Compliance Calling 14th February
Written by Charlie Palmer on 10/08/2018

Deadline for Pension Individual protection 5th April

Individual protection 2014 (IP14) is for those with pension fund value of £1.25m as of April 2016, and gets you to keep that value as a lifetime allowance, subject to a £1.5m cap.  The deadline for applications for IP14 is the 5 April 2017.

Individual protection 2016 (IP16) is for those with pension fund value of £1 m as of April 2016, and gets you to keep that value as a lifetime allowance, subject to a £1.25m cap.  There is no deadline date for IP16.

You can have individual protection once only, if you don’t have primary protection or any other IP, and you can combine it with enhanced protection or any form of fixed protection.  You also lose it if you get divorced via a sharing order.
See more docs here 
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Technical Question

Assuming no Fixed Protection, if a member takes – via a BCE payment - a proportion of their life time allowance LTA three years ago and another proportion of their LTA today - which LTA cap applies to today’s BCE payment?
1. The one three years ago
2. The one today

Answer below written in french 
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 see pension drawdown and freedom packs available for purchase and download

la response est deux


Trump Administration issues Executive Order on financial regulation

On 3 February 2017, President Trump signed an executive order (EO) outlining the administration's core principles for financial regulation, which include:

  • Prohibiting taxpayer funded bailouts.
  • Fostering economic growth through a more a rigorous regulatory impact analysis
  • Enabling American competitiveness in domestic and foreign markets.
  • Advancing American interests during negotiations and meetings concerning foreign financial regulation.
  • Restoring accountability and rationalization of federal financial regulatory agencies.
  • Empowering Americans to make independent and informed financial decisions in the marketplace.

They say things cross the Atlantic.

FCA thematic review on Suitability Reports
The FCA have issued the first tranche of the Suitability Report Thematic Review.
One problem that has plagued the industry is high levels of unclear.
Four years ago all files were marked by FCA as SUITABLE, UNCLEAR or UNSUITABLE.
Three categories only.  It is instructive to note that the three categories introduced by the FCA have not stood the test of time.  Repeatedly in all the industry wide thematic reviews ever done by FCA more than half of IFAs files failed to pass as suitable. The vast majority of the fails scored unclear.

They now have two categories with three sub categories - so six in total!

  • Suitability is the first category: Suitable/unsuitable/unclear
  • Disclosure is the second category – with the same three sub categories.

This the FCA have done because they have a real problem with our industry. In all the previous thematic review the same number – about half – of all files show inadequate disclosure and were previously assessed as unclear. This the FCA criticised industry loudly about, but the figure barely moved in all subsequent reviews.  So - presumably to save embarrassment - the above fudge has been introduced.  Out of 1,166 files, no one has apparently been referred to enforcement.


From IFAC team - designers of Bat - the only specialist compliance management system available on the market for IFAs.

Charlie Palmer, John Downs, Mark Ellis, Andy Smith, Alastair Frame, Dan Rey, Ken Baksh, Andrew Wilkinson, Matt Duval and Nick Hall.
 

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