Proposition
The government is committed to improving the financial capability of consumers. In 2007 the Treasury allocated £110 million to the Financial Services Authority to develop pilot approaches in financial capability. Separately, the Thoresen Review in 2008 delivered a report on how generic financial advice should be delivered.

We agree with the FSA that "a sound and accessible basic financial education for less sophisticated consumers is essential if the consumer is to take more personal responsibility ". But UKSA believes that conflicting objectives, political compromise and accomodation of commercial interests is making a mountain out of a small hill.

The word 'consumer' is a giveaway. It is consistently used by both the FSA and Treasury in discussion and policy documents - and in legislation - and chimes with their view of individuals as consumers of the products of the financial services industry instead of as people trying to manage their money and their futures. This bias infects their view of financial education.

Basic financial education is not difficult provided it is rooted in sound principles. This website is offered as a practical demonstration of that assertion and a theoretical framework to support the delivery of tailored modules to different target groups.

Financial advice
UKSA also wishes to create a vibrant commercial advice market. The availability of suitable advice is critical:-

• It is a necessary condition for developing a savings environment of the type envisaged by government.
• It is a necessary safeguard in any market, like the market for financial products, in which sellers are more knowledgeable than buyers.

The market for advice has been stunted by regulations that allow the sophisticated selling operations of Independent Financial Advisers to be disguised as advice. Consumers will not pay for what they believe they are already getting for nothing. Breaking this model is a necessary condition for creating an educated consumer.

Governance
Control of the syllabus of any new education service should not lie in the hands of the financial services industry. It is an unfortunate fact that the industry makes more money out of ignorant consumers than it does out of educated consumers. The more enlightened parts of the industry will recognise its obligations to society over and above the drive to make money. The less enlightened ones will not.

It is symptomatic that the FSA's own attempt at basic education, MoneyMadeClear, does not explain the importance of product costs, the distortion of sound decision-making by individual behavioural biases or the effect of commission on the nature of advice from IFAs - all indispensible concepts for long term savers. But not, of course, conducive to selling more product.

The more that government seeks market-driven solutions to social problems, the more important it is that the foxes are not allowed to design the hen-coop.

Regulation
We also believe that a sound and freely available intellectual framework for investment advice offers opportunities for both simplifying regulation and making it more effective. For example, it could be made a condition of all product selling by IFAs that consumers are made aware of the appropriate generic advice tailored to the particular product being sold (and given access to it online in IFAs' offices?). That would allow a more flexible response to advisory issues and make much detailed regulation unnecessary.

As an example of the low-hanging fruit available: various surveys have shown that 20-40% of all users of IFAs with consumer debts are not advised to repay them in preference to buying a savings product. This mis-selling could be prevented if IFAs were required to direct customers to read a couple of sentences on debt management, from a source in which they have confidence, before proceeding with any product purchase.

Last word
Any compromise on the basic principles will erode the whole structure. Bad advice and bad financial products are like water: any crack in the dam and they'll find a way in.

From an FSA discussion paper: "....... we would rather achieve [effective consumer protection] by tackling the root causes of the problems and removing unnecessary barriers that prevent firms from operating in a way that is both commercially viable and results in the fair treatment of their customers".