This means that a Pension Transfer and Opt Out PTOO licence will be required in order to transfer them even at the point of retirement.

It now transpires that some providers are interpreting the rules such that Protected Tax Free Cash is a safeguarded right.  The implications are that if the TFC is safeguarded, then it becomes a transfer, and requires specialist permission from the FCA.  If this is their interpretation then there is little point arguing over whether or not they are right.  We think most of us will just then say, “well I need Pension Tfr permissions then”   And remember you do not have to include the occupational permission requirement, it could be a permission restricted to non-occupational safeguarded transfers.  And a transfer simply to buy an annuity is excluded. 

The biggest thing in retail financial services today is the providers are acting as policemen, and that is leading to inconsistent rule interpretation and in places like this arguably gold-plating of the original rules. 

The argument you can all have in your offices is this. 

Is protected tax free cash a safeguarded right?
It is an academic discussion because if as we are being told, some providers are refusing to act even for the qualified, just because they don’t have the correct FCA register entry of permissions – then they must pay the FCA fee of £500 to upgrade their permissions to carry on doing what they have been doing.

IFAC upgrade permissions for all members for no extra cost. The FCA charge £500.
Contact charlie.palmer@ifac.eu for more information – mentioning this email of course.

The current standard to get a pension transfer application approved with the FCA seems to be around 18 Weeks.