CP17/16 response form

We are asking for comments on this Consultation Paper by 21 September 2017.

Please use this online form or alternatively, send comments in writing to: Emily Pinkerton and David Berenbaum, Strategy and Competition Division, Financial Conduct Authority, 25 The North Colonnade, Canary Wharf, London, E14 5HS

Email: [email protected]

We make all responses to formal consultation available for public inspection unless the respondent requests otherwise. We will not regard a standard confidentiality statement in an email message as a request for non-disclosure.

Despite this, we may be asked to disclose a confidential response under the Freedom of Information Act 2000. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by the Information Commissioner and the Information Rights Tribunal.

Once you complete this form, we will email you a copy of your submission to acknowledge receipt of your response.

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Q1: Do you agree with our proposal to require all advice on the conversion or transfer of safeguarded benefits to be a personal recommendation? Please provide the reasons for your response.

Q2: Do you agree with our proposals for new guidance on assessing suitability? If not, what guidance do you think would be helpful?

Q3: Do you agree with our proposals to add guidance to the Handbook to clarify what a pension transfer specialist is expected to do when checking advice on transfers or conversion of safeguarded benefits?

Q4: What are your views on how the current qualification requirements for pension transfer specialists operate in practice?

Q5: Do you have any comments on our explanation of the responsibilities of advice firms and pension transfer specialists?

Q6: Do you have any comments on our explanation of the responsibilities of advice firms and independent pension transfer firms?

Q7: Do you agree with our proposals on the introduction of an appropriate pension transfer analysis? If not, how could we amend it?

Q8: Do you agree with our proposals on preparing and presenting the client with a mandatory transfer value comparator within the appropriate pension analysis? If not, how could we amend it?

Q9: Do you agree with the proposed changes to the assumptions for the rolling annuity interest rate, non-annuity mortality, the growth rate and the inclusion of charges?

Q10: What are your views on the use of stochastic tools within appropriate pension transfer analysis? How could the outcomes be presented in a way which results in good consumer understanding, given the format and outcomes presented in other mandated documents?

Q11: Do you have any comments on our explanation of the responsibilities of advice firms in relation to software?

Q12: Do you have any views on the assumptions for CPI and for benefits with caps and collars?

Q13: Do you agree with our proposal for the application of the additional requirements for pension opt-outs to be restricted to opt-outs where there are potential safeguarded benefits available?

Q14: Do you agree with our proposal that the new TVC analysis should not be required for any pension opt-outs?

Q15: Do you have any thoughts on the impact of these proposals on overseas transfers?

Q16: Do you have any comments on our expectations for the provision of streamlined advice when advising on safeguarded benefits?

Q17: Do you have any comments on our cost benefit analysis?

Is your response confidential?

Yes

First published: 21/06/2017 Last updated: 21/06/2017