To be fair, the-then draft Financial Markets Conduct (FMC) legislation did include some DIMS reforms but Ross pushed the issue from the regulatory margins to centre-frame.
Ever since, the Financial Markets Authority and industry have been pondering DIMS questions: What is a DIMS? Are there different kinds of DIMS? Do DIMS come in different sizes? Who can deal in DIMS?
After an interminable series of consultations, the answers arrived in a hotchpotch of regulations covered under two pieces of legislation: the FMC, and; the Financial Advisers Act.
There are 'class DIMS' and 'personalised DIMS' and 'contingency DIMS', gradations of small DIMS (small, medium and large small DIMS) and so on.
The latest FMA DIMS FAQs does its best to untangle the mess of instructions. Be warned, however, the FAQs are intended as industry guidance only and may cause drowsiness.
The FMA document includes some helpful scenario-testing to identify DIMS liabilities, such as: "A research provider 'Research Ltd' produces model portfolios that it provides to an AFA.
The AFA considers her client's personal situation and advises that they invest in a particular model portfolio.
"She also advises her client to use the services of a wrap provider 'Wrap Ltd' which provides an automated service so that the client's portfolio is changed every time there is a change to Research Ltd's published portfolio."
I'll leave readers to puzzle out DIMS implications here.
But as far as Sovereign is concerned, the upshot of the new regulations would have left it responsible for the DIMS decisions of the mainly insurance advisers who have been using its 'Select Wealth Management' service.
Select is definitely a DIMS - it offers, quite expensive, access to a range of underlying funds, or model portfolios (a pre-set mix of different funds) chosen by low-key investment advisory firm JMIS.
Sovereign appeared anxious to unload Select before the May 31 DIMS decision deadline, and JMIS was the natural buyer.
In a note sent to clients last week, JMIS said Select "is a great complement to our existing investment services".
JMIS has yet to be issued a DIMS licence but it's probably in the mail: as should be a thank you note to David Ross.