APCIMS has responded to FSA's consultation on professionalism in the context of the Retail Distribution Review. It has serious concerns about many aspects of RDR proposals that will mean existing advisers need to top up their Continuing Professional Development where the scope of the top-up is irrelevant to the services they provide. However, it notes some positive developments in CP10/14. The response draws on several areas of the proposals, including comment on the accredited bodies, as well as answering FSA's specific questions.