CP18/7 response form

We are asking for comments on this Consultation Paper by 25 May 2018.

Please use this online form or alternatively write to: Sandra Graham and David Berenbaum, 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 the proposed changes to the qualifications for a PTS? If not, how would you suggest we amend it?

Q2: Do you agree with our proposed arrangements for the transition period?

Q3: Do you agree with the proposed changes to the exam qualification standard, ApEx 21? If not, how would you suggest we amend it?

Q4: Do you agree with the proposed changes to the pension transfer definition? Please indicate if you consider there are any other consequences that have not been identified.

Q5: Do you agree with our proposed guidance for advisers working together? If not, how should we amend it?

Q6: Do you have any comments on our explanation for advising self-investors?

Q7: Do you agree with our proposed guidance on triage? If not, how could we approach it differently?

Q8: Do you agree with our proposed guidance on assessing attitude to transfer or convert risk?

Q9: Do you agree with our proposals to modify the Handbook rules and guidance in respect of suitability reports and the advice confirmation?

Q10: Do you agree with our proposal on pension increase assumptions?

Q11: Do you think that contingent charging increases the likelihood of unsuitable advice? If so, can you provide any evidence to support intervening in the way pension transfer advice is charged, or would another approach be more effective?

Q12: If we proceeded to restrict the way in which pension transfer advice can be charged, do you have views on how this should be implemented? In particular, how could we avoid different forms of restriction from being ‘gamed’?

Q13: How would different forms of restriction on pension charging impact consumers and firms? Are there any ways in which we would mitigate any negative impact? For example, to address concerns about reduced access to advice (due to increased advice costs for consumers who do not transfer), could we require firms to ‘signpost’ consumers to internal or external guidance/triage services, including The Pensions Advisory Service?

Q14: Do you have any comments on our cost benefit analysis?

First published: 26/03/2018 Last updated: 05/04/2018