Pensions technical oversight

Pension Switches, Consolidations & Transfer Suitability

Pension advice is where suitability failures are most costly and most permanent. Led by a CISI Level 6 pensions specialist (MCSI), we provide independent technical oversight across the retail pension spectrum, from defined benefit transfers under COBS 19 and DBAAT to multi-scheme consolidations, SIPP non-standard assets, UFPLS and flexi-access drawdown, testing whether every recommendation genuinely puts the client in a better position.

Every Switch Must Earn Its Justification

Consolidating pensions is often presented as simplification. For many clients it is. For others it means giving up valuable guarantees, moving away from employer contributions, or paying higher ongoing charges for a platform and investment proposition they didn't need. The FCA expects firms to be able to show why the switch was in the client's best interests, not merely that it was explained.

Our reviews test that justification at a technical level. We examine the ceding scheme as carefully as the receiving one: guaranteed annuity rates, protected tax-free cash, protected pension ages, death benefits, with-profits terminal bonuses and exit penalties. Then we compare the true cost and benefit of the recommendation against the client's objectives.

Where advice is sound, our review gives you evidence to defend it. Where it isn't, we identify the pattern, whether it lies in the adviser, the process or the proposition, so it can be corrected before it becomes a complaint book.

How a pension review runs

  1. 1 Ceding Scheme Analysis
  2. 2 Receiving Scheme & Cost Testing
  3. 3 Objectives & Suitability
  4. 4 Disclosure & Understanding
  5. 5 Findings & Remediation

What the review covers

A

Defined Benefit Transfers

Objective: Forensic assessment of DB transfer advice against regulatory standards.

  • File assessments under COBS 19.1 and the Defined Benefit Advice Assessment Tool (DBAAT).
  • Review of the appropriate pension transfer analysis (APTA), transfer value comparator and the client's capacity for loss.
  • Testing whether the starting presumption of unsuitability was properly addressed.

B

Switching & Consolidation

Objective: Testing the genuine customer benefit of moving out of ceding schemes.

  • Lost-guarantee testing: Guaranteed Annuity Rates, protected tax-free cash, protected pension ages and enhanced death benefits.
  • Charges comparison against lower-cost workplace arrangements, including the loss of employer contributions.
  • Assessing the suitability of the replacement platform, SIPP and investment proposition.

C

SIPP & Non-Standard Investments

Objective: Auditing due diligence where asset risk is highest.

  • Review of SIPP operator and adviser due diligence on non-standard assets.
  • Liquidity, valuation and concentration risk assessments.
  • Assessing whether the client could understand and bear the investment risk.

D

Decumulation & Retirement Income

Objective: Making sure retirement income advice is sustainable and tax-aware.

  • Reviewing UFPLS and flexi-access drawdown recommendations, cash-buffer strategy and withdrawal sustainability.
  • Tax-awareness testing: emergency tax on first payments, MPAA triggers and statutory flexible-access notices, and the post-LTA lump sum allowances.
  • Checking that clients were warned about foreseeable tax and income risks before crystallisation.

Why partner with us

  • CISI Level 6 Pension Transfers (MCSI)

    Peer-to-peer technical evaluation of complex DB transfers, SIPPs and decumulation strategies.

  • Former FOS Investigator

    We know how pension complaints are investigated and what makes a file defensible.

  • Operational Pensions Knowledge

    Experience owning the technical interpretation of pensions legislation for platform operations.

Is Your Pension Advice File-Ready for Scrutiny?

Whether you need a thematic review of pension switching advice, independent checking of DB transfer files or technical support on decumulation, contact us for a confidential discussion.