Apcims argues that changes imposed by the FSA on existing data security measures may be "expensive, erode client relationships and produce outcomes which are not wanted either by firms, clients or regulators".

Says David Bennett, CEO of Apcims: "If the FSA impose a regime on firms whereby they are required to ask intrusive questions rather than use voice recognition to identify often long standing clients, the FSA risks undermining the foundations of a well functioning industry. Identifications such as a password, birth date and mother's maiden name are inappropriate for the stockbroking industry and will undermine valuable client relationships and trust.

"If the FSA wants best advice and best execution from our sector, it needs to trust our business model which is built on personal relationships, often over several generations. If our members were not giving best advice and best execution they would not retain their client base. We want to say to the FSA 'if it ain't broke, don't fix it'."

Apcims says it will ask the FSA to acknowledge the different business models run by personal investment firms and "avoid telling them how to run their businesses by imposing costly one-size-fits-all approaches".

The trade body is also raising concerns about market fragmentation and the aggregation of post trade data following the implementation MiFID last year.

"We want to know how the FSA intends to tackle the issues of aggregating data coming from the many trading platforms through which investors are now trading," says Bennett. "There is currently no requirement for the information to be aggregated. The result of this is potentially misleading data from information providers not covered by the provisions of the Financial Services and Markets Act."

Apcims says post trade data is a significant revenue stream for the many venues that have sprung up since the implementation of MiFID, but without a consolidated tape for the market as a whole there is no easy or cost-effective way to enable brokers to guarantee best execution for their clients.

The association also argues that the "rigorous implementation of MiFID" in the UK has been "enormously expensive" for brokers and its members find themselves at a competitive disadvantage to European brokers where the local regulator is more relaxed.

"In order to maintain the stockbroking and investment management community in the UK, which manages £400 billion a year, we must ensure that there is a level playing field across Europe," says Bennett. "We will be challenging the FSA to ensure we do not lose business because the UK has been more rigorous than some of its European counter parts in implementing MiFID."