DB Pension transfers, the next chapter…

DB Transfers Back on the FCA Radar

If you haven’t heard about what’s been happening in South Wales with the Steel Workers DB pension transfers, then you must have been living on another planet! One thing’s for sure: the FCA is paying close attention to DB transfers. With recent confirmation that they intend to collect data from all firms with the permissions, you may be wondering how to prepare for their request.

Review the Consultation Paper

If you haven’t read consultation paper CP17-16 from June 2017 and reviewed your procedures, now’s the time to do so.

Examine Your Management Information (MI)

Review what MI you can extract easily. Do you keep details of cases you don’t review because you know they won’t be suitable, or where the recommendation is not to transfer? If not, start collating this information, as your PI company may ask for it at renewal even if the regulator doesn’t.

Evidence Ongoing Competence

Consider how you evidence ongoing competence for your advisers and Pension Transfer Specialists (PTS):

• Do non-qualified advisers provide advice that a PTS checks?

• When did your advisers and PTS last undertake structured CPD for this area? Is it regular, relevant, and fully documented?

• How do you show that advice is challenged? Do you pre-approve all cases? Are these completed in-house or through external independent review?

Review Your Suitability Report

Take another look at your suitability report:

• Does it clearly document the client’s objectives?

• Is it individually tailored?

• Is the recommendation clear (don’t sit on the fence!) and does it reinforce how it will help them achieve their objective?

Stay Prepared

A growing number of firms have agreed with the FCA to stop providing transfer advice since last summer. While no-one is completely safe, at least you can be prepared. Contact us to discuss how we can help you be ready when the regulator gets in touch.