We thought it appropriate to issue a reminder about the SUP 15.12 notification requirements where, in a 12-month period, a Retail Investment Adviser has :
- Three or more complaints upheld; or where
- Redress for a complaint exceeds £50,000*
*The £50,000 includes all payments including goodwill, distress, inconvenience, interest etc.
These requirements are in addition to those in the regular GABRIEL complaints return. The rules can be found here.
Briefly, where one of the scenarios above occurs the firm must report, via Form G, to the FCA within 20 business days of the third complaint or the day the complaint was upheld, where redress is agreed. The reporting process and forms can be accessed via the link above.
Note, if the firm rejects a complaint and the FOS subsequently upholds it this must be included in the reporting requirements.



Pension Transfer charging
Alistair MacDougall Compliance abridged, FCA, P1, Pension, Pension Transfer, PI, transfer
Policy Statement PS 20-06 stated that a firm providing pension transfer advice “… may also not charge less than it would charge for investment advice of the same value”. That seems clear enough, but the rule that gives effect to this statement is subtly different. COBS 19.1B.7 states: “A firm should not charge less […]