FCA's pension-switching advice suitability assessment template: Questions section

Transcription

1 FCA's pension-switching advice suitability assessment template: Questions section Section 1: File specific information Firm name Joe Bloggs Financial limited Adviser name Joe Bloggs Customer name Example Client The provider of the receiving scheme is Skandia Investment Solutions The provider and reference of the existing scheme is (Policy 1) Abbey Life EC (Policy 2) Standard Life EC (Policy 3) Aegon AE (Policy 4) Scottish Widows SW Q2334 (Policy 5) Friends Life FL Reviewer name Review date Customer date of birth 15/01/1963 Date of application form The receiving scheme is a Section 2: Customer needs analysis A. What drivers for the pension switch were stated in the suitability report or in other documents on file? Consolidation Future drawdown Investment flexibility Performance Specific investment Switch to cheaper scheme Other: state in customer needs box File does not contain drivers Comments on customer needs analysis 1 Printed on 12 vember 2013

2 Section 3: Unsuitable outcomes 1. The customer has been switched to a pension that is more expensive than their existing one(s) or a stakeholder pension (because of exit initial penalties and/or costs and ongoing costs of the receiving scheme versus the old scheme or a stakeholder pension) without good reason. 1.1 Is the receiving scheme more expensive than the ceding scheme(s)? : same : receiving scheme is less expensive t enough information to tell Costs are not an issue: explain why 1.2 Is the receiving scheme more expensive than a stakeholder pension? : same : receiving scheme is less expensive t enough information to tell Costs are not an issue: explain why 1.3 For each pension switch, did the advice consider any MVAs or penalties that applied on switching out? : this is detrimental to the customer t an issue: explain why NA: has no penalties 1.4 Does the receiving scheme have the features / options that meet the customer's needs? t an issue: explain why NA: has no penalties 1.5 Could the features / options / funds have been achieved more cost effectively by a different product? t an issue: explain why NA: has no penalties 2 Printed on 12 vember 2013

3 1.6 Is the recommendation to switch to a more expensive scheme than the ceding scheme(s) without good reason (see guidance)? : provide details Costs are not an issue: explain why t enough information to tell additional cost Examples: Did the adviser identify a limited range of investments in the ceding scheme? Did the adviser check that the investments in the ceding scheme were performing poorly? Has the adviser analysed the with-profit funds in the ceding scheme 1.7 Is the recommendation to switch to a more expensive scheme than a stakeholder pension without good reason (see guidance)? : provide details Costs are not an issue: explain why t enough information to tell additional cost Examples: Has the adviser made use of external funds? Would a stakeholder pension meet the customer's needs? Comments on outcome 1 Outcome 1 materialised? 3 Printed on 12 vember 2013

4 2. The customer has lost benefits (e.g. guaranteed annuity rates) in the pension switch without good reason. Were guarantees in the ceding scheme considered and was there good reason for their loss on switching out? : loss of guarantees justified : loss of guarantees not justified : no evidence of guarantees checked t an issue: explain why NA: no guarantees Comments on outcome 2 Outcome 2 materialised? 4 Printed on 12 vember 2013

5 3. The customer has switched into a pension that does not match their recorded attitude to risk (ATR) and personal circumstances. 3.1 What is the ATR recorded in the know your customer (KYC)/fact find documents? N/A (calculated via questionnaire) 3.2 What is the ATR recorded in the suitability report? Moderate (3 out of 5) 3.3 Is the investment recommendation suitable given the customer's ATR and personal circumstances? t an issue: explain why Comments on outcome 3 Outcome 3 materialised? 5 Printed on 12 vember 2013

6 4. The customer has switched into a pension where there is a need for ongoing investment reviews but this is not explained, offered or put in place. 4.1 Did the suitability report explain the importance (see guidance) of regular ongoing reviews? : but should have t an issue: explain why 4.2 Have these been offered, carried out or arranged for a future date? Either offered, carried out or arranged Offered but review date has passed the review has been missed : not offered, not carried out and not arranged t an issue: explain why Comments on outcome 4 Outcome 4 materialised? 6 Printed on 12 vember 2013

