October / November 2019

The FCA is issuing letters to around 1700 firms that have advised on DB Transfers. The letters are being issued in stages.

The letter is a follow up to the online data submission by firms following the FCA section 165 request. The letter is standard and follows consideration by the FCA of each firm’s:

• Volume of transfers
• Conversion rate
• Insistent client(s)
• Income from DB business
• Unauthorised introducers
• Transfers per Pension Transfer Specialist
• Expensive solutions

The letter states relevant firm specific data for each of the aspects above and defines action to be taken in respect of each aspect. Firms are required to:

• Review the feedback and take the actions defined in each section including appropriate mitigation actions;
• Provide the FCA with a high-level, succinct overview of the actions taken, the results from this and any further action planned. The response for each area of feedback (e.g. volume of transfers, conversion rate etc.) should be no more than 1 side of A4;
• This summary should be emailed to the FCA when complete.

This action must be done ‘as soon as practicable’ but, in any event, within either one month or two months (varies according to individual firm’s letter) of the date of the FCA’s letter.

If the letter received does not outline any concerns on a particular area, that does not indicate there is no risk arising from the firm’s systems and controls in that area. In reviewing practices and procedures, the firm should ensure that all DB advice requirements are met.