Understand and describe:
1. Legacy rules for dealing with Pre-RDR business, in a post-RDR environment
2. FSA guidance around replacement business and centralised investment propositions
3. FSA pensions switching guidance
Robert Cochran, Key Accounts Development Manager, Scottish Widows
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Presenter: Welcome to this Akademia session. Today we have Robert Cochran, Key Accounts Pension Development Manager at Scottish Widows. In just a moment he’ll be covering three learning outcomes. He’s going to review the legacy rules for dealing with pre-RDR business in a post-RDR environment, and there does seem to be a lot of interest about that at this time. He’ll also then look at some of the FSA’s guidance around replacement business and centralised investment propositions. That’s still very very current. And to put it all in place he’s then going to recap on the FSA pension switching guidance. So those are the three main learning outcomes from this session. Let’s now go straight to Robert.
Robert Cochran: I’d like to start off with the issues around legacy rules. And the issues around legacy rules were not really clarified until February last year. FSA brought out a paper, PS12/3, and that was about the distribution of retail investments, RDR adviser charging and treatment of legacy assets. So it came quite late into the picture around RDR. And it made some pretty clear rules and some rules that were pretty difficult to manage. So the first thing is not a surprise to us, no commission payable for advice provided post-RDR on legacy products. I say not a surprise to us but as the initial rules from RDR came out we weren’t expecting this to apply to legacy products. A bit of a lobbying went on and the FSA decided to make the position perfectly clear, so no commission payable for advice provided post-RDR on legacy products.
That brings us into some issues around fund-based renewal commission and how that’s treated. So here’s clarification around some of the FBRC rules. First of all fund-based renewal commission can continue in a policy transfer to a new adviser, but it must be disclosed and the new adviser must offer service commensurate with the cost, so it’s not that different from ongoing adviser charging, it’s just that it’s still called fund-based renewal commission. The second thing is that we cannot simply, an adviser cannot simply turn fund-based renewal commission into ongoing adviser charging en masse. So when you looked at the rules that were coming in, that would probably have been an elegant solution for us as a provider to say let’s take all of our existing business and move that onto ongoing adviser charging. But that breaks one of the principles of ongoing adviser charging, and that is that it’s a relationship between the adviser and the customer, setting out an agreement specific to the service that’s being offered on that occasion. So we cannot simply do that, and there’s no point in advisers writing in and asking us to do it for your booker business, it’s a unique relationship with each one of your customers.
The final thing I’d like to say about fund-based renewal commission is yes, if you buy someone else’s book then the fund-based renewal commission can be transferred across to that new adviser on a bulk basis. The new adviser must at least match the previous service offered. These are FSA rules, it doesn’t mean that that’s what will happen with every provider or every product, and as we’ve settled into 2013 advisers are beginning to realise that different providers and different products from different providers will be dealt with in different ways. And it’s important that you clarify those rules, but these are what the FSA have set out.
So let’s take it down a stage and let’s look at some of the exemptions. So we know what the intention of the regulator was, and we know what the headline is, but let’s look at the exemptions. The first and biggest exemption to legacy rules is group pensions. And it’s still pretty clear for group pensions any schemes that were set up pre-RDR, or where the advice was given to set these schemes up pre-RDR, and they were on a commission basis, then for new members and increments to those schemes commission can continue to be paid. There’s another whole set of questions about how consultancy charging will work, but as regards legacy policies they’re treated differently from individual pensions.
The next item down here we’ve got is indexation. So indexation will lead to clients having increments post R-Day, but the advice given which has led to those increments was given pre R-Day. So indexation means that the policy can continue on a commission basis. The most contentious issue around this whole paper is non-advised. So we know that any non-advised increments or non-advised changes to a policy will not disturb the commission that will sit in there. Now that won’t be true of every provider, but that’s the FSA rules. I’m going to come back to that in a couple of minutes, because it’s a real key issue.
Other areas where they relaxed a little when they brought out PS12/3 was they said if there’s a reduction in premium or amount then that will not disturb the commission which was payable on the existing plan. If the advice was to not change the product in any way then yet again that will not disturb the current remuneration structure on the plan. And then there was the whole issue around fund switches, so if the fund switches within a life and pensions wrapper then it can continue to generate fund-based renewal commission, and continue to operate in its pre-RDR way. However, if it’s outside of a life and pension wrapper then it’s deemed to be an advice point, and that will switch off any fund-based renewal. And that’s really because fund-based renewal operates in life and pensions funds at wrapper level, whereas in things like ISAs and OEICs and other direct investments, that would be generated at the fund level rather than the wrapper level. So that’s why they took life and pensions out of this.
