Recent M&A activity, what is driving it and what it means
First FSLAA impacts – we believe current estimates overstate the number of advisers in the new regime. Estimates of the number of FAs in the new regime are based on application data by FAPs.
As each transitional license application was made the FAP was required to estimate the number of FAs it intends to employ. It has to be said, fairly enough that this is the best formal estimate we have.
I would use the sum of these estimates as well, for a first attempt at the expected number of advisers in the new regime.
However, compliance advisers report that when faced with the question, if a FAP was unsure of the number, they were advised to enter a higher figure. For example – if you previously had a dozen RFAs contracted to the business, and you were unsure if you would bring all of them across you probably still put that number down as 12. In practice we think the requirement to have all FAs connected to FAPs by July 15 will probably see lower numbers reported as more leave.
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