CP18/7: Improving the quality of pension transfer advice

Open consultation: CP18/7
Consultation closes
Policy Statement
Autumn 2018

We are consulting on improving the quality of pension transfer advice.

Read the summary of CP18/7 (PDF)

Read the full consultation (PDF)

The proposals we are consulting on include:

  • raising qualification levels for pension transfer specialists (PTSs) to require them to obtain the same qualification as an investment adviser
  • guidance to clarify our expectations that advisers should be exploring clients’ attitudes to the general risks associated with a transfer, in addition to their attitude to investment risks
  • guidance to illustrate how firms can carry out an appropriate ‘triage’ service (an initial conversation with potential customers), without stepping across the advice boundary, by providing generic, balanced information on the merits of pension transfers
  • a requirement for firms to provide a suitability report regardless of the outcome of advice

We are also seeking views on whether to intervene in relation to charging structures. This could include introducing a ban on contingent charging, which is when a fee for advice is only paid when a transfer goes ahead.


Defined benefit pensions and other safeguarded pensions provide valuable benefits so most consumers will be best advised to keep them.

In 2017, in CP17/16, we consulted on proposals aimed at providing advisers with a framework which better enables them to give good quality advice so that consumers make better informed decisions. We have now published new rules in PS18/6.

In CP17/16, we asked discussion questions on a number of topics. Respondents also raised issues not considered in the paper. This feedback, as well as findings of our ongoing supervisory work, has informed the proposals in CP18/7.

Who this applies to

This consultation will primarily be of interest to:

  • firms advising on pension transfers
  • those acting as pension transfer specialists
  • pension providers
  • those providing software for pension transfer advice
  • consumer groups

The consultation may also be of interest to:

  • employer sponsors of defined benefit pensions
  • employee benefit consultants
  • providers of qualifications
  • providers of professional indemnity insurance
  • other industry and professional bodies

What you need to do

Please send us your comments by 25 May 2018

Online response form

You can also:

  • email [email protected] or
  • write to: Sandra Graham and David Berenbaum, Strategy and Competition Division, Financial Conduct Authority, 25 The North Colonnade, Canary Wharf, London, E14 5HS

Next steps

We will consider your feedback and publish our rules in a Policy Statement in the Autumn 2018.

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