Adrian Coles, director general of the BSA, said: "As with any change we do have some concerns, notable among them the apparent guilty until proven innocent approach to future enforcement publicity."
Coles said in the days of 24/7 media and Twitter recovering a reputation after such an announcement if events prove this warranted will be "very difficult".
And he warned "The innocent may well pay for the sins of the guilty."
The Financial Conduct Authority's plans include a pre-emptive approach to regulating business conduct with an act now, investigate later attitude.
The regulator will also have the power to name and shame firms or individuals who have received a warning notice proposing disciplinary action.
The paper makes clear that the FCA’s new authority to publicly announce the start of disciplinary proceedings will be of equal benefit to consumers and firms.
It states: “By being more open and transparent about our enforcement process, we will help consumers better understand the action we are taking on their behalf, and bring potential problems to their attention earlier.
“It also makes it clear to firms, and the market, as to what we consider to be unacceptable behaviour.”
But despite Coles' concerns he said the trade body welcomed the publication of the Journey to the FCA document today.
"This is a helpful step as we get closer to their official launch next year," he said.
"We are particularly pleased to see that putting customers at the heart of the business is a key element of the FCA's approach. This underpins the way our members, as customer-owned organisations, do business."
