FSA: we spent too much time on RDR instead of RBS

So they spent too much time and energy on a problem that didn't exist and so completely missed what they should have been regulating?

If ever a new broom were needed this is it as how can anyone have any confidence going forward?

FSA LOL

Quite a title considering what was actually written in the report. The main reason RBS failed was poor management and goverenace of the bank, by the bank. Yes there were many other contributing factors such as aquisitions, the global economic crisis, regulatory challenge and liquidity. Blaming RDR for RBS failing doesnt seem overly....balanced?

LMAO

Perhaps they don't have enough apparatchiks??

Spent most of their time trying to regulate the little man out of business whilst ignoring the real issues.

Spent the rest of the time wondering where all their future pay packets would be coming from no doubt.

Sants and Turner should be sacked with no pay offs - grow some balls George and do it. They're answerable to your department aren't they?

Are the FSA going to compensate the tax payer for the billions lost when propping up RBS. Of course not. The failures that the FSA have listed for their own organisation are no different to those that they fine many IFA/Banks for.

Brilliant - you have to laugh ... or you'd simply cry!

If it were us, as an IFA firm, we'd be crucified!

Why on earth do we bother to worry about clients decsisions at the micro scale if the regulators couldn't seemingly care less about the far more important macro scale ?

Having just passed the RO1 exam and having reading about all the lovely commitees / boards / directives and so on and the milions that are spend on ensuring "financial stablity" (ha ha ha ha ha) domestically and in the EU, it simply beggars belief.

The lunatics really do run the the asylum.

I totally agree with Jonathan.

The lack of proper skills was mentioned, which I reported on several years ago. They recruited graduates in non-financial subjects from the beginning - people who did not have a clue about basic finance, let alone any complex bank issues!!

Those in management positions responsible for not regulating the bank(s) should all lose their pensions!!!!

Once again it just beggars belief!

You can bet your bottom dollar we are now all going to suffer for this poor supervision in that we will be more and more under the spotlight.

Wonder if I can lose my clients £25 billion - Anyone know of such a scheme - oh yes it is called 'banking'.

You have to admire their cheek, apologising for spending too much time on the wrong things and then acting as if it doesn't matter anyway as we will now be free to devote even more wasted time on the RDR and TCF issues.

What happens in about 18 mths time when the retail investment market declines dramatically because ordinary families cannot afford the costs of fees, cannot access their IFA because they have decided to leave the industry and cannot spread the cost of advice over the term of a contract and another no doubt inwardly gazing investigation determines they got that wrong as well.

Has no one at the FSA any common sense, if you are going to change an industry, impose additional (and quite unrepresentative) exams on existing businesses, ban commission and make consumers pay fees, which in turn will lead to less consumers buying into financial investments then you need to move forward slowly, assess each element when it comes into force as to the effect on consumers, the industry stakeholders, who after all pay these peoples wages, educate the public on the changes and prepare them for the inevitable shock wave this will cause, not barge through ill conceived, badly researched and draconian changes to existing systems and IFA practices.

The sledghammer wielders of the FSA have lost the plot, fining Transact £3.5million for a system error, which resulted in no consumer detriment is just plain daft, when banks were not properly supervised by knowledgeable staff.

Our world has gone mad and the lunatics are definitely in charge of this particular asylum.

This is what happens when an ideology gets in the way of the business at hand. Empire building with our levies instead of providing proper supervision. Shameful!

I hope Mr Hoban studies this carefully. Jonathan's quite right, they spent too much resource where there was no real problem, RDR and the quite mad 'TCF' initiative (does it still exist?) and too little on the Banks.

Though if Brown hadn't have taken the BoE off the Supervising Clearing Banks case, they may not have got into such a state.

Agree with Barman, interesting title for the article to grab our attention, and opportunity for other commenters to get in some FSA bashing.

At the end of the day RBS management are responsible for the failings of RBS. Getting into a bidding war for ABN Amro at the peak of the market can't of done it any favours.

Warren Buffett suggested the way to get decent behavour from bank chief execs and senior managers was to ensure that they and their families suffered financially if there was a failure of an institution they are responsible for. Contrast between this and the position Fred Goodwin now finds himself with his £342,500 a year pension is striking.

So, in other words, the FSA decided to spend far too much of their resources on their pet projects (such as TCF and RDR) to the extent that they ignored the RBS take over of ABN AMRO and their capital inadequencies? With the result that the current loss to taxpayers runs into the serious billions.