The whole issue of commission and legacy products has been getting a lot of coverage within the press, so if I go back to the end of January, in the consumer press we had BBC's Money Box programme, Paul Lewis reigniting the whole issue around trail commission. His suggestion was that many advisers were being paid trail commission and not doing a lot for it. That ignited another whole debate, so we had lots of adviser input, we had consumer input, and we had various media commentators. I was quite interested in this article here which appeared in Financial Adviser at the beginning of February, and it was a suggestion that advisers should consider pulling the pull on trail. What John Lapin, a commentator, goes on to discuss here is the idea that trail may disappear within three years, certainly not our viewpoint but you have seen some specific investment houses decide that they’ll switch it off on the all the products. Not really happening in the mainstream, amongst the bigger providers, but it does happen at some product levels.
So should they consider pulling the plug on trail? Well let’s again go on to have a look at that in a bit more detail. Certainly we’ve seen various providers say that for some of the product lines they’re going to have to restrict how trail is paid, or restrict it completely. The most viewed item on some of them in financial media has all been about how legacy products are treated. So let’s go and have a look at an individual case, so let’s look at an example case and see what different options might arise. So I have a client here, he’s in a stakeholder type plan. It’s a £50,000 investment or £50,000 fund value, it was a 1% annual management charge that was taken on it and 5% initial only, so no trail being paid, it’s just sitting there with a 1% annual management charge, as most stakeholder pensions are. Reduction in yield would be 1.1% with a rounding.
So this client wants to make a £10,000 increment to the plan, what are their options? Well we know that if that £10,000 increment comes in as non-advised then our default would be to pay out commission on that at whatever the level the original plan was set up as. And that seems to be the way most providers are working, and seems to be the recommendation as to how we deal with that business. It might not seem right because it seems like the adviser’s been paid some remuneration for not giving any advice, yet we find that the majority of our increments that come in around the time of the tax year are all non-advised, they’re directly in from the client. What we will do is write back to the client and say we’ve assumed this is non-advised, is that accurate? If it’s not they will write back into us and we will change the terms of the policy.
So what in fact if it’s an advised piece of business? So it’s an advised piece of business, what are your options? Well if it’s a stakeholder type plan you will struggle to find many stakeholder plans which have adviser charging built onto them. We know that commission can’t be paid, but they may not have the functionality to do adviser charging. And the very nature of a stakeholder pension plan made it almost impossible to do initial adviser charges. So if you can’t do adviser charging what’s the option? Well the option is to charge a fee outside of the plan. So for the £10,000 still to go in, the advice to be given, and the client to then pay a fee on top of that, and some will choose will do that and some will not. So what if they do pay the fee outside of it, will there be a rebate in charges, will they get a reduced charge because no payment for commission has been paid from the plan? Well again that will depend on the policies. Some policies will do that and some will not. Some providers will do that across the board, some providers won’t. So it’s a really careful one to look at, and you might think that just seems unfair, but it’s something that the FSA recognise in their paper.
When they produced the guidance they went out and asked providers how much do you think it would cost just to deal with these adviser charging changes, and it was nearly half a billion pounds, so at that amount of money there was no way that the industry could do this to all of their products. And I was involved in how Scottish Widows responded to RDR, and how we responded to these changes, and how we’d have to treat our legacy business. And it wasn’t that straightforward, we had some business lines where you get lots of increments in and you’ll build some functionality in there, either to put adviser charging on or to have some kind of rebate functionality. You have some products where you were getting just a handful of increments in a year, and the cost of changing the plan would be in the hundreds of thousands, that just doesn’t make commercial sense and that’s why some providers have made the decisions they’ve made.
