The FCA has issued guidance for firms in relation to processes for handling paper and post during the COVID-19 emergency. Firms should read the guidance. The key messages are:
- The FCA understand that some processes will not be able to be complied with currently. Where that is the case, firms need to notify the FCA.
- Firms should take reasonable steps to mitigate the impact of any non-compliance with normal required processes and timescales.
- Firms should ensure they collect post delivered to the normal place of business as regularly as possible so it can be dealt with as appropriate.
- Firms should take steps to inform clients of current arrangements and delays that might occur, for example through the firm’s website or by email, and update the information as required.
- Cheques and transactions that cannot be processed should be confirmed to clients as soon as possible and any funds returned.
- The needs of vulnerable customers and others who might not be able to access online services should be addressed.



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 […]