Having done our first post 1 October reviews of pension transfer cases this week, we spotted a misunderstanding of how the transitional period applies.
Cases we have looked at are still being charged on a contingent basis – all perfectly fine because they satisfied the criteria for the transitional rules …
“Where a firm can demonstrate that clients that have agreed contingent charges terms before 1 October and started work before 1 October, the firm may charge contingently, provided a personal recommendation is given before 1 January 2021 (i.e. within 3 months of the ban being implemented)”
However, the suitability reports did not include the required one-page summary. The firm thought the transitional period applied across the board. It does not. It only applies in relation to the charging basis and the requirement to compare a workplace pension. Other new rules, including the requirement to have a one-page summary and the new CPD requirements for Pension Transfer Specialists, apply as from 1 October.
New Content Integration with EDI, Periodic Review Template Updates & Much More
David Anderson Suitability 2022, abridged, Defaqto, EBI, MiFID, Pension, platform, protection, Switch, Update
We have completed the latest upgrade to ATEB Suitability on 14th August 2022. This update comes at no additional cost and provides various template related enhancements as well as a new addition to our content integration library. Full details of the enhancements can be found in the tables below, but some of the highlights are: […]