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Ever tried reading Finnegans Wake or Moby Dick? How about Les Miserables, or maybe an FSA consultation paper...?
Like each and every FSA paper preceding it, last week's effort on proposals for its regulatory fees and levies for 2010/11 was a tough old read.
If you haven't yet had the pleasure of going through it, we've pulled some of our favourite bits to see if you can make head or tail of them. Please do let us know what you think, or perhaps whether it's "just us".
Otherwise, the campaign for clearer, jargon-free FSA communication documents starts here. Let's begin...
1.43 We propose that inward-passporting authorised payment institutions providing payment services from UK establishments are offered a discount to reflect our limited role as host state.
That one was just a taster. It gets a lot worse.
3.6 We proposed that the straight line recovery policy should be flexible enough to accommodate a targeted recovery of costs within a fee-block, on an exceptions basis, where such exemptions can be justified.
We get the gist of this - we think - but isn't there a simpler way of saying it? Perhaps the next bit will clear it up?
3.6 (cont.) This exceptional moderation can be either side of the straight line recovery and would be achieved by applying a premium or discount to the rates applied to the tariff data for the specific permitted business firms undertake within the fee-block where recovery will be moderated from a straight line.
Thought not. Moving on...
11.17 Firms already authorised under FSMA and allocated to fee-block A1, except for credit unions, that provide payment services by virtue of their part IV permissions will be charged fees based on the MEL tariff data as supplied to calculate fees on in fee-block A1. This basis for tariff data was confirmed in PS09/8.
Next!
13.15 The additional levies for FinCap/CFEB mirror the FSA fees structure and are applied to the tariff-bands that we have introduced for each fee-block following the strategic review, as explained in Chapter 3. We have applied the straight-line recovery model to all fee-blocks, without moderating the line to put a premium on the high impact and systematically important firms. This is because the moderation is intended to take account of our enhanced supervisory costs, which would not affect CFEB.
I haven't seen a paragraph this poorly written since my A Level history paper.
13.15 Firms which make pre-payments of their FSA fees by 30 April because their previous year's FSA fees (excluding the FEES 7 levy) were £50,000 or more, as set out in FEES 4.3.6, will make pre-payments on the same terms of their FEES 7 fees.
Can it get any worse?
17.5 The total costs incurred by us in arranging the authorisation process and preparations for regulating reclaim funds post-authorisation comes to approximately £170,000.
No further questions, your Honour.
There are many more examples, but frankly we're feeling a little sleepy. Maybe you have come across even worse examples in the past. Please do enlighten us.
Anyway, let us know your thoughts and, if we get enough responses, maybe we'll pen a really, really long letter to the FSA to let them know how we feel!
Thanks for reading.
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And if WE said it...
Advisers are castigated by the FSA for using jargon and/or failing to make statements in clearly understandable language. ANd they talk a complete load of twaddle....
Posted by: Rhodri Evans
Clear - Not Misleading
Well the FSA tell us to be clear , not misleading and produce our adverts in clear english - to our customers. We are their custoners so maybe they should do the same for us. Ever tried asking the FSA to calrify a 2.2.4.56.7.5.4 paragraph? They will tell you they cant explain it and that it is as you interpret it. How about you sort yourselves out FSA then started trying to rule the world of finance. More fees to follow for their PLain English teachers...£££££ need recruitment help?
Posted by: Anon
FSA versus English language
The FSA are obviously out to cause as much confusion as possible therefore nobody will realise that they don't actually know what they doing (see bank fiasco(s)). While we all try to unravel the misinformation cleverly constructed by FSA GHQ they can set about their real work of distroying the small IFA sector and allow the banks to finish the job of stitching up the poor longsuffering U.K. taxpayer.
Posted by: Captain IFA
the usual rubbish
The cretins have to justify their miserable existance somehow. What better way than to add more rubbish to the litany of incompetence? They've had 23 years (including FIMBRA and PIA)to drag the industry to the present depths, and it sinks further. If the idiots presented regulation in simple straightforward terms it would reduce costs, but they aren't interested in that. Obfuscation: "To make so confused or opaque as to be difficult to perceive or understand." It is one of the trademarks of rogues. It was also a favourite method of Sir Humphrey Appleby of obscuring the true meaning of legislation. Sack the morons.
