Advising on DB to DC transfers

The following Pensions practice note provides comprehensive and up to date legal information covering:

  • Advising on DB to DC transfers
  • The definition of 'appropriate independent advice'
  • Legal definition
  • FCA position
  • Who can advise on the conversion or transfer of pension benefits?
  • FCA authorisation requirement
  • Pension Transfer Specialists
  • FCA framework for advising on the suitability of a transfer
  • Starting assumption that transfer is unsuitable
  • ‘Appropriate pension transfer analysis’ (APTA) from 1 October 2018
  • More...

Advising on DB to DC transfers

CORONAVIRUS (COVID-19) UPDATE: Until 30 June 2020, the Pensions Regulator (TPR) allowed trustees of DB schemes to suspend cash equivalent transfer value (CETV) quotations and payments. This was to give them time to review CETV terms and/or to assess the administrative impact of any increase in demand for CETV quotes. Since 1 July 2020, DB trustees are expected to report any breaches of their transfer obligations. TPR said it would continue to take a pragmatic approach to breaches caused by coronavirus issues, pointing out that trustees could take advantage of the legislative ability to extend CETV quotation deadlines by up to three months if the delay is due to reasons outside the trustees’ control.

As regards DB to DC transfers, TPR expects DB trustees to issue a letter template to all members requesting a CETV quote for the foreseeable future. The letter contains points for the member to consider before making a transfer decision. Moreover, DB trustees should actively monitor the number of requests for CETV quotes they receive and which advisers are supporting the members’ request. If the trustees identify unusual or concerning patterns, such as spikes in CETV requests or the same adviser across a multitude of requests, they should contact the FCA at

In parallel, the Financial Conduct Authority (FCA) has

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