FCA has reminded firms of the risks of accepting business from unauthorised introducers or lead generators. It stresses that authorised firms may be held responsible for unsuitable advice given by an introducer, and has noted with concern that an increasing number of introducers appear to have influence over how authorised firms run their business. It is also worried that firms are delegating activities, including their advice process, to unauthorised entities that are not appointed representatives, or to authorised firms that do not have the right permissions. It is particularly worried about advice on pension switching and transfers. FCA has listed specific issues that are of concern and asked firms to consider whether any listed warning signs apply to their business. It asks firms to tell it if they think they have been subject to these influences, or been approached for this type of business. Separately, FCA has set out its expectations of firms that advise on pension transfers. It wants firms to pay extra care when advising, and consider the assets into which clients’ funds will be invested on transferring or switching. It sets out what it expects firms to do when preparing and providing a transfer analysis. The guidance also covers how firms should react in certain circumstances, for example where a client is set on ignoring advice, or where transfers are being made to overseas schemes. It also notes the COBS requirements for advice that constitutes a personal recommendation.
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