The Association of Professional Financial Advisers (APFA) has submitted its response to the FCA’s Discussion Paper DP15/3 on MiFID II.

In the response APFA calls for the FCA not to gold plate the implementation of MiFID II’s telephone recording requirements. It says the Directive’s aims are to counter market abuse and provide a record for consumers. For equivalent measures for advice, market abuse is irrelevant and the suitability report provides more than adequate records of advisers’ recommendations.

Chris Hannant, director general of APFA, said: “The FCA has to make a choice. It can either gold plate the Directive or it can pursue a common sense approach to help firms at no risk to consumers.”

MiFID II also includes a new standard of “independent” advice which requires firms to assess a “sufficient range” of products as opposed to the FCA’s current “comprehensive and fair analysis.”

Hannant added: “There should only be one standard of independence. We support MiFID II’s standard as it better reflects the guidance the FCA has issued and the standard it seems to expect.”