Response to DP24/3

Response to DP24/3

Enhance has responded to the FCA’s Discussion Paper “Pensions: Adapting our requirements for a changing market”.

As you will be aware, the DP posed a number of discussion points related to the SIPP sector. Some of these discussion points are potentially quite far reaching, so we do think it’s important that as many SIPP Operators as possible respond. If it helps, please feel free to lift any ideas or text from the attached although it’s important to stress that the attached reflects our views which you may or may not agree with! The response closes on 27 February 2025, so there is a little time still to go.

The full response can be downloaded here

Response to the FCA’s Consultation Paper CP24/16 – The Value for Money Framework

Enhance has responded to the FCA’s consultation in respect of a ‘Value for Money’ framework that will apply a consistent approach to assessing the performance of DC-workplace pension arrangements. The performance assessment will include looking at past performance; costs & charges; and, quality of services provided, each being measured by prescribed criteria to allow comparison against other arrangements. The assessment will result in an overall red, amber or green ranking, with prescribed outcomes for those arrangements with an amber of red ranking. Where SIPP provider has not sought to establish a workplace arrangement but are used by members who direct an employer to contribute, therefore technically fall within the definition of a workplace scheme, these are proposed to be exempted from the VfM framework requirements.

The full response can be downloaded here

Response to the DWP’s Occupational and Personal Pension Schemes (General Levy) Regulations review 2023

Enhance has responded to the General Levy review, in particular focusing on the proposed ‘Additional Premium’ option that will impact on small schemes, which as the review is currently framed, seems to include Small Self Administered Schemes (“SSAS”). Our response outlines why we believe the proposed premium of £10,000 is disproportionate to SSAS, especially when out of all the pension scheme types that use the resources that the levy pays for (The Pensions Regulator, The Pensions Ombudsman and MaPS), SSASs impact on these services the least.

The full response can be downloaded here

The Financial Ombudsman Service – Fair and Reasonable

Further to my recent LinkedIn post, there have been a few requests to share the content of my thesis for Research Masters degree in Law, focusing on the role of the Financial Ombudsman Service in settling financial services disputes. In particular, the research focused on the extent that the ombudsman departed from legal precedent (case law) when reaching its decisions. In response to requests to share the detail, posted here is both the thesis and a much shorter overview document. If nothing, it makes a good bed time reading for insomniacs – enjoy!

Kevin Jack

The Financial Ombudsman Service – Fair and Reasonable

202306 Masters summary

Regulatory Barometer – February 2022

The purpose of this document is to provide an overview of current and upcoming regulatory matters that may be of interest to the Operators/Administrators of personal pension schemes (and in some matters, the Administrators/Practitioners of SSASs). For each item there is a brief summary including the source (i.e. regulatory/legislative changes) along with the relevance to firms, timelines and sugges ted actions the firm may wish to consider. 

 

Regulatory Barometer – October 2021

The purpose of this document is to provide an overview of current and upcoming regulatory matters that may be of interest to the Operators/Administrators of personal pension schemes (and in some matters, the Administrators/Practitioners of SSASs). For each item there is a brief summary including the source (i.e. regulatory/legislative changes) along with the relevance to firms, timelines and suggested actions the firm may wish to consider. 

Regulatory Barometer – May 2021

This high level document aims to capture topical regulatory matters that firms may wish to be aware of. For each, we have applied a broad RAG rating based on the impact of each item, along with a suggested high-level action and further information sources. The document will be updated on a quarterly basis. 

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