So clearly if there’s no rebate in charges then the adviser would need to look at that. A further question is can you even accept an increment? Some policies are no longer open to increments. I was with an adviser yesterday who was talking to me about a Trustee Investment Plan (TIP) proposition and explaining to me that a client had wanted to increment their Trustee Investment Plan and they were just told you cannot do that because we no longer have an ability to accept increments. The reason they can’t accept increments if because they can’t switch the commission off on the policy. So again it’s all around what the provider is able to do with those products. A final option, and an option which looks to be fairly well recognised, is putting the increment into a separate policy, so trying to link the original policy to a new policy, but the two policies are operating on a different charging structure. They’re trying to link them together but they’re on different charging structures, so that’s another whole area as well, the ability to accept the increment but into a separate policy. So it’s quite a difficult and it’s quite a confused situation, and I really feel for advisers trying to deal in this space just now. But to be fair it’s been driven by the late change in rules from the FSA.
So let’s have a look at this client here and see what other options might be available. And clearly another option that might be available is to move the entire policy to a better charged RDR friendly option, something which offers adviser charging within it, particularly if the customer doesn’t want to pay for advice outside of the plan. So in this scenario here let’s look at Scottish Widows Retirement Account plan. We’ll move the existing policy across to the Retirement Account plan, that brings a, in this scenario here it would bring a product cost of 0.3% and an investment cost, they’ve picked our most popular fund choice which is governed investment strategy, that comes with an investment cost of 0.1%. So that gives you a 0.4% product and investment cost. The existing policy was on a reduction yield of 1.1%. This would give you a reduction yield of around about just over 0.4%. So if we’re looking at adviser charging in this scenario here, I've just highlighted three different options, three different service models if you like.
First one here, adviser fee of 3% to conduct the pension switch, plus an ongoing adviser charge of 0.3%, so both in percentage, both set out in percentages, and the reduction yield there is 0.9%. The second option is for a different service model, and this service model the adviser says I have an ongoing adviser charge and my charge is represented in pounds and pence. So here again we have an adviser fee of 3%, which would be equivalent to £1,800 in this policy, plus an ongoing adviser charge of £300 per annum. Assuming it’s a 20 year term, that would give us an RIY of 0.91%. And I've dropped up another option there with a £400 per annum service charge. Again these all assume a 20 year term to retirement, if it was a different term then clearly it would be a different outcome, and we can simply calculate those figures.
So what do you have to bear in mind if you’re looking at any of these cases, where you’re looking at an existing pot moving to a new adviser charge model? Well all of the stuff which has come in the past around pension switching has to be considered. So let’s go back and look at what that guidance looked like.
[Pension switching and centralised investment propositions]
So the big thematic review of pension switching was in 2008. The FSA assessed 500 files, and what they found was that advice was unsuitable in 16% of cases. Well another way of putting that is in 84% of cases advice as appropriate and correct. But let’s focus on the poorer outcomes, where did people go, where did advisers go wrong, and where did people end up in a poor situation? The reasons they ended up, number one, overwhelming reason was taking on extra cost for no good reason. So they were put into a more expensive product, or a more expensive investment offering, and there was no good reason for that. 40% was funds not matching the attitude to risk. So attitude to risk was assessed and the funds that were selected ended up not matching that approach. In just over a quarter of the cases clients were paying for an ongoing service but the reason for them receiving that ongoing service was never explained to them. It wasn’t clear what they were paying for. And the final area that the FSA focused on was loss of benefit without good reason, so that could be giving up guaranteed annuity rates or any other kind of benefits that were on the existing plan which weren’t offered in the new plan. So it might seem like ancient history to be going back to 2008, but that thematic review was the biggest review of pension switching and has informed a lot of what’s come after it. So at that point in time 16% of cases failed, I’m afraid it just gets worse for every review that we look at thereafter.
The next review, exactly the same area, was quality of advice and pension switching. This time 251 files were assessed as opposed to 500, and this time the results were worse. Advice was unsuitable in 34% of cases, was unclear in 31% of cases, and was suitable in 35% of cases. That’s almost a third unsuitable, a third unclear and a third suitable. Admittedly when the FSA conducted this review they targeted firms that they expected would be more likely to fail, so they were higher risk firms. When we looked at the second review there was some new concerns that came, and these were around, they were almost like centralised investment propositions where advisers were picking their portfolios and clients were paying a little bit more to be in those managed portfolios. The other area was around tied advice, and tied advisers not considering existing pensions as a part of the overall advice. So that was 2008/2010. In 2012 the FSA produced some new guidance, and it was focusing around two things; replacement business and centralised investment propositions. They assessed 181 files, and I’m afraid the outcomes weren’t particularly great here either. Quality of advice unsuitable in 33 cases and unclear in 103. Quality of disclosure unsuitable in 108. So three out of four cases were questionable.
