The whole basis of checks has shifted post CP17/16 (more info here: FCA ps18-06.pdf), so IFAC are looking to reshape their relationship with firms who pass Pension Transfers to us to check.
There are a few different scenarios that present new issues.
As IFAC read it… if they act as a Pension Transfer Specialist checking a file then we will need to do the following:
Now normally IFAC simply act on a file double checking process.
For PII purposes, IFAC suggest that checks include the above statements.
Better still, get those checks in Pre-sale,and if they are not perfect, get them re-checked a second time before sending to clients.
PII will expect this.
Full details and changes are being worked on by the PTOO team (Max, John & Mike) at present.