During a recent workshop, the FCA commented on SM&CR training. They do not believe that some e-learning or short generic training meets their requirements.
We believe that this is primarily a reference to the need for all staff to understand the intention of the SM&CR to move firms to a culture of accountability at all levels. Accordingly, Conduct Rules training should include the opportunity for individuals to identify how these apply to their own organisation and, in particular, to their role within the organisation.
Reasons for recommending a transfer or switch that are open to challenge
Alistair MacDougall Compliance 2017, DB Pension, FCA, Pension, Pension Transfer, PI, Switch
CP19/25 highlighted some commonly used reasons to transfer/switch that often do not stand up to close scrutiny.