Replacement Business

(From this blog’s perspective it is coincidental that ‘R’, ‘S’ and ‘T’ are adjacent in the alphabet and you should read all three at the same time.)

Pension switch, pension transfer, investment switch, fund switch, platform switch, product replacement, policy re-write – all terms that describe some form of replacement.

Firms can sometimes get confused about the requirements for different types of replacement, particularly with the FCA issuing specific guidance where they consider there to be a high risk of consumer detriment, such as for pension switches and platform switches.

However, the fundamental principles stay the same regardless of the replacement type:

  1. It must be suitable.
  2. It must be in the client’s best interests.
  3. Where a more expensive solution is recommended, there needs to be a good reason and this reason needs to be justified to the client (unnecessary additional costs is often cited by the FCA as a reason for unsuitable advice).

To demonstrate the above, relevant comparisons between new and old must be undertaken and objectively analysed. The advantages and disadvantages must be disclosed and discussed with the client. Alternative solutions must be considered. Care should be taken when considering complex replacements, such as critical illness. There must be clear and documented justification for the replacement.

The reasons why the adviser considers a replacement suitable must be clearly explained in the suitability report.

Firms therefore need strict controls to police all forms of replacement business and the default position should be – ‘don’t replace unless there is a damn good reason to do so’.

If you have not already done so, you should read this guidance

This guidance on pension switching is also important

as is this for platforms

(now read ‘S’)

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

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About the Author

Director - Having joined us directly from university, David quickly developed into an indispensable member of the team. As our IT Director he is responsible for ATEB’s technology strategies, security systems and platforms. He has been at the forefront of the development of ATEB Suitability and instrumental in ensuring that the complex regulatory requirements are catered for in an interactive and intuitive fashion. He would be delighted to discuss its capabilities with you in more detail.

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