"Care needs to be taken to avoid reading across from banks to insurers and asset managers, whose businesses are substantially different and pose much less risk to overall financial stability."
The FSA doc released yesterday shows that the ABI responded to the consultation. But which hat did they wear when writing it - the one representing insurers as companies that might get caught by the FSA code, or the one representing insurers as investors who need to have confidence in the remuneration policies in place at BOFIs? It's not that easy to do both.
The quote suggests that the ABI is thinking about the impact of the code on insurers as insurers. As I blogged yesterday, it doesn't look like any individual asset managers responded to the FSA consultation, but a number of the parent insurers that sit behind them did (Aegon, Standard Life etc). Again it seems that the interests of the insurer as insurer, rather than as institutional investor, get priority. And there's going to be a similar conflict in terms of responses to the Walker Review.
Of course this is all entirely reasonable from one perspective. I obviously wouldn't suggest that the ABI shouldn't lobby on behalf of its members as insurers (and listed companies). But it does point up the conflicts of interest that potentially inhibit more robust shareholder engagement. And to hammer the point home - the ISC, as a collective of trade bodies, has this problem multiplied by four.