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.
Financial protection post-BREXIT
Huw Reynolds Compliance 2020, 2021, complaints, EEA, EU, FCA, FOS, FSCS, protection, Update
In December 2020, we reminded readers about the expected changes to FSCS protection after the EU withdrawal period ended on 31 December. You can read that article here. The transition did end when expected and with last minute agreement on a trade deal, which was not so certain. However, the agreement did not cover financial […]