Firms who have advised clients to transfer away from the British Steel Pension Scheme (BSPS) should be well acquainted with the content of PS22/14 by now …
… but some don’t seem to be aware that they need to have completed some key activity for clients in scope of the redress scheme.
The BSPS Redress Scheme covers consumers who were provided with advice to transfer out of the BSPS between 26 May 2016 (the date the DWP launched its consultation on BSPS) and 29 March 2018 (the date the BSPS entered the Pension Protection Fund) and PS22/14 outlines the steps firms need to take in relation to clients within scope of the scheme, which commences on 28 March 2023.
A flowchart, which starts on page 10 of the Policy Statement confirms that firms with clients in scope of the redress scheme, provides timeframes for specific activities that FCA expects firms to take.
By 28 March 2023 firms must have identified all clients who were advised to transfer out of BSPS and from these must identify all those who fall within the scope of the redress scheme.
By the same date firms must write to all clients (within and outside of scope of the redress scheme) to advise them that the firm will be performing a review of the advice they provided in relation to the transfer, unless the client decides to opt-out. They should also confirm that even if the advice falls outside of the scheme, that the client may still be able to complain in certain circumstances.
Clients who do not receive the letter by 28 March are advised to contact the FCA directly, so firms would be wise to issue the letters.
Acknowledgement of a client’s decision to opt-out of the scheme must be provided within five business days.
The flowchart then spells out the actions required by firms with a further deadline of 28 September. We will provide a further reminder nearer that time.