APCIMS has responded to FSA's consultation on competence and ethics. It says it cannot understand the need for the paper. It says it has repeatedly asked FSA for feedback on the sector and FSA has never expressed any concern about competency. It also finds no evidence for FSA's assertion that very few individuals are now carrying out the same roles as they were when the original FSMA provisions took effect. It is concerned at the impact FSA's proposals will have on many of its members and the source of FSA's information. However, it agrees in principle with some of FSA's suggestions, such as the proposal to create a separate activity for dealing in securities or derivatives.