Aspect

Requirements to qualify for transitional treatment

One-page summary

Not applicable, the one-page summary is required in all suitability reports from 1 October 2020 although certain elements relating to workplace pension may be omitted – see below.

Contingent charging

Firms may charge contingently where they can demonstrate that:

• the advice process before 1 October; and
• contingent charging terms were agreed in writing before 1 October; and
• a personal recommendation/suitability report is prepared before 1 January 2021.

Consideration of workplace pension scheme (WPS)

Firms may:

1. omit the comparison with a WPS in APTA; and
2. the one-page summary can omit the comparison with a WPS …

… where they can demonstrate that:

• the advice process before 1 October; and
• a personal recommendation/suitability report is prepared before 1 January 2021

Cash flow modelling*

Firms need not carry out cashflow modelling as set out in the new rules where they can demonstrate that:

• the advice process before 1 October; and
• a personal recommendation/suitability report is prepared before 1 January 2021