Responding to the consultation paper, Lucy Courtenay, CII Qualifications Director commented:
"Our concern is that grandfathering would create two classes of adviser and lead to confusion among consumers."
She added:
"Given the complex nature of LTCI advice and the potential vulnerability of consumers, we believe that ALL advisers should be subject to the new training and competence requirements however transitional arrangements need to be put in place to ensure existing advisers have sufficient time to meet the new requirements."
The CII supports the FSA proposal for LTCI to be regulated as an investment product and believes that the regulation should also encompass Equity Release Schemes when they are used to fund LTCI costs or life time mortgage arrangements.
In its response to CP200 Regulation of long-term care insurance, the CII went on to say that it supports the indicative syllabus and continues to work with the SCFS on the detail. There are particular aspects relating to the different legislation in Scotland, Wales and Northern Ireland and cross border placement issues which still require clarification and the CII have put forward options as to how these might be handled.
The CII also warns against advisers postponing taking any examination or undertaking T&C on the grounds that the new regime will have different requirements. It calls on the FSA and SCFS to make this position clear and so avoid a potentially damaging T&C hiatus.