Perhaps a properly regulated RBS might have thought twice about such moves, but probably they knew there were unlikely to be any regulatory objections, so ploughed ahead anyway.

And what consequences are there for the FSA in all of this - abolsutely none yet again. I read one report this morning saying that whilst RBS survived this crisis, the FSA did not - but they have really, as they will just resurface as the FCA!

Is this yet another form of Phoenixing that we all love in this industry?

Frightening, truly, truly frightening.

So, in addition to the stupidly high costs of TCF and RDR (not that I would quarrel with the aims of either), we now know what we had always suspected, that we can lay a good proportion of the blame, and the consequent costs, at the door of the buffoons at the top of the FSA!

Wonderful!

Oh! and thanks Dave, for doing your best last week to protect this lot from the marauding and evil EU and their 'restrictive' regulations!

? Unfortunately getting them both wrong?

Resulting in a state bailout in the first case and then in the second case depriving a lot of not very rich people of financial assistance by reducing IFAs available and pushing up the costs.

Classic case of too busy looking after the pennies & ignoring the pounds!

TCF and RDR may not be all we would hope, but it does seem rather petulant to ascribe blame to them for the failure of regulation of RBS. Certainly the regulator ought to be placing greatest emphasis on aspects of the industry with the greatest potential for damage/loss which we all believe to be (and seemingly have evidence for) the banks. We all have lessons to learn from the crunch such as better governance, systems and controls, risk assessment, adequate research, transparency and understanding.

The headline is quite accurate.

The potential for consumer detriment is exponentially higher within the bank advice sector and the financial meltdown of one of these behemoths has staggering financial implication and knock-on effect, as we know.

Any regulator which understands its remit and has the political support to follow this, rather than play to the consumer/journalism gallery, would have focused on themajor players.

How many of these staff received and accepted their 30% of salary bonuses? How many were disciplined or sacked? How many have since been promoted to positions where their lack of skill will be even more glaring?

"The FSA also recognised it failed to develop, within the supervisory teams, adequate levels of skill and experience to focus on issues of capital ......."

When they say 'The FSA' they actually mean the senior management. Are any of these people being held to account or losing their job - or even having to repay their bonus? Yet if an IFA firm failed to ensure that their staff were of adequate skill and experience ......?

Same old story I'm afraid - one rule for those of us doing the job and another for those who we pay to look after the industry. Still, the consumer will no doubt feel that the current (and coming) austerity measures, job losses, home repossessions, later retirement etc is a small price to pay for the benefits of RDR. Hey, my pension pot may have been decimated - but at least I know exactly who gets what from the charges!

Hector ........................... bye bye

So - why are we surprised?

FSA devoted all their time devising schemes to kick the crap out of IFAs, yet as "Nero fiddled Rome burned".

You really could not make this stuff up.

As commented earlier - you have to laugh or you would cry.

But I bet you the same FSA faces will appear at the window of FCA or whatever it's to be called.

We really do deserve better and so do our clients.

Just a refund would help.

FSA - NOT FIT FOR PURPOSE

And, as true to form as ever, those who wrote the report simply HAD to get in a bit about the supervisory teams having been "seriously under-resourced", thereby fuelling further Adair Turner's never-ending calls for more resources, more staff, more power and, above all else, as always, MORE MONEY ~ the solutions to all the ills of the regulator. Just allow us to keep on demanding more, more, MORE of everything from the industry and more powers over every little thing it does and eventually, one day, some day, when we employ more people than there are left in the industry itself, paying us levies of truly breathtaking and back-brealing magnitude, we'll finally find the pot of gold at the end of the regulatory rainbow and everything will be hunky dory. We'll have so much in the way of people and powers and money that if ANYONE steps just an inch out of line, we'll be able to send in a SWAT team at a moment's notice and stamp on them so hard that their innards will fly out of their mouths.

Meanwhile, the massive blunders, oversights, profligacies, let-offs for senior individuals in the banking sector and the complete lack of accountability will continue on a scale that simply wouldn't be believable if it weren't for the fact that they're already happening and we're all paying for them.

In a way, I'm sympathetic to the regulator for having been given responsibility for a task for which it was patently ill-equipped. What I'm not sympathetic to is the fact that neither Hector Sants or his predecessor recognised this or, if they did, that neither of them was prepared to admit as much and have the backbone to tell the Treasury.

A lame excuse from a lame regulator.

Imagine the fine and penalty an IFA would pay for giving the same dumb excuse.

How can anyone have any faith in a regulator where no one is being held to account for its failings, smacks of do as we tell you to do and we will do just as we please.

