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. 

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