, Paul Smee, AIFA's Director General, said: "We support the FSA's proposal for the introduction of a broader and more in-depth set of examinations which, if implemented, will expand the knowledge and, consequently, the professionalism of the IFA community.
"But the proposed framework lacks clarity. An example of this is the absence of any clear indication of the number of modules which an IFA operating in today's market would need, in order to achieve qualified adviser status. AIFA estimates that it could be as many as seven - four more examinations than are currently required.
"If this is the case, this could result in those firms which are recruiting and training new advisers, being put under severe financial pressure at a time when there is a clear need for more advisers and the industry needs to attract and train new recruits.”
He continued: "Whilst we have been a consistent supporter of the FSA's modular approach to examinations, we think their proposed framework fails to provide a clear structure which addresses the changes which are likely to occur in the advice market in the near future and which allows career progression.
"The FSA's proposals for the reform of polarisation and the Treasury's proposals for the introduction of simplified products, are likely to result in the evolution of a number of different types of advisers giving differing levels of advice. This could range from very basic financial advice to holistic financial planning.
"Any new examination structure must be able to accommodate the needs of these various advisers and their clients, but the FSA's proposed framework fails to deliver the 'tiered approach' which we believe is necessary to achieve this."
