To correct errors in my previous post: "policies, templates, and controls" should read "policies, processes, systems and controls", and "is more conductive" should read "is more conducive".

The goalposts haven't shifted, and no-one is moving the hole to the side of the green just to mess with the twilight burglars. The phrasing of the opening sentence ("having policies, templates, and controls in place is no longer enough") might suggest otherwise, but the wording is unfortunate. Having policies, templates, and controls in place was NEVER enough - it is a necessary, but not sufficient, condition of "playing by the rules" since 15th March 2021. A new player to golf might completely miss the ball on their tee shot - a swing and a miss. The wise coach/mentor/official knows that adding a stroke to the scorecard at this early stage of the player's development could have a deleterious effect. A reminder of the rule and the sanction - not applied at this early stage of development - is more conductive to continued participation. Focus on learning to hit the ball in the first instance, and move on to applying the penalty once the basics are firmly bedded in. No rule change, just a firmer application of the existing rules as the golfer matures.

Instead of goal posts let's talk about holes. I was at a working bee at the golf club. We were doing some maintenance near one of the greens, and there was a club twilight series coming up. Just for a laugh the greenkeeper moved the hole to a particularly difficult spot, down pitch, near the edge, which rolled over a steep angle to a downhill run away from the green. Miss the hole and your off - you'd need to chip back up. Oh Steve. What I'm talking about is not "prevalence-induced", it's not a blue dot, and it's not the invention of a new risk. It's the FMA effect. I'm calling a molehill a molehill. As the supervision moves into a "mature phase" they are redefining what our safe harbour is. Until now we moved to understand what the goals were - get this qual, do these things, and you'll be fine. Now they are looking at other things, "raising standards" or changing the definition of the already-vague "good outcomes". They literally picked up the goal posts and shifted them. Moving that hole didn't change the stroke index. The rules of the game didn't change. It affected every player equally, and we all had the same goal to aim for. But moving it sure made things harder for everyone.

Advisers can probably be forgiven for believing the ‘goalposts’ keep shifting, because they probably are, and there is a likely explanation for that, it’s called “prevalence-induced concept change”, a term coined by Harvard researcher Daniel Gilbert. Also called the ‘Blue Dot Effect’, this is a psychological tendency for humans to invent new risks, or expand existing minor issues into major ones, in the absence or reduction in the incidence of real threats. As real threats diminish, our brains tend to look for and redefine what threats are, making us see problems where there might be none, essentially making ‘mountains out of molehills’. Evolution has hard-wired us to expect threats regardless of whether there are any. As Daniel Gilbert says “Solving problems causes us to expand our definitions of them. When problems become rare, we count more things as problems”.

Advisers outline their latest expectations for FMA Advice firms are raising the bar for their expectations of the FMA, warning that having vague requirements and constantly increasing expectations is no longer going to be tolerated. Adviser told FMA’s Michael Hewes that Advisers expect the FMA to demonstrate their systems are working, not by having systems that work, but by having records that show they do. So far their records is one adviser was found in a monitoring visit that lost their registration. Hundreds of monitoring visits, lost of angst and censures and chest puffing but the record currently stands at one. For advisers, the message from the FMA is not to create more paperwork. It’s to make sure a client file clearly has the paperwork that shows why advice was given and how conflicts were managed, and whether the client understood the recommendation. Advisers make the paperwork to meet these requirements, and now we’re being criticised for creating the extra paperwork. We have noticed and adage when they go though and engage with entites: don’t talk to us about our management issues, we want to talk about yours. Mr Hewes says the FMA recognises the significant work advice firms have done since the new regime was introduced, including rebuilding advice processes, policies and professional standards. Advice firms say they appreciate the recognition of the significant time and cost and effort that went into all that, which means that the shifting of goalposts to ever increasing requirements shows the FMA has no idea how significant that work was. Advisers say that good advice is what we have always provided and that we know it starts with the client, and always did. Regulation did not change that, it just added a ton of paperwork and record keeping and costs that made it harder to spend quality time with those same clients. In fact advice firms strongly resent the insinuation that our advice process starts with a product before a client. FMA says it believes in advice. Advisers believed in advice before the FMA existed.