This document summarizes a workshop discussing proposals to improve the timeliness of pension and investment transfers between financial institutions in the UK. Key discussion points included clarifying the definition of a "step" in the transfer process, exemptions to the proposed 48-hour standard for completing each step, data needs to monitor industry performance, and implementation timeframes. The group aimed to draft an industry statement by end of 2017 outlining the scope, exemptions and timelines for adopting the 48-hour standard across different parts of the financial sector.

1. IMPROVING PENSION
AND INVESTMENT
TRANSFERS AND
RE-REGISTRATIONS
Workshop A: Platforms,
Off-platform SIPP
providers, Wealth
Managers, TAs,
Custodians, Banks and
Fund Managers
15 August 2017, 1030 - 1230
• The Association of British Insurers
• The Association of Member Directed Pension
Schemes
• The Investment Association
• The Pensions Administration Standards
Association
• The Pension and Lifetime Savings Association
• The Personal Investment Management and
Financial Advice Association
• The Society of Pension Professionals
• The Tax