Pension Transfer Advice
Pension transfer advice has been a high priority for the FCA for some time now. Ever since the Government’s pensions freedom legislation relaxed the rules, the regulator has been concerned about the appropriateness of pension transfer advice.
The ‘disappointing’ findings of the FCA’s suitability assessment on advice given in relation to the British Steel Pension Scheme significantly added to these concerns and intensified regulatory scrutiny on the sector.
The FCA has recently raised the prospect of a partial ban on contingent charging, increasing the CPD requirements for anyone providing pension transfer advice, and collecting more, and more frequent, data on their activities.
In short, pension transfer advice remains very much in the regulator’s sights.
Failure to provide suitable pension transfer advice can have serious implications for your business. The FCA could remove your pension permissions. You might find it hard to get professional indemnity (PI) insurance cover. The damage to your reputation could see clients taking their business elsewhere. If you’re in the latter stages of your career, it’s worth reflecting that it could also affect your firm’s value when you come to sell.
You may have been providing pension transfer advice for years. You may be looking to grow your business by moving into the pension transfer space for the first time. Either way, we’re the people to talk to. We can advise you on how to de-risk the process of providing pension transfer advice.
We offer a range of services around pension transfers:
- We can advise you on your pension transfer advice proposition and processes to make sure they’re compliant – and that any weaknesses in your advice are mitigated and in line with COBS 19.1 and COBS 9
- We can advise you on how to comply with the recommendations in PS 18/06 and on the requirement for appropriate pension transfer analysis (APTA)
- We can carry out a past-business review to identify any issues around pension transfer business you’ve conducted previously. This can help identify advisers who may have provided substandard advice and can also help in conversations with PI providers
- If you’re a consolidator or an IFA looking at purchasing another practice, we can help you with the vital task of understanding what pension transfer activity has taken place within your target acquisition – and what liabilities may be sitting on its books. This can be important when it comes to negotiating price and terms
- We can give you an expert opinion on your investment proposition and on whether your risk profiling is up to standard
- We can help you ensure any conflicts are managed and documented
- A member of our team can sit on in on triage processes for initial case take-on – or on the PT committee for pension transfer cases that are less clear-cut.