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.
Papers galore!
Huw Reynolds Compliance 2021, Certification, Conduct, COVID-19, FCA, Gabriel, Pension, platform, protection, Senior Manager, SM&CR, Switch, transfer
It has been a busy month for papers and publications at the FCA. These include: New Consumer Duty CP The FCA is consulting on plans to introduce a new Consumer Duty, which aims to set a higher level of consumer protection in retail financial markets. The Duty will have 3 key elements: A new Principle – the […]