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.
FCA Covid-19 Survey #5
Richard Foster Compliance 2020, 2021, COVID-19, email, FCA, platform, scam
The FCA has advised; Many of you will be aware that we issued the first phase of the Covid-19 Impact Survey in June 2020, covering around 13,000 firms across 15 Supervision portfolios (Tranche 1), and then rolled this out to a further 9,500 firms in 21 portfolios (Tranche 2) at the beginning of August 2020. […]