When democracy is died you eventually have a revolution.

How much blood needs to be drawn, washed into the waters of discontent before the media sharks become hungry enough to feed? When will someone with authority stand up and be counted. When will someone say “enough is enough”?

I am but a simple man, but from where I sit, the world has gone mad. The consumer needs protection that there is no doubt, but from who?

We live in a country where those that pay the wages of the Government, Regulars and the public sector, have no say at all on how it is run. These bodies have managed to manipulate the system so they have total control and can TELL us we are wrong and they are right. They waste our money, they tell us we cannot do that, this and the other, yet expect us to do it. When we get it wrong we are fined, see claims, put out of business and face possibly prosecution. When they get it wrong they just say sorry and are allowed to move on to the next disaster or higher paid job.

I close with these final worlds “Absolute power corrupts absolutely!”.

So FSA couldn't do job it was paid to do or effectively discharge it's responsibilities - yet Turner wants more power for the regulator and Cable seeks to try and disqualify bank directors whilst quietly saying nothing about FSA top brass?

If this headline was true then every bank, financial organisation and small practice would have failed due to the regulators focus on RDR. But they didnt. Why? Because they were managed and run much better than RBS was.

It's been said before but so so true now:

"The FSA fiddled while the UK economy burned!"

Then Hector gets a new job on the back of it - disgraceful!

One is reminded of the lyrics of the 1972 song Is There Life On Mars: Take a look at the lawman beating up the wrong guy...... And doesn't the FSA just love to beat people up?

No one can reasonably argue against raising standards across the board or that those who dispense defective advice should be held accountable for it, but for the FSA to have concentrated SO intensively on the relatively small scale sins of the IFA sector whilst allowing such a massive corporate entity as RBS to crash and burn really is an appalling, all but criminal, dereliction of duty. Reckless? Negligent? How the mandarins at Canary Wharf can do anything but hang their heads in shame really does test the limits of credibility.

Yet again the FSA has proven it is unfit for purpose. It really is time the Government called it to task and put in place a form of regualtion which works and is in the public interest.

There see new it was all us IFA's fault, if we weren't around for them to try and destroy it wouldn't have happened!

Echoing other comments, the cretins at the FSA should be castigated and then sacked for not regulating the banks properly.

The resources spent on RDR, a concept that is going to destroy the indusrty's scale and leave Joe Public seriously uninformed, under-insured and under funded for retirement because they can't or won't pay the fees demanded (which will be high so we can pay the useless parasites), should have been directed to watching the banks antics.

The situation will worsen as the independent sector shrinks and the banks are left to continue fleecing the public.

It might not be QUITE so bad if the FSA, or at least all the people at the top who allowed this catatrophic train wreck to occur as a result of their total mis-prioritisation of their responsibilities, was going genuinely to be scrapped and replaced. But it isn't. The FCA will be the same people doing the same jobs, in the same office, being paid the same salaries and bonuses, under the same management, and all with the same total lack of accountability (as confirmed by the government). Yet somehow or other, incredibly, appallingly, disgustingly, according to Hector Sants, the transition is going to cost (us) a truly staggering £50,000,000!!! HOW, for Christ's sake?

You really couldn't make it up.

Christ has nothing to do with regulation, if you recall he upset the moneylenders stalls in the temple and nixxed them.

Now I do not advocate full revolution, but every IFA needs to write to the chancellor and ask him to step in where Andrew Tyrie and the TSC could not.

Stop RDR in it tracks, have the potentially disasterous consequences re - asessed and let us see some common sense (or should I say "sense" check ) applied to the future of Financial Services.

Under resourced my eye !

Perhaps you should read the report... or at least the Chairman's summary. There is clear explanation about why no one has been brought to book. There is also hope for advisers:

"The reasonableness of judgements, moreover, has to be assessed within the context of the information available at the time, and not with the benefit of hindsight".

Interestingly too, the legal advice that the regulator has received in relation to due diligence..."...case for inadequate due diligence would have minimal chances of success, given that there are no codes or standards against which to judge whether due diligence is adequate, and given that the limited due diligence which RBS conducted was typical of contested takeovers."

If this is indeed the position of the regulator, then provided that sensible systems and controls have been implemented, observation of current themes/trends and I suspect that this statement alone might help many firms currently facing sanctions.

I have avery strong feeling that RDR is going to deliver to the general public

fewer and far less approachable advisers with the added fear that they will be far more commercially minded, but for the Regulator to cite the initiative as the reason for their failure with Banks in general seems barely credible.

