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.
The replacement business blind spot?
Paul Jay Compliance Drawdown, FCA, Pension, PI, platform, Switch, transfer
We’ve been involved with a number of firms who are on the acquisition trail and as part of the due diligence work we support them with, we check a lot of advice files. It won’t come as a surprise that many of these involve replacement business. What never ceases to amaze us is that, despite […]