15 January 2018
If you’ve not heard about what’s being going on in South Wales with the Steel Workers DB transfers, then you must have been living on another planet! One thing’s for sure, DB Transfers are well and truly back on the FCA’s radar, and with recent confirmation that they intend to collect data for all firms with the permissions, you may be wondering what you can do to prepare for the request popping through your door. So here are a few points for consideration: –
- If you haven’t read the consultation paper CP17-16 from June 17 and reviewed your procedures off the back of this, then now’s the time to do so.
- Review what MI you can extract easily. Do you keep details of where you don’t proceed to review as you know it’s not going to suitable? or where the recommendation is not to transfer? If not, then you should be, so have a look back through your records and start collating this information, as chances are your PI company will ask for it at renewal even if the regulator doesn’t.
- How do you evidence ongoing competence for your advisers and Pension Transfer Specialists (PTS)? Consider:
- Do you have non-qualified advisers providing advice which is checked by a PTS?
- When did your advisers & PTS last undertake structured CPD for this area, is this regular and relevant? Is it fully documented?
- How do you evidence that the advice is challenged? Do you pre-approve all cases? Are these completed in-house or through external independent review?
- Take another look at your suitability report, does this clearly document the client’s objectives? Is it individually tailored to them? Is the recommendation clear? (don’t sit on the fence!) and does this reinforce how it will help them to achieve their objective?
There’s a growing number of firms since last summer who’ve ‘agreed’ with the FCA to stop providing transfer advice. So, whilst no-one is safe, at least you can b-prepared. Contact b-compliant now to discuss how we can help you b-ready when the regulator gets in touch.