Two months ago, it looked like it was the brokers' turn to be the latest whipping boys in the row over high insurance charges.

A preliminary Competition Authority report into the non-life sector stated that they had been taking a growing share of the money spent on policies. In 2002, brokers' commissions came to €134 million of the €1.6 billion spent on insurance in the State during that year.

Dr John Fingleton, the authority's chairman, said at a press conference that reform of the broker market alone could cut "tens of millions" of euro from the national insurance bill.

Insurance companies presumably sighed with relief, as they - along with lawyers - had been taking most of the flack for the rapidly rising insurance costs.

But Irish Brokers Association (IBA) president Mr David Cowman, of Coyle Hamilton, says that, from the intermediaries' point of view, they appeared to be getting it from all sides around that time.

The Irish Financial Services Regulatory Authority (IFSRA) was continuing to scrutinise their business; banks and building societies were moving on to their territory; and there was yet more regulation on the way from Brussels. Then the Competition Authority fired its salvo.

However, Mr Cowman is not interested in criticising any of these groups. "The Competition Authority actually asked some very good questions, and it has a perfect right to ask them," he says.

The IBA is going to answer the authority's questions today with a submission that it has put together over the past two months - a direct response to the issues raised in what Mr Cowman stresses was the authority's "preliminary" report.

At its heart is the argument that brokers encourage competition.

"The Competition Authority itself, in its initial report, acknowledged this. It said brokers encourage competition, they reduce costs, they bring lower prices to the attention of the customer," he says.

"We think there's more to be said. Not only do we search the whole local market for the clients, we also search the overseas markets and the kind of markets that otherwise wouldn't be available to the clients.

"It's important to realise that the Irish market is shrinking, there are less and less insurers, and they have more and more power. That's not a good thing for the customers, and it's the brokers who are out there trying to supplement capacity."

But the concerns of the Competition Authority were as much focused on competition between the brokers. Its report states that, while the cost of liability insurance rose 94 per cent from 2000 to the end of 2002, brokers' commissions increased by 126 per cent. In the motor market, commissions increased by 51 per cent, while costs rose 21 per cent.

The authority's concerns were not only focused on brokers. Dr Fingleton argued at the time that there was no incentive for insurance companies to cut commissions, which are based on policy costs. He pointed out that if one was to do this, it would automatically become less attractive for brokers, and lose their business.

Mr Cowman rejects outright the argument that brokers go with the highest offer in order to get the best commission.

"The first thing is that any broker who did that would lose his livelihood, the clients would walk. Apart from that, it's a regulatory requirement. If IFSRA came in and did an audit and found that the broker was routinely giving higher quotes to the client, they wouldn't pass the audit. It's a regulatory requirement that you put the client's interest first. IFSRA takes this seriously.

"We had independent research done to establish if brokers offer clients the lowest available price at renewal," he says. "The research is there and the stats are there in the report for the Competition Authority, and they show that in the vast majority of cases, almost 90 per cent, the brokers were placing clients with the lowest available quote.

"In cases where they didn't, it was for good reasons that were in the best interests of the client, and the clients knew about it."

In some cases, clients opted for higher quotes because these were given by insurers with which they were already dealing, or because lower quotes did not offer the same cover or sought greater excess payments.

So what are brokers charging? Mr Cowman says the commission rates are well-known. The standard motor rate is 5 per cent, employers' liability is 6 per cent and public liability is 10 per cent.

The issue of a standard commission is a tricky one. On one hand, it looks as if there is little competition from broker to broker. However, Mr Cowman argues that if one insurance company was offering 10 per cent commission and another was offering 12 per cent, there would be a fear that all the business would go to the one offering the highest commission. He says that the IBA has no position on standard commission.

He argues that the policy price structure is already transparent. What customers need is more time to shop around. They get this with personal motor but not with liability insurance - and this the Competition Authority and the IBA agree needs to change.

The question is: on how much else do the various sides in this debate agree?