So this review and this report I think works in a pretty good way, because it gives you examples of poor practice and it gives you examples of good practice for firms that are undertaking replacement business or offering centralised investment propositions. So let’s remind ourselves of what the definition of a centralised investment proposition is. It’s merely a standardised approach to providing investment advice. And the examples that they look at are portfolio advice services, so where an adviser runs their own portfolios, or buys in some portfolio advice services from a third party and they put a number of their clients in on those similar portfolios. It could be discretionary investment management where they buy in a DFM or some form of discretionary mandates. Or it could be distributor influenced funds. But I like to look at it in its most simple format, all it means is that if you have two customers that come in your door, that look the same and feel the same, so in terms of their attitude to risk, in terms of their age and what they want out from the money they’ve got, they’re likely to get the same investment proposition from you. And the FSA’s keen to see that, because that shows that you’ve got a standardised approach in there, and it shows that you’re treating your customers fairly. However, the FSA felt that some firms had gone too far.
And if you look at some of the poor practice that they’ve outlined here, the first and most obvious one is shoe horning, where you have too narrow a range of investment options. You may have one size fits all, so every client that comes in your door gets the same investment offering. That’s clearly not going to be right, and that was one of the first things that it highlighted. Secondly they highlighted churning, where they saw adviser firms going to buy in or agree a centralised investment proposition, and then looking at everyone that they had in their books and moving them all onto that centralised investment proposition, whether it was in their best interests or not. The third area was additional costs, and they found that many of the centralised investment propositions that advisers put in place were potentially more expensive and potentially less transparent than the existing offerings, particularly if you look at something like discretionary fund management where it’s been quite difficult to make clear what all the charges are, and to present the charges on the same way that you might present them on say for example an insured fund. The fourth area was asset allocation process but no reviews. So you’re agreed where you’re putting them in, customers in at the start date, but there’s no clear guidance as to how they’ll be rebalanced on an ongoing basis to continually match that asset allocation.
So those were some of the poorer outcomes that the FSA identified. But what I think is really good about this paper is how they clearly identified good outcomes as well. So let’s have a look at good practice, and none of this is rocket science, it’s fairly straightforward, most firms will be doing this right now. So several firms segmented their client bank effectively, and designed appropriate solutions to cater for each segment. So that way you’re avoiding the shoe horning approach, you’re making sure that your customers and your clients are in appropriate investment solutions for them. A second area of good practice was actually why not review your clients’ needs before you develop your centralised investment propositions. You might look across your client bank and see various chunks that might operate in similar ways, and then design centralised investment propositions for them, rather than buying in centralised investment propositions or creating them, and fitting your clients into them. And a third area of good practice, and again it’s common sense, is to have a different transactional offering for clients where a centralised investment proposition is not suitable, maybe those that don’t want an ongoing level of service for example.
So bearing all that in mind, and looking at Scottish Widows Retirement Account, what I've done is create a simple version which brings some of this stuff to life. So if we look at this graph here, we’re starting off with a graph which I would imagine would be able to represent most advisers’ client banks. And those two red lines on it, so we see them running up to a point there, in the bottom left corner we’re saying you’re likely to have more clients that sit in that space, and you’re narrowing up in terms of the number of clients, so when you get into clients with over £250,000, probably got not as many clients in there, and you’re probably going to find that they need a different advice requirement to those that sit in the bottom corner.
So let’s take you through that. If I start off in the bottom corner there, we’ve got Governed Investment Strategy, and Governed Investment Strategy is a lifestyle investment option. It’s very keenly charged, and it means that you can put clients in there and they will see automatic rebalancing and moving to safer assets as they progress towards their retirement stage. So that might serve a certain segment of your clients for whom ongoing advice is not necessarily required, or for whom require a different more minimal touch offering. So Governed Investment Strategies sit there perfectly within that space. And that interestingly is the area that lots of advisers thought they might struggle to serve post-RDR. So there’s an offering that sits in there.
