The FCA has published an alert to all Principals, regardless of sector, who have one or more Appointed Representatives or Introducer Appointed Representatives (‘ARs’). Principals are responsible for the regulated activities of their ARs. The alert sets out the risks that the FCA expects firms to consider and act upon, where relevant.
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This is a follow up to previous alerts about the risks involved in dealing with Introcuders. All Principal and Appointed Representative firms should read it.
For information.
The rights of pension scheme members to transfer, that were established in the Pensions Act 2015 are no longer absolute from 30 November 2021. From that date, in an attempt to identify potential scams and prevent members becoming victims, trustees and scheme managers must ensure specific checks are made before complying with a member’s […]
We previously issued a newsletter in February 2021, outlining government proposals to increase the Normal Minimum Pension Age (NMPA) from 55 to 57, with the change due to come into effect from 6 April 2028. This means that from April 2028, the earliest a member of a pension scheme will be able to access their […]
Policy Statement PS20-06 states: “A firm may set a different level of non-contingent charges if they are not undertaking the full range of advising and related services that are normally provided alongside DB transfer advice. For example, if a firm is not advising on the proposed destination for the funds, it could offer lower charges […]
Occasionally, we come across firms that are ‘Principal Firms’ – i.e. the firm has Appointed Representatives (AR) but where one or more individuals straddle both the Principal and the AR. This can raise questions around the applicability of SM&CR to such individuals since the SM&CR does not apply to ARs. Why does the SM&CR not […]
Conduct Rules Breaches – follow up
Huw Reynolds Compliance Conduct, FCA, Pension, Senior Manager, Update
We wrote recently about the Conduct Rules and, in particular, breaches and notifications . See here. This article is intended to clarify some of the grey around COCON breaches. All of the following is taken from Policy Statement PS 18-14. When is disciplinary action required? When and how a firm decides to undertake disciplinary action […]