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.
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Paul Jay Compliance assessment tool, Conduct, DB Pension, DBAAT, Defined Benefit, FCA, FOS, Pension, PI, Senior Manager, SM&CR, Switch, transfer
Most firms will have at least vague recollections of the FSA’s thematic review of pension switching and the report it produced in December 2008. It produced a flurry of activity, but as time has elapsed it has perhaps become a distant memory, despite the high volumes of replacement business that have been and continue […]