latest news and industry updates from Enhance

Preparing for Brexit: Considerations for SIPP Operators

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’s recent issue PS16/12

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