Enhance has responded to HM Treasury’s review of the FOS.

It is probably acknowledged that the Financial Ombudsman Service requires updating and this review, along with an FCA consultation, aim to do that. We think there are some reasonable proposals made by the Treasury, however as with many of these types of proposal, there are a few questions yet to be answered. This is especially so in relation to how the FOS may interpret some of the higher level FCA rules when applying these to decisions. This is a challenge now and it is unclear how this particular dial gets moved forward. The consultation closes on 8 October 2025. As always, if you are thinking of responding, please feel free to lift any ideas or text from our response, although it’s important to stress that the response reflects our views which you may or may not agree with!

The full response can be downloaded here

Enhance has responded to the FCA’s consultation on modernising the redress system.

It is probably acknowledged that the Financial Ombudsman Service requires updating and this consultation, along with HM Treasury proposals, aim to do that. We think there are some reasonable proposals made by the FCA, however as with many of these types of proposal, there are a few questions yet to be answered. This is especially so in relation to ‘mass redress events’ which the pensions sector will wish to avoid! The consultation closes on 8 October 2025. As always, if you are thinking of responding, please feel free to lift any ideas or text from our response, although it’s important to stress that the response reflects our views which you may or may not agree with!

The full response can be downloaded here

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

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

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

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

Enhance have responded to the Financial Reporting Council’s proposals to revise the basis of SMPIs. In particular, we have focused on the FRC’s proposal to move to projection rates based on the underlying volatility of the funds. Our response can be downloaded via the link below.

20220506 Response to FRC AS TM1 Consultation.

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.