Well, certainly in the view of the Association they ought to be. And indeed usually that is the pattern. So if you see the situation which obtains here in the UK at the moment in relation to law, to financial services, to utilities and to property professionals, the ombudsmen are entirely separate from the regulatory body, whether that's a statutory regulator or a self-regulator.
I think there are perhaps a number of reasons why one would go down this road. There's a concern that otherwise one might confuse sanction for breaking rules, which is a matter for the regulator, with redress for those adversely affected by the actions of the body, which is a matter for the ombudsman.
It's very difficult to handle within the same body both sanction and redress with their differing standards of proof, the effect that it has on mediation in redress issues, if there is potentially a sanction, if somebody confesses that they have done or accepts for the purpose of resolution that they have done something wrong, and indeed entirely different skills are required for the different roles.
So as far as the Association is concerned, they are not enthusiastic about the proposal that has been put forward by the -- on behalf of the industry, that complaints should be handled within the body that also handles the regulation.
The fact that within that model the proposal is that it should be handled by two separate arms goes some way to recognising the points that I have made about the difference in function. But our view would be why not go the whole hog and separate them into an independent body for complaints? The arguments seem to us to be strong to have them separate, but we're not aware of any strong arguments why they need to be packaged together.