7 5. Other unsuitable outcomes 5.1 Detail any other unsuitable outcomes identified Outcome 5 materialised? Initial rating Suitable Unsuitable Explain why you have this rating Final rating (if initial rating is "") Suitable Unsuitable If the initial rating is "" because of incomplete information on file, you should obtain the missing information from the adviser and reassess 7 Printed on 12 vember 2013

8 FCA's pension-switching advice suitability assessment template: Data section Ceding schemes Policy Policy Type Transfer value Fund value Ongoing charges % date (low rate) date (mid rate) date (high rate) Guarantees and guaranteed annuity rates Comments Policy 1 70, , % 103, , ,000 Policy 2 45, , % 109, , ,000 Policy 3 Executive Pension 13, , % 27,700 35,000 44,000 GAR, PCLS>25%, Policy 4 28, , % 43,500 49,000 56,500 Policy 5 Stakeholder 61, , % 80, , ,500 Policy-specific data for receiving scheme Policy Fees / initial commission for advice Fees / ongoing commission Adviser waived fee and commission Comments Policy % 1.00% Fees from unit encashment. 3% reg. premium fee Policy % 1.00% Fees from unit encashment Policy % 1.00% Fees from unit encashment. 3% reg. premium fee Policy % 1.00% Fees from unit encashment. 3% reg. premium fee Policy % 1.00% Fees from unit encashment. 3% reg. premium fee Policy Retirement date Retirement age on KFI / projection n fund charges (initial) % n fund charges (ongoing) % date (low rate) date (mid rate) date (high rate) Comments Policy 1 15/01/ % 0.25% 87, , ,000 Policy 2 15/01/ % 0.25% 99, , ,000 Policy 3 15/01/ % 0.25% 14,700 19,400 25,300 Policy 4 15/01/ % 0.25% 35,700 40,900 46,800 Policy 5 15/01/ % 0.25% 67,100 88, ,000 8 Printed on 12 vember 2013

9 s Fund-specific data for receiving scheme Fund or asset % of TV invested in fund or asset External fund? Fund charges (initial) % Fund charges (ongoing %) Comments Invesco Perpetual Income 9% 0.00% 0.85% Franklin UK Mid Cap 7% 0.00% 0.83% AXA Framlington UK Select Opportunities 5% 0.00% 0.82% BlackRock UK Smaller Companies 3% 0.00% 0.84% M&G Recovery 3% 0.00% 0.86% Liontrust UK Growth 2% 0.00% 0.93% BlackRock rth American Equity Tracker 4% 0.00% 0.11% Threadneedle American Select 2% 0.00% 0.84% Baring Europe Select 3% 0.00% 0.82% Jupiter European 3% 0.00% 1.04% Schroder Tokyo 2% 0.00% 0.84% First State Asia Pacific Leaders 3% 0.00% 0.89% Newton Asian Income 2% 0.00% 0.82% AXA Framlington Emerging Markets 2% 0.00% 0.90% Lazard Emerging Markets 2% 0.00% 0.77% Invesco Perpetual Monthly Income Plus 7% 0.00% 0.69% Kames Strategic Bond 5% 0.00% 0.81% Threadneedle High Yield Bond 5% 0.00% 0.74% Fidelity Strategic Bond 3% 0.00% 0.71% M&G Short Dated Corporate Bond 3% 0.00% 0.55% Templeton Global Total Return Bond 3% 0.00% 0.80% SWIP Property Trust 9% 0.00% 1.30% First State Global Property Securities 2% 0.00% 1.00% BlackRock Cash 3% 0.00% 0.29% M&G Global Basics 2% 0.00% 0.88% Henderson Global Growth 1% 0.00% 1.55% BlackRock Gold & General 1% 0.00% 0.97% First State Global Listed Infrastructure 2% 0.00% 0.87% Sarasin AgriSar 2% 0.00% 1.07%. Performance related variable TER 9 Printed on 12 vember 2013