The FSA has for many years now demonstrated a total lack of understanding when looking at either end of the industry and as a result burdened us with inappropriate regulation that does not deliver the promised high-level objectives stated in its 'sale' to equally ill-informed politicians.

I firmly believe that if advisers were routinely explaining their status via the IDD and correctly disclosing commissions using appropriate illustrations, much of what RDR seeks to achieve would be secured already. That would be simply by enforcing requirements that have been inforce now for over 15 years. However, like so many other fields, instead of policing the laws we have already, 'change' is seen to be more effective when it comes with a raft of new laws that are both unnecessary and unlikely to be enforced any more assiduously.

What the RBS debacle demonstrates all too well is that many people within the FSA have been promoted way beyond their level of knowledge and competence, something for which an advisory firm would face justifiable censure. RDR will, in time I fear prove a similar waste of focus and yet again point to the only sensible course of action, which is to scrap the whole lot and start again with a Regulator that genuinely understand what it is dealing with and can deliver against its objectives.

I've been asked to write a 3000 page article entitled "What does good regulation look like?".

Now I'm a little cynical and did consider just saying "Not like this" but more seriously what would the answer be?

Yes FSA, every IFA knows you have been missing the elephant in the room ever since RDR was first mentioned, and if you yourselves have only just realised this, then it just says it all.

However, this admission contradicts the comments made by the Teflon-shouldered Hector Pants, (or ‘Nero’ as many IFAs know him) a couple of weeks ago where he refused to accept the blame for anything untoward that had happened on his ‘watch’.

Crikey, the air-headed buffoon Mark Hoban must be feeling very uncomfortable now, and quite foolish (perhaps not though…bloody arrogant twit) now the cracks are beginning to show for Nero and the FSA overall. Perhaps all his ar*e-licking may not come to anything after all.

It is easier to say what it shpould not like. Basle 1 and 2 for starters.

But if you are takling domestic retail regulation then the answer is to have product regulation see Germany.

@Dominic Thomas

Probably clutching at straws there if you imagine weasel worded excuses for failing to take action against RBS executives and directors could be extended to give any IFA a "Get of Jail Free Card."

To act against RBS would mean that the FSA's own CEO and executives may be subject to scrutiny - far better to simply blame lack of resources and bad luck.

I agree that it does seem incongruous that IFA's are the only sector that is blessed with the ability to make recommendations that can be judged with the benefit of hindsight that for some reason could not be expected of Sants and his banking pals.

What is also noticeable is that no where is there any mention of anybody from the FSA ascribing their name to this.

Every other communique from the FSA palace always has a non-job quoted as saying Blah, blah, blah - notice that no one wants their name acsribed to this least of all Dear Old Hector Pants who usually never missses an opportunity to point the rigid digit at some other poor soul.

Come on Hector - let's hear from you

Poor old David Cameron, he goes to all this trouble to protect the British Financial Services industry from Europe and behind his back Hector is destroying it just to feather his own nest!

This industry is very sick, I will be glad to be out of it!

@SW - the report appendix provides a full list of FSA actions and who was in charge. They aren't hiding.

To Sam Lever ~ Your suggestion re: proper commission disclosure chimes with what I have already suggested, namely that if commission was made subject to specific client agreement then, provided the contract is 100% clean on entry and exit, would there really be any need for what the FSA proposes? Does the FSA have the slightest idea of just what proportion of the IFA community doesn't already operate a CAC model? I somehow doubt it.

Legacy contracts with enhanced allocation and tapered exit charges in their early years are a different matter but, when all else is said and done, is it remotely reasonable for the FSA to insist on life offices rejigging their entire systems, at vast expense, to accord with Adviser Charging in respect of all future top-ups, not least as Investment Bonds are declining in popularity and there probably aren't going to be that many top-ups to them anyway?

If the FSA is concerned about excessive commissions on top-ups to old contracts, why not simply stipulate rebates to investors, directly from the provider, over and above whatever may have been agreed between them and their adviser? Wouldn't that be so much simpler and more cost-effective? Of course it would.

Surely, one of the factors that the FSA ought to take into account when considering new regulatory edicts is proportionaily, as in will the benefits justify the cost? Of course, which is why the FSA is supposed to undertake Cost:Benefit Analyses before imposing new rules, not to mention consulting on them. But, as we see so often, the inconvenience of any sort of Cost:Benefit Analysis is frequently swept under the carpet (Cost, as we know, being something about which the FSA clearly doesn't give a toss), whilst the FSA's consultation exercises are nothing but hollow, token shams, with all feedback submitted kept well locked away from prying eyes instead of being published for all to see and to debate. The FSA, by its own admission, become so carried away with steamrollering through the RDR and all its provisions, that simple procedural requirements such as Cost:Benefit Analyses and Consultations have just been conveniently ignored.

