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PIMA responds to FSA Platforms Discussion Paper

June 27, 2007

In responding to the FSA Discussion Paper 07/2 – Platforms: the role of wraps and fund supermarkets, Director General Tony Vine-Lott said,

[i]‘PIMA is extremely pleased with the Discussion Paper issued today which is broadly reflective of our input to the FSA and the work of the PIMA Strategy Group on Wraps.

It is particularly encouraging that the FSA has undertaken this work. We believe that the FSA has taken a balanced approach to potential benefits to the consumer arising from the product features offset against potential for consumer detriment. We believe that the principles-based approach is the right one and look forward to working with the FSA on how to apply the principles in the future.

The FSA is prescient in its reluctance to put rigid definitions on terms and parameters. They have clearly grasped the diversity in the current marketplace amongst propositions and the scope for even greater choice in the future.

Likewise, members of our Strategy Group were particularly keen that the FSA recognises ‘wrap’ as a service instead of taking the view that it is a part of a packaged product (i.e. the service being inextricably linked with the underlying investment) and the Discussion Paper has clearly agreed with this position.

However, there are a number of areas where we look forward to working with the FSA. They include:

· Appropriate use of wraps, including better understanding by intermediaries of both services and underlying investments

· Transparency of charges

· Improved standards on issues such as transfers out and re-registration.

. Better methods for comparison between platforms/offerings

The Tax Incentivised Savings Association (TISA) will continue to work with content and platform providers, distributors, and the FSA in this important area in the very near future.’[/i]

For more information:
Tony Vine-Lott, Director-General, PIMA
07790 006108

Jacob Coy
Iain Anderson
Cicero Consulting
020 7665 9535
079 0039 2531