Posted by: Dave Hedge
Canary Speak
It is by no means just you. I do try to engage and keep up by the version of English used at Canary Wharf is not one with which I am familiar. I guess it must be Canary Speak. Bad as your examples are they omit the awful habit of taking in mnemonics. One needs a separate glossary to have when trying to decipher their missives. COBS, ICOBS, MiFID, CRD, Arrow ll – so many they would fill a page on their own. If this is an initiative of yours to try and get Canary Speak banned and plain English substituted – all power to you. I’m not optimistic, but if you only partially succeed you deserve a Nobel Prize.
Posted by: Harry Katz
Pot & Kettle
We have been castigated by the FSA for trying to explain to clients about both their righst and responsibilities (i.e. trying to be fair to our clients) and specifically asked the FSA to point to anything they felt in theri terms did not meet the Unfair Contract terms Legislation (our previous terms had been looked at our request by trading standards and deemed acceptable), all we got back from the FSA was links to the handbook telling us what we could not do (in their opinion) which actually contradicts the law. The good old FSA right rules, which are a contract not open for negotiation (in their view) and use as uninteligable language as possible! I am currently reading Kin by Rudyard Kipling and despie the language being used being very dated, it makes more sense than the FSA's manual. Isn't it about time they started treating advisers fairly?
Posted by: Phil Castle
FSA - Clear as mud
No wonder a great many IFA's don't read consultation papers Say no more
Posted by: Common Sense IFA
waste of space
FSA always have been. interested mainly in career paths and benefits hence offices in Canary Wharf not Hartlepool where they need the jobs. love the way they, when asked for guidance or a pre approved template, respond " we do not work like that; send it in and we tell you if it is ok". could have had some compo fund with all the money poured down the sewers on those dossers.
Posted by: david levin
Dictionary
I told them at at Treating Customers Fairly meting in Bolton 2 years that they were guilty of creating a new language of jargon and that we needed a dictionary to interpret their crap And we actually pay these creeps What a load of rubbish
Posted by: Roger Rouse
English as she is spoke
All I really need to know is how much are they going to demand from me this year. How or why they reach that figure is irrelevant as it cannot be challenged. Mnemonics have, also, creeped in to GABRIEL, another mystery to most logically thinking people. Question - How many CF30s are employed in your firm. Apparently, and there was no "Help" button to this question, it means how many or our employees talk to customers.
Posted by: Mike Hillier
New Address for FSA
I suspect Dickens would have loved to have lived in the age of the FSA. Bleak House instead of Canary Wharf anyone?
Posted by: Liz Topalian
Toilet to Toilet
Is it not true that the FSA payscales exceed the norm,in order to atract the best nee greatest brains to the regulation industry and its just cause, forcing common members to avoid profitablity in order too achieve artifical intelligence, via the rotating examination, turning an equivalent double glazing salesperson into a professional, even providing such persons with the standing of Bank Managers in Society. Therefore do not belittle such worthy cause. Is it not equally true that Einstein was a genius the the normal/common podiatry failed , yes failed to understand for generations. Therefore do not cry fail, just put the Rule Book in the Toilet where it belongs, to be found and reviled in 50 years, if it has not composed in aid of globle warming. As the Good Book states from Toilet to Toilet.
Posted by: M J Winfield
Plain English from the FSA campaign - yes please
AT LAST agreement that most of the words that come out of the FSA are incomprehensible. Anyone else out there struggling to make head or tails out of the FEE DATA Request form - If you can't understand the question, how can you give the correct answer. I absolutely concur with all the comments and the sooner we start a real campaign to get them to write in english the better. WHO WRITES that garbage anyway?
Posted by: Alison Prior
Send for Stanley!
Isn't it a pity that professor Stanley Unwin has passed on. A DVD of him reading this latest gem from the FSA would have been hilarious and would have sold thousands - to non-ifa's!
Posted by: David Lindsey
CF30s and a nomination
Mike, re your comment about the number of CF30S, I was confused too. The spaces for inserting the "whole number" of employees who talk to customers in the firm is sufficient for up to 999,999,999,999 such persons. The box for "amount in words" is not proportionately large - clearly an error by the form designer. It may well have been done already, both this year and in previous years, but I have nominated the Regulatory Fees and Levies section for the Plain English Awards 2010.
Posted by: Robin Bennett
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Ever tried reading Finnegan's Wake (sic)?
Finnegans Wake Is a spelling mistake And as for the plot Well there's not a lot Note to subeditor - there's no apostrophe in Finnegans as to have one would destroy the end/begin pun (finnegan begin again).
Posted by: Martyn Page