The FCA has published two new bite-size SM&CR podcasts. These will be useful for firms currently preparing for SM&CR.
- Certification and regulatory references: The purpose and scope, plus practical steps firms can take to prepare.
- Conduct rules: The five Conduct Rules will apply to everyone doing financial services work. The podcast explains the training requirements around them and offers practical tips for training staff.
The latest guidance and information on SM&CR can be found here. We would recommend that firms check this link regularly between now and 9 December 2019.
In particular, firms should note the deadline of 24 November for submitting Form O (Opt Up Notification – for Core and Limited Scope firms only) and Form K (Conversion Notification – for Core and Enhanced firms only) if these are applicable.
Pension Transfer charging
Alistair MacDougall Compliance abridged, FCA, P1, Pension, Pension Transfer, PI, transfer
Policy Statement PS 20-06 stated that a firm providing pension transfer advice “… may also not charge less than it would charge for investment advice of the same value”. That seems clear enough, but the rule that gives effect to this statement is subtly different. COBS 19.1B.7 states: “A firm should not charge less […]