Holistic Pension Transfer Specialists
Defined benefit specialists HPTS are proof it’s possible to survive FCA scrutiny and return to unrestricted trading with the right compliance support.
A surprise from the FCA
In November 2019, the FCA visited Holistic Pension Transfer Specialists (HPTS) and immediately asked the firm to “voluntarily” withdraw from the market as seven files dating from 2017-18 were deemed “unclear” because they did not contain enough fact-finding evidence.
HPTS’ existing compliance support was heavily criticised by the regulator, so the firm engaged B-Compliant to undertake reviews of the files highlighted as inadequate and oversee changes to the systems and processes in place.
Hands-on support
B-Compliant was provided with the files in question by HPTS and an initial review was undertaken to establish what information was missing. These findings were then peer reviewed by our director, Vicky Pearce, who has extensive experience in this area.
After approval was sought by HPTS, our consultants contacted the affected clients via video call. With agreement, recordings of the conversations were made for transparency and further feedback.
A total of five clients agreed to speak to our consultants. Once contact was complete, our defined benefit (DB) specialist reviewed the responses and the original files to ensure the missing information had now been obtained.
Where a final assessment of suitability was not possible because gaps still existed, further documentation was then requested from HPTS.
Vicky said: “Anyone with DB permissions can expect to come under scrutiny from the regulator, and many firms have folded under the pressure. HPTS proved that if you are willing to jump through the FCA’s hoops and have nothing to hide, you can operate in this high-risk market.
“The firm emerged from the ordeal with a clean bill of health and the knowledge to produce advice of the highest standard, but reaching this point was a huge learning curve.”
A long, hard slog
Ultimately, it took HPTS 30 months to return to unrestricted trading.
Administrative delays and the effects of the pandemic meant it was May 2021 before work could recommence and only then, with every file being checked closely. This requirement wasn’t removed until June 2022.
Clare Bruce, head of advisory at HPTS, added: “We spent nearly £300,000 in legal fees and running costs to fight our way through the FCA’s investigation and subsequent surveillance, but no inappropriate advice had been given and we were determined to prove our innocence.
“Had we known at the outset how long it would take, it might have been another story, but coming out the other side of such an ordeal has given us an enormous sense of satisfaction.”
