The FCA has issued a ‘Dear CEO’ letter to General Insurance Intermediaries setting out its expectations for maintaining adequate arrangements that safeguard client money especially during the coronavirus (Covid-19) pandemic.
It reminds firms of their obligations to continue to oversee the CASS arrangements. It requires firms to discuss the contents of the letter with the board and agree what further action is necessary to help ensure adequate arrangements are in place, highlighting the following areas:
- application of client money rules to firm’s business model;
- governance and oversight;
- oversight of third parties, including due diligence;
- client money calculations and reconciliations;
- acknowledgement letters for all client money accounts.
You can find further information regarding client assets and coronavirus here.
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 […]