£ Scheme transfer checklist If a member is asking for a scheme transfer, you can use this checklist to find out more about the receiving scheme and ho...
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Scheme transfer checklist
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If a member is asking for a scheme transfer, you can use this checklist to find out more about the receiving scheme and how the member came to make the request.
Answering yes to any of these questions individually does not necessarily indicate a pension scam, but if several features are present there may be cause for concern. The nature/status of the scheme Is the scheme to which the member wants to transfer:
How to establish:
•
newly or not registered for tax purposes with HMRC, whether it is an occupational or personal scheme (including SIPPs)?
•
check the scheme is registered with HMRC for tax purposes: ask the pension scheme in question for documentary evidence of their registration. You can also write to HMRC for confirmation
•
a personal pension (eg a SIPP) where the scheme operator is not authorised by the Financial Conduct Authority (FCA)?
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check the scheme operator is authorised with the FCA (www.fca.org.uk/register)
•
a recently set up small self-administered scheme (SSAS), where the member is a trustee?
•
ask the member
•
sponsored by a newly registered employer?
•
•
sponsored by a dormant employer?
obtain employer information from scheme in question
•
sponsored by an employer that is geographically distant from the member?
•
check with Companies House for details of the employer status (www.companieshouse.gov.uk)
•
connected to an unregulated investment company?
•
ask the receiving scheme for details of their investment service providers
•
check these providers with the FCA (www.fca.org.uk/register)
Description/promotion of the scheme Do descriptions, promotional materials or adverts:
How to establish:
•
•
ask the member for copies of promotional materials, emails or letters about the scheme
•
ask the member about the way the receiving scheme has been described to them over email/ text/phone
include the words ‘loan’, ‘savings advance’, ‘cash incentive’, ‘bonus’, ‘loophole’, ‘preference shares’, ‘one-off investment opportunities’, ‘free pension reviews’ or ‘government endorsement’?
•
allude to overseas investments?
•
hint at unusual, creative or new investment techniques?
The scheme member Has the member:
How to establish
•
been contacted by an ‘introducer’?
•
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been advised by a non-regulated adviser?
ask the member about how he/she became aware of the receiving scheme
•
taken no advice?
•
•
decided to transfer after receiving cold calls, unsolicited emails or text messages, often from someone claiming to be from the government?
check whether the advisers are approved by the FCA at www.fca.org.uk/register
•
pressured the trustees/administrators to carry out the transfer as quickly as possible?
•
•
mentioned that your pension scheme has transferred funds to this arrangement before?
check whether the member has contacted trustees/ administrators to hurry along transfer since first submitting request
•
not received documentation from the new scheme?
•
check whether the member has received documents
•
been told they can access their pension before age 55?
•
review promotional material for receiving scheme
•
been told about the potential tax consequences?
•
been advised that there will be no contributions paid by themselves or the employer?
•
ask what the member has been told about contributions
Trustees and administrators should take care to ensure that they have the exact name of the scheme correct – in some instances, dummy schemes have been set up with names that are almost identical to legitimate schemes.
