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). 

Barclays & Enhance SIPP Seminar Agenda