Technical insights
Technical commentary on pensions rules, ongoing advice, remediation and dispute resolution, written for compliance, risk and operations leaders.
1 November 2026 , 11 min
Principle 12 asks for contemporaneous proof of customer outcomes. Activity statistics, dealing SLAs and a green dashboard do not provide it.
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1 November 2026 , 9 min
A 48-hour dealing SLA can hide three or four weeks between a drawdown instruction and cleared money. That gap is a foreseeable-harm question under PRIN 2A.2.
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1 November 2026 , 8 min
The Money Purchase Annual Allowance starts when taxable income is paid. The scheme administrator then has 31 days to tell the member. A document sitting in a portal is not that notice.
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1 November 2026 , 8 min
A flat trustee fee that is trivial on a large SIPP can consume several % of a residual pot. PRIN 2A.4 looks at that cohort, not the average charge across the book.
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27 October 2026 , 11 min
A practical account of high-stakes complaints: eight-week final responses, DISP 2.8 time-bars, preliminary-view rebuttals and redress modelled to the FCA benchmarks.
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26 October 2026 , 4 min
A complaint about advice given eight or ten years ago is often a jurisdiction question before it is a suitability question. DISP 2.8.2R is the test.
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26 October 2026 , 4 min
An adverse preliminary view is not the decision. It is a document that can be taken apart where it uses hindsight or misreads the product.
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26 October 2026 , 4 min
The eight-week letter is the brief the Ombudsman will read. An apology that concedes a breach is very hard to row back.
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26 October 2026 , 4 min
A signed risk questionnaire does not answer a complaint about losses. Capacity for loss, recorded at the time, does.
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26 October 2026 , 4 min
A dealing backlog at the platform is not, by itself, an advice failure. The timeline shows who had the instruction, and when.
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26 October 2026 , 4 min
Consumer Duty language in a complaint about pre-2023 advice does not rewrite the rules that applied on the day. DISP 3.6.4R keeps the case in its own time.
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26 October 2026 , 5 min
When a SIPP asset fails, the operator's duty and the adviser's duty are not the same duty. Adams v Options UK does not merge them.
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26 October 2026 , 4 min
A falling complaint count is not root-cause information. DISP 1.3 and the Consumer Duty board report ask what kept going wrong.
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26 October 2026 , 4 min
Money in minus money out is not a pension redress calculation. FG17/9 and DISP App 1 require the position the client would have been in.
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26 October 2026 , 4 min
A Month 1 tax code can withhold thousands on a first drawdown payment. Most of that money is reclaimable. It is not automatically redress.
Read article 26 October 2026 , 4 min
A demand for £5,000 to £10,000 of upset, attached to an ordinary delay, sits outside the Ombudsman's published bands. The log is what places the case.
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22 October 2026 , 12 min
A forensic file review tests defined benefit transfers, high-risk SIPPs and ongoing charges against COBS, SYSC and the Consumer Duty, before a regulator or ombudsman does.
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20 October 2026 , 6 min
The unregulated introducer model has driven SIPP provider failures and FSCS levies for two decades. Toxic funnels leave repeatable footprints that a structured red-flag audit can find.
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18 October 2026 , 6 min
In bespoke SIPPs holding property, unquoted equities or loan notes, pension flexibility is often theoretical. Crystallising benefits without a clear cash pathway creates operational drag, Consumer Duty breaches and complaints.
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16 October 2026 , 5 min
Commercial property in a SIPP or SSAS sits under intense HMRC scrutiny. Breaching the 50% borrowing cap or tolerating connected-party rent arrears triggers punitive unauthorised payment charges.
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14 October 2026 , 5 min
Labelling illiquid investments as standard assets suppresses a SIPP operator's capital requirement on paper. A forensic liquidity audit tests every asset against the 30-day gate.
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12 October 2026 , 6 min
An execution-only disclaimer no longer shields a SIPP operator. After Adams v Options UK, reviewers ask whether the operator actively vetted the asset and the distribution channel before accepting it.
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10 October 2026 , 5 min
Abridged advice can only ever produce two outcomes. Firms that blur the boundary into full advice risk breaching the contingent charging ban and issuing invalid Section 48 confirmations.
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8 October 2026 , 5 min
The FCA reviews defined benefit transfer books with the DBAAT, not narrative impressions. A single gate failure on capacity for loss or information gathering can render the whole advice outcome unsuitable.
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6 October 2026 , 4 min
Employer covenant weakness is often used to justify an otherwise unsuitable defined benefit transfer. COBS 19.1.2DG sets clear limits on how scheme solvency and PPF compensation are presented.
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2 October 2026 , 5 min
Cashflow modelling is one of the most heavily scrutinised parts of a defined benefit transfer file. Optimistic stochastic models are often used to paper over structural cracks in transfer sustainability.
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