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.
As we move into a New Year, we have produced a brief reminder and overview of some of the key regulatory matters that will impact SIPP operators over the coming 12-months.
We have submitted our feedback to the FCA’s consultation of investment pathways and associated matters – our view is that the FCA’s focus should be on the unengaged rather than the non-advised. Our feedback can be found here:
We have produced an update which covers the FCA’s policy statement linked to their Retirement Outcomes Review and the consultation paper dealing with investment pathways.
Within the update, reference is made to appendices which include a summary of the wake-up each requirements (details of what to send and when) along with suggested risk warnings. We are happy to share these upon request – please use the Contact page if you would like a copy.
Two significant FCA publications issued 28/01/2019.
PS19/1 covers the Retirement Outcomes Review. The theme is more frequent consumer information, provided sooner – from age 50 onwards. Generic retirement risk warnings are to accompany ‘wake-up’ packs from age 55. Key features illustrations for drawdown will be presented in real, rather than nominal terms and will include a ‘summary’ page of key information. Prima facie there is nothing too contentious here although pension operators will need to start planning for the partial implementation in November 2019, with KFI changes following in April 2020. A more detailed update for Enhance clients will follow in due course. Link to PS19/1 here: https://www.fca.org.uk/publication/policy/ps19-01.pdf
CP19/5 is a further consultation on ‘investment pathways’ for those with non-advised/cash-based crystallised benefits. Whilst there is a proposed easement for smaller pension providers in having to offer an investment pathway, as always the devil is in the detail. The opportunity to respond is open until 5 April 2019. This feels like innovative work on the part of the FCA where feedback could really influence the final implementation. Link to CP19/5 here: https://www.fca.org.uk/publication/consultation/cp19-05.pdf
Accepting that Brexit is a malleable and fast-moving beast, we have attempted to list in the attached update some Brexit considerations for Sipp operators, in particular in the event of a no-deal.
There are two documents that comprise this update; firstly, some narrative and secondly a table (in PDF and Excel) that lists a range of potential items which, in our view, could be relevant to a Sipp operator. As mentioned in the update narrative, this is not an exhaustive list, rather is a starting point for firms to consider.
We hope this is useful in the first instance. We cannot promise to be able to answer any questions arising, however please feel free to contact us nonetheless in respect of the content of this update, whether questions or observations.
For reference, in preparation for a FCA ‘Brexit’ forum being held next week for trade associations, we have raised via the Association of Professional Compliance Consultants a concern/question for the FCA in regard to whether there will be any flexibility on the part of the regulator in the event of financial resource requirements increasing, for example where current standard regulated funds become non-standard due to illiquidity post Brexit (assuming a worst-case scenario).
The FCA recently issued PS16/12 which was the much anticipated follow up to CP15/30, the FCA’s consultation on Pension Freedoms. Both the consultation and the policy statement were wide ranging in their content. The policy statement changed various pension-related rules and guidance within the FCA Handbook, some of which took effect from 25th April 2016, some from October and the rest from next April. The changes impact on those who advise on personal pensions as well as personal pension operators. Enhance have developed a staff briefing that provides an overview of the Policy Statement. If you would like a copy then please email firstname.lastname@example.org