(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:
- It must be suitable.
- It must be in the client’s best interests.
- 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 http://www.fca.org.uk/static/pubs/guidance/fg12-16.pdf.
This guidance on pension switching is also important
http://www.fca.org.uk/firms/financial-services-products/investments/pension-switching
as is this for platforms
http://www.fca.org.uk/firms/financial-services-products/investments/platforms



Should clients take Abridged Advice?
Paul Caine Compliance 2018, abridged, DB Pension, FCA, MiFID, Pension, Pension Transfer, Switch, TCF, transfer
Assessing suitability has always essentially been based around the same overarching principles … The recommended product type should meet the client’s profile and needs? The actual product recommended should be the most suitable, taking account of features and costs. In relation to the second principle, the cliché about cheapest is not necessarily the […]