Pension transfer suitability requirements
Three steps for advising insistent clients
How is CETV is calculated?
Differing assumptions for CETV and TVAS
CETV assumption are set by the scheme. TVAS assumptions are set by the FCA.
Assumptions: annuity rates, inflation and NAE
What is an employer covenant? Why would it lead to an unreduced CETV?
Employer’s legal obligation and financial ability to support its scheme.
Features of EPP
Steps a client must take if they want to transfer to access flexibly
It benefits are safeguarded and the transfer value is more than £30k, the member will have to provide evidence to the trustees that he has received independent advice from a firm that has appropriate regulatory permissions.
Timeline for statutory transfers over £30k
Day 1: member requests statement of entitlement.
1 month: within 1 month the scheme must inform the member of the requirement to seek independent financial advice
3 months: guarantee date
3 months and 10 days: within 10 days of guarantee date the trustees must provide the statement of entitlement and inform member of deadline to provide evidence of advice
6 months: deadline to apply for transfer in writing
6 months and ten days: within 3 months and 10 days of guarantee date, deadline to provide evidence of advice.
9 months: within 6 months of guarantee date, and with evidence of advice, trustees make transfer.
APTA Process
Firm must do APTA prior to giving recommendation. Must include TVC.
No need for APTA if only guarantee is GAR.
Step 1: assess benefits likely to be paid and options available under ceding scheme
Step 2: compare results from step 1 with benefits and options of proposed scheme
Describe the TVC
Explain triage services
List BCE events and how they’re valued
BCE 1: age 75 - amount of unused funds
BCE 2: scheme pension - 20 x income
BCE 3: excessive increase to scheme pension - 20 x increase
BCE 4: lifetime annuity purchase - purchase price
BCE 5: DB age 75 - 20 x income plus lump sum
BCE 5B: age 75 - unused funds
BCE 5C: death benefits in FAD before 75 - fund value
BCE 5D: death benefit for lifetime annuity before 75 - purchase price
BCE 6: lump sum - amount of lump
BCE 7: lump sum death - amount of lump
BCE 8: overseas transfer - amount of transfer
BCE 9: adhoc payment - amount of payment
Benefits and drawbacks of a defined benefit pension
Benefits
Drawbacks
Benefits and drawbacks of a lifetime annuity
Benefits:
Drawbacks:
Benefits and drawbacks of flexible options
Benefits:
Drawbacks:
Definitions of:
List the transitional protections
Primary Protection
Min value to qualify: more than £1.5m April 2016
Level of protection: PP factor multiplied bye underpinned LTA of £1.8m
Contributions permitted: Yes
Restrictions: N/A
Lose protection of DB transfer: No
Enhanced protection
Min value to qualify: No minimum Level of protection: No LTA Contributions permitted: No Restrictions: N/A Lose protection of DB transfer: enhanced protection is lose if 'relevant benefit accrual occurs'. If a member with enhanced protection elects to transfer benefits from a DB scheme to an MP scheme they may lose protection
Fixed Protection 2012
Min value to qualify: No minimum Level of protection: £1.8m Contributions permitted: No Restrictions: Cannot hold if either PP or EP held Lose protection of DB transfer: No
Fixed Protection 2014
Min value to qualify: No minimum Level of protection: £1.5m Contributions permitted: No Restrictions: Cannot hold if PP, EP, FP12 held Lose protection of DB transfer: No
Individual Protection 2014
Min value to qualify: £1.25m as at April 2014
Level of protection: value of pension as at April 2014, subject to £1.5m cap
Contributions permitted: Yes
Restrictions: Cannot hold PP
Lose protection of DB transfer: No
Fixed Protection 2016
Min value to qualify: no minimum Level of protection: £1.25m Contributions permitted: No Restrictions: Cannot hold with PP, EP, FP12 or FP14 Lose protection of DB transfer: No
Individual Protection 2016
Min value to qualify: £1m as at April 2016
Level of protection: value of pension as at April 2016, subject to £1.25m cap
Contributions permitted: Yes
Restrictions: Cannot hold PP
Lose protection of DB transfer: No