So for the next stage along, clients that are requiring something a bit more sophisticated, are looking for some level of ongoing advice, then we might have something like multi-manager funds. So they bring rebalancing to the picture but they don’t bring any reassessment of whether it’s an appropriate risk strategy for you going forward, they don’t move you into safer assets. So certainly requires more involvement from the adviser, but it’s still a relatively straightforward proposition that does bring you the benefits of rebalancing. The next element we’ll look at is those where it’s really active management, and these are where you’ve very often seen advisers design their own centralised investment propositions, so they’ve maybe got preferred portfolios that they use, they may be doing rebalancing quarterly, they may be selecting and reassessing the funds. I've come across a number of advisers who do that either on a quarterly basis or a half yearly basis, assess whether the funds that are in those portfolios are appropriate, and then go ahead and recommend switches on that regular basis. So there we have adviser preferred portfolios, and I've put in a typical cost there of 1% to 1.5% as the expense ratio there.
And finally in that top corner I've put in discretionary fund managers. I've put in an expected total expense ratio there of 1.4% to 2%. And they would see very active management, and they’re likely to only be more appropriate for people with significant assets. It’s up to you as advisers to decide where you draw those lines. But that’s a relatively straightforward interpretation of what the FSA’s come up with for segmenting your clients.
So that’s around the centralised investment proposition, the second part of that FSA paper was all about replacement costs. Big headline there, and no surprise I’m sure to most advisers, we expect firms to consider the issue of cost for all recommendations. The most common reason for unsuitable advice in both the platform review and the pension switching review as we’ve seen, was unnecessary additional costs. If you look at the reviews we’ve looked at already, they were just focus around pensions. This one’s bringing all replacement products into the same space, so it could be bonds, it could be any other type of investment that you might hold. This isn’t just about pensions. The FSA expects to see a cost comparison between the two solutions. And that’s sometimes been challenging to do, and part of the reason it’s been challenging because different providers, even where you’re choosing the same fund will have different growth rates, and that makes it difficult to make those comparisons.
Another clear identifier that they brought out here was that firms should disclose any additional costs in a fair manner, and it should also disclose extra cost like trading charges. And that’s where discretionary fund managers have found it hard, because they don’t have a set portfolio. You go in, you’ll get a specific portfolio built for you, they don’t know at the outset how frequently the trading is going to take place. But what the FSA is saying is they need to find a way to explain that, that customers can understand, and that will allow you to contrast that with an insured fund offering for argument’s sake. And you’re seeing some progress there from discretionary fund managers, and it’s certainly something that we’ve always required on the Retirement Account, that they product a total expense ratio so that we can compare it with our other fund offerings.
Now the FSA are not saying you cannot recommend a more expensive product, because clearly there’ll be times when that’s right. It might be a completely different advice offering to what they had previously, a different service offering. So what they’re saying is that where additional costs apply firms must judge whether they’re suitable in light of the needs and objectives of a client. So look at your client specifically, is it the right thing for them, can you justify it, does it make sense, will it all fit down in the reasons why letter, well fine, you can still recommend it on those occasions. Just like they did with centralised investment propositions, the FSA has recommended good practice here, and good practice might look like this. Several firms use reduction in yield figures in cost comparisons. This takes into account both the initial costs associated with recommendations and the ongoing costs. And some also use cash values to explain the cost impact, whereby you look at different illustrations at retirement or whatever the chosen point was.
Now that will be pretty familiar to most of you that use third party software like ONM or Select a Pension to review your pensions, all the FSA are saying is you should also bring that into any other replacement propositions that you’re looking at.
[How are we seeing advisers manage the current challenges?]
Handily when you’re looking at Retirement Account type plan versus existing business, we have a comparison tool which is really easy to use. It’s a really straightforward comparison tool and you don’t need to have any login details to use this, you just go onto our extranet site, go onto that extranet site, look under the tool section and you’ll find the Retirement Account comparison tool. And this allows you to carry out some of that best practice from the regulator. So most importantly it calculates an RIY, reduction in yield, on the existing plan and the new plan. Your starting point for this is you’ll probably have an annual benefit statement. The annual benefit statement won’t have a reduction in yield figure on it, but what it will have is a current fund value or transfer value, a projected one at retirement, and it’ll have a growth rate. And from those different bits of information we can very, very quickly calculate a reduction in yield figure.
