The Code Working Group is to be congratulated for the work that they have done so far. The proposals in the consultation document are a significant achievement, in laying a new foundation for conduct for financial advice providers and financial advisers.
In particular, some structural decisions that, perhaps appear straightforward now, would not have been clear to the group when commencing their work: such as the separation of requirements on the business providing the services, and the individual providing the advice. The development of the themes from the legislation, of ethical behaviour, conduct and client care, general competence, knowledge, and skill, and particular competence is also strong. The lens of a 'good advice outcome' also appears to be a reasonable test, as defined, for the successful operation of the standards.
There are definitely problems, and they are to be expected. This is, after all, a consultation document. The working group has a particular skew - self-employed advisers make up a substantial part of the marketplace (perhaps accounting for half of all advice given) and yet not room was found on the committee for an adviser of that type, so it must now take into account wider views.
The areas of particular concern to me, and those interested in the provision of advice for insurance, may be concerned about the requirement for a Bachelor's degree qualification (or higher) and a level five certificate for the provision of an insurance plan (see pages 11 and especially 16 of the consultation document, see the blog post below for the link). That captures a substantial proportion of insurance advice as given now. The discussion of recognition of prior learning / experience needs to be a lot more detailed. Another area of concern, to those interested in the use of technology in advice-giving, will be the aspects of the draft make that appear to make that difficult.
But there will be plenty of time to engage in the 'now fix this' part of the engagement. I reiterate my congratulations to Angus Dale-Jones and all the members of the Code Working Group on the document we have.