Put yourself in the position of one of the Treasury mandarins tasked with reviewing ABTA’s regulation of travel insurance. What would you see?

Apart from the submissions, including ABTA’s 37-page defence of its exemption from the rules of the Financial Services Authority, you might also notice that Thomas Cook has decided to withdraw from the ABTA scheme.

And this week Advantage and Worldchoice have announced they are offering members the opportunity to become FSA-appointed representatives through its joint venture with insurance provider Covermore.

Oh, and if you watched BBC Watchdog recently, or read Which? you would have wondered how effective agents are at selling travel insurance.

All in all, it’s a mess. For ABTA, this does not look good. These are significant moves by Thomas Cook and Advantage that serve to undermine the value of ABTA’s insurance.

While the Treasury decides the fate of the ABTA scheme, agents will be looking at what model best serves them and their clients. For those looking to expand their financial products, the only way will be FSA regulation.

ABTA argues that FSA regulation is too costly for members and that its current regime – including training and exams for members’ employees selling insurance – serves members well.

ABTA is right to defend members’ interests but the insurance landscape is changing and travel providers are looking to sell financial products. For these providers, ABTA’s scheme is no longer relevant.

Agents selling ABTA insurance find themselves between a rock and a hard place. Consumers expect to be sold the right cover but they also expect the best deal. Without that, they go online and get cheaper deals.

But as consumer groups fail to point out, no one is asking about medical history online and no one is checking whether the cover is what the consumer requires.

On the whole, agents are doing a good job at selling cover. The rules governing the sale of it need to be clarified and made simpler so clients are clear about what they are buying.