Now this will not replace a third party system like Select a Pension or ONM, because it’ll only do a comparison with Scottish Widows Retirement account. But what it brings to the table is it’s very, very quick and easy to use. So a minimal number of inputs will get you to a very quick RIY calculation and a quick go/no go decision. It’ll also help you with that fund specific illustration rate issues, because it’ll allow you to illustrate two funds forward on your selected growth rate rather than have two funds operating in different growth rates. So it’s a fantastic tool, available to you right now, there’s just an example of an output from it, and from this you’ll probably be able to see that the client, we had a transfer amount, we had a projected value and we had assumed growth rate. The adviser was recommending a fund going forward which was on a different growth rate, and what we’ve done there is project them both forward in the 6.5% growth rate. So it’s available to you, it’s very simple, very easy to use, and very straightforward.
If I look here I can see that number one fund holding is Consensus Mixed Fund. And it’s been around for the duration that the retirement account’s been launched. But those three funds that I've highlighted in yellow, at the point of taking these figures they’d only been available for two years. And these are the lifestyle investment options, and these are where we’ve seen by far the biggest fund inflows going into them. What I can also see is the total expense ratio, year on year on year if I take the top 10 fund holdings, put 10% in each one, what would my total expense ratio look like? Well each year it’s come down to this point at the end of 2012 where it was only 0.37% total expense ratio. So I’m seeing clear evidence that advisers are selecting funds which are generally lower cost, which again fits in with some of the replacement product guidance from the FSA. And think about that attitude to risk piece. If you’re selecting one of the Governed Investment Strategies, you have a very simple risk profiling tool you can use. The customer can use it themselves. Ask them ten questions, the questions aren’t overly sophisticated but they’re simple and easy for customers to use and you can do a clear mapping that they’re in a fund solution which is appropriate to their attitude to risk.
So there’s a number of other things that have helped to influence, a number of other things that we’ve seen in terms of trends in the market just now. And one of those things has been a drive towards e-commerce, more and more advisers dealing online. And in fact we saw over last year, the start of last year, 8% of the new business we got into Retirement Account was online, at the end it was about 47%. And that tells us that we were actually slow coming to market, because we brought in a number of e-commerce improvements over the course of the year. We can now accept completely signature free applications. We also listened to you and you told us about Origo Options Transfer Services, saying that they were a simple way for you to carry out pension switch business. And we’ve introduced that in January as well. And since we brought that in our service standards for pension switches has come down significantly. We now have a 10 day SLA, and recently we just had a case that went through in four days. So that’s gone from a position where you were looking at three to four weeks to do it all on paper, to doing it through the Origo Options process and it’s significantly quicker, improving cash flow and improving profitability.
A third thing that’s happened recently is we’ve introduced the ability to do online reports for existing customers. So many of those advisers that are telling us they’re going down things like governed investment strategies are still offering an ongoing service, and that ongoing service might look like every six months you provide them with a report which gives them a split of where their investment is geographical etc. You can now do that at the touch of a button, previously it took an awful lot more time with us but now it’s very straightforward to do. And my middle item here is I've got a bunch of letters, why have I got those letters there? Well those letters are some support letters we produced to help you re-engage with your clients. So if you’re looking at existing clients and you’re looking at your new advice model, and thinking about some of them that you haven’t been able to engage with on that new adviser charging approach, well here’s some support that can help you. So you can access all of that stuff and more information through our website.
I’m going to finish off just by reminding everyone of what the learning outcomes of this session were. So first of all we carried out a review of the legacy rules for dealing with pre-RDR business. Secondly we gained an understanding of the key issues and findings of the FSA report from last year, their guidance around replacement business and centralised investment propositions. We looked at both good practice and bad practice. And we wouldn’t be able to look at any pension switching without going back and reminding ourselves of the main rules and the main findings of the FSA pension switching thematic reviews of 2008 and 2010.
Presenter: Thank you Robert. I’m sure this has been a really useful. Legacy business is a big issue, and there’s plenty of business out there for advisers in addressing old legacy issues and bringing them up to the new RDR world.
I hope you found this Akademia session useful please look out for further accredited CPD from Akademia and Asset.tv.
In order to consider the viewing of this video as structured CPD you must complete the reflective statement to demonstrate what you’ve learned and it’s relevance to you. This session has covered the following learning outcomes and key points:
1. The legacy rules for dealing with pre-RDR business in a post-RDR environment.
2. FSA guidance around replacement business and centralised investment propositions
3. FSA pension switching guidance.
Please now complete the reflective statement to validate your CPD.
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