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Regulation requires that past DB transfer advice is reviewed for compliance with current rules. This is uncomfortable, particularly when the original advice was given in good faith. We have extensive consulting experience of DB transfer reviews and get the job done efficiently, robustly, and cost-effectively.

The current FCA consultation paper on the British Steel Pension Scheme (BSPS), CP22/6, makes the direction of travel clear: advisers will be required to review all BSPS cases rigorously using a process designed by FCA. Their Defined Benefit Advice Assessment Tool (DBAAT) is being modified for use with BSPS cases.

The DBAAT can be implemented by the firm itself to keep costs as low as possible, but this approach has significant risks if errors are made.


Senior managers are likely to be required to provide Attestation with personal liability under the Senior Managers and Certification Regime (SMCR), something that should only be taken on by managers with confident knowledge of the complexities of DBAAT and how it will be interpreted by FCA.

Although this consultation relates only to British Steel, it will undoubtedly serve as a precedent for all DB transfers.

We are able to undertake reviews of past DB transfers (whether British Steel or not) in an efficient manner using established methodologies that have satisfied the FCA.

How we apply them

  • Proven three stage approach:

    1. Information gathering

    2. Analysis

    3. Regular reporting to firm and FCA

  • Use of a modular database:

    • Customisable to different types of review

    • Runs either within the firm or in the cloud

    • Efficient QA and audit trail to satisfy FCA

    • Minimises need to refer back to customers

    • Manages critical communications

  • Assess suitability of advice

    • Calculate redress where appropriate

  • FCA Skilled Persons reviews

  • Proactive reviews to assist with gaining PI cover

  • Reviewing suitability of advice

  • Identifying Material Information Gaps (MIGs)

  • Compiling the DBAAT

  • Calculating redress under FCA Finalised Guidance (FG 17/9)

  • Liaising with FCA and gaining support for practical solutions

  • Senior quality oversight of all work (not charged)

Most of our work is confidential in nature so details cannot be published. We are happy to provide more specific information about work we have undertaken.

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