• The BSA supports the broad aim of the FCA’s Consumer Investment Strategy for a consumer  investment market in which consumers can invest with confidence, understanding the risks they are taking and the regulatory protections provided.
• We understand the desire to support mass-market consumers who may benefit from investing through enabling simplified advice. As part of the safeguards around this, we support limiting the range of investments under simplified advice, and can see that using framework of existing Stocks & Shares (S&S) ISA regime makes sense, as well as the various other limits and restrictions. However we believe the £10,000 threshold is arbitrary and too low a limit. To date there has been little justification for this level, but it is fundamental to the proposals so it is vital that it is calibrated appropriately.
• It is sensible for all consumers to think about how they will achieve their financial objectives, but it is important that they do this with an understanding of the risks that achieving those objectives might entail for them. We want to make sure that individual consumers’ risk appetites and preferences are sufficiently protected in the core investment advice regime. 
• We suggest some additions to the guidance to ensure that an individual’s risk appetite, medium term savings objectives, and existing ISA subscriptions are given due consideration to help to ensure that consumers do not end up being harmed by making decisions or taking risks if they did not fully comprehend the consequences of these decisions.
• Separately, we highlight a potential impact of the proposal, and which is not included in the Cost Benefit Analysis, on deposit-takers which, other things being equal, will have to raise the funds that are withdrawn to invest in S&S ISAs from other sources. This could have knock-on implications in other markets.

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