So much for the FSA's claim on its website to being "an open and transparent regulator". Open and transparent, my eye. The FSA basically does whatever it wants and to hell with what anyone else may think. If it's not written specifically in statute that the FSA can't do something, then as far as the FSA is concerned, it can, a prime example being denying IFA's the legal protection of the longstop ~ because the FSMA 2000 doesn't say specifically that IFA's should have such protection. By this line of reasoning, the FSA could string up errant IFA's on crosses outside their offices and douse them in petrol. Well, the FSA would say, there's nothing to say we can't so, as far as we're concerned, we can. Nightmare.

@ Dominic Thomas

"and I suspect that this statement alone might help many firms currently facing sanctions."

Sorry but when did IFAs become entitled to be judged against the same criteria as the regulator? These are the same people who are trying to have the common law of causation removed solely in respect of IFAs.

For those rugby followers, has anyone ever seen Rob Andrew and hector Nero Pants in the same room together? They seem to have an indentical outlook on accepting responsibility, and both are teflon coated.

@ Compliance Officer : 3,000 page article?? I'm thinking good regulation shouldn't need 3,000 pages to describe it ... and I'm assuming it was a Freudian slip ;-)

Sorry @Gillian - I did mean 3,000 words; I must have been thinking of an FSA consultation paper.

IFA's and multi tied to go on strike !!..or to put another way...we all somehow unify and refuse to pay the fsa (protection money) fees in entirety.This includes all life offices and wrap providers etc.(notice I don't include the fsa puppet masters ie the banks)

I've just about had enough of these "jobs for the boys" idiots ripping us off

They couldn't fine us all, well not all at the same time.

Maybe a tad revolutionary and I know i'm gonna get some clever dick comments about how rdr ready and wonderful we are (sitting on our fat arses in our ivory towers) managing our 20 multi millionaires....but you just never know. Remember that Polish fella "Lek" and the old soviet union ?...just a thought

While I agree with you Reality bites, I'm afraid the FSA would just pick us off one at time. Hectors pants has no sense of morality or honour. I'm afraid to say it but we are finished!

@ Compliance Officer

Good regulation does not need Compliance Officers (sorry!)

@Nick

Their but for the grace of god......

You know. Nick, in some circumstances I wouldn't necessarily disagree but any form of regulation is always going to need a certain amount of bureaucracy so if you are happy to do it yourself without impacting on the service you can provide to your clients then great - but i doubt it!

I've no idea what your experience of compliance officers is but after 20 years of being one in a variety of sectors I like to think that I have seen enough to be able to constructive and helpful to the business.

Lord Turner says that there's no legislation available to pursue those who brought down banks or failed to supervise them. In the good old days when politicians (and others) made serious mistakes, they just fell on their swords. What was wrong with that? Why is Hector Sants to be punished by a promotion to Deputy Governor of the Bank of England? Surely Bank of Toytown would be a better fit.

Contributers please do not lose sight of the Northern Rock debacle or the fact that RBS was not the only bank caught out buying rubbish and gambling our money away. None of them were properly regulated because the FSA was and it's reincarnation is, stuffed full of bank placemen. They have been put in place to control the system for the banks.

Take a look at a programme which was on BBC2 last Wednesday night titled "Storyville." It explains and details the way that the banks and Wall Street gradually infiltrated then took over the US government during the time of Bill Clinton, George Bush and now Barack Obama. It is no wonder people over there are beginning to demonstrate against it. Things in our country are not a great deal different. David Cameron is prepared to sacrifice our influence in Europe so long as we do not upset his cronies in the city. He will not even contemplate any form of transaction taxes on short term speculative transactions or derivatives which would tilt our economy more towards long term investment in manufacturing and exporting instead of what has become pure gambling and was the root cause of our present demise.

An earlier contributer commented that the FSA have and continue to recruit inexperienced graduates with degrees in unrelated subjects because most of their top people only have degrees in modern languages, philosophy, psychology, English literature, theology etc. Is it any wonder they are not up to their jobs?

Another question that springs to mind is whether or not the FSA's obsessive focus on TCF and the RDR was applied equally to the banks as to the IFA sector. Issues such as Barclays' mass mis-selling of those two Aviva funds and the epidemic of MPPI mis-selling (on both of which the FSA was very tardy in taking action), suggest not.

Was it, in reality, as I somewhat strongly suspect, a matter of excessive focus on the wrong SECTOR, as opposed to excessive focus on the wrong issues?

As Bob Arum (U.S. Boxing Veteran) said of Amir Khan's team for letting him fight in Washington with a home-town referee - "These people need adult supervision!"

If, as Lord Turner would have us believe, there's no legislation available to pursue those who brought down the banks or failed to supervise them, then if he's genuinely concerned about protecting consumer interests (and there can hardly be a bigger issue of consumer protection than the failure of banks), then surely he and his cohorts at the FSA should be pressing for such legislation to be included in the latest revision to the FSMA.

The trouble is, though, that the FSA can't really press for senior bank personnel to be made personally responsible without at the same time pressing for senior regulatory personnel to be made equally responsible. And so, for that reason, he probably just won't bother, despite Hector Sants having claimed before the TSC back in March that he's such a big supporter of accountability. If that claim is true, then why isn't he making appropriate representations to the legislators on this very subject? Answers on a postcard please.

Hmmmmm, so, it was a lack of qualified personal within the FSA that contributed towards this disaster!

So, what qualifications do these high ranging FSA officials and staffs hold, as they have refused to make them public knowledge? Now call me Frank, Bob or Susan if you like, surely the argument of the RDR applies to the FSA.

So, I am sure that they have reviewed their compliance, T&C and set themselves a three year window in which to have all staff and officials qualified to at least NVQ4 in the areas they work. As well as this, all senior officials will take at least an NVQ6 qualification with the three years in the area they over see. This is based on their own recommendations to the advisers.

NO, why is that?

It would detract the staff from doing the job at a time when they are very busy.

You don’t have time.

There is no need as they only look after certain areas and they can receive training for this.

You don’t need to have a qualification to manage and oversee the process.

It would not have changed the outcome.

No, those are the arguments we but forward and you told us we were wrong and you knew best!

Pot, Kettle, Black.

What’s good for the goose is good for the gander.

When in Rome ?

People in class house ?

You receive what you ?

Once again the FSA demonstrating it is regulating the industry upside down. Regulate the institutions and the product providers and the regulation will trickle down to the adviser sector. If the FSA had regulated the banks and investment houses then the FOS would not be making ridiculous decisions against advisers as to whether Mr or Mrs Client had been placed in the wrong investment fund in order for them to be compensated for poor investment returns. As for the management at RBS and other similar institutions when are they going to be prosecuted for corporate negligence?

I awoke this morning and suddenly realised what's missing from everything the FSA has said about its report into the near-collapse of RBS. I've not read the report itself (too busy serving my clients and studying), though I'd be very surprised if it's in there because, if it were, it would surely have been reported in letters writ large.

It's a very simple thing. Just one word in fact. Only two syllables. So many people deserve to hear the FSA say it but the FSA, it seems, just cannot bring itself to do so. Not Adair Turner, not Hector Sants, not Sheila Nicoll. Not any of them, as they line themselves up for this year's bonus and next year's pay rise.

To paraphrase what Winston Churchill said in the wake of the Battle of Britain: Never, in the history of regulation (or indeed in the history of financial services), has so much been owed to so many by so few as a result of their dereliction of duty.

To the public, to IFA's, to all the people who've lost their jobs (not least in the financial services sector) or who are facing an uncertain future and/or reduced living standards, to all the young people who can't secure their first job or buy a home of their own, to everyone else affected negatively by what's happened as a result of the FSA having refused to listen to what the industry and others have for years been trying to tell it and having disastrously mis-prioritised the application of its totally untrammelled regulatory firepower.

It's just one little word, yet such a crucially important one. But I haven't seen it anywhere. Can you guess what it is? Scroll down.....

Sorry.

Julian, not only is it not there but you won't find that word anywhere in any press release, feedback statement, policy confirmation or anywhere on the website.

Not only do they not say sorry but, more pertinently, they are not sorry.

After all, if your decisions, determinations and processes run unchallenged and are unchallengable and you can never be made personally accountable for your actions or inactionsthen there is no need to even consider an apology.

I have first-hand experience of being harrassed and vilified by our good regulator for no reason whatsoever and they never apologised. When I wrote asking for an investigation and an apology I received a letter promising a "substantive response". Seven years later I still await this reply.