MIFID investment firms now need to use a new form to notify FCA of management body changes for Non-SMF Directors. This form is required to submit information when appointing Non-SMF Directors to, or withdrawing them from, the firm’s management body.
The form is called ‘Notification Procedures for Changes to the Management Body for Non-SMF Directors’ and is available to download in SUP 15 Annex 14R of the FCA Handbook.
If a firm’s management body changes, the form needs to be downloaded, completed and emailed to NonSMFNotification@fca.org.uk until it is loaded on to Connect. From Q1 2020, firms will be able to submit the form via Connect, the FCA’s online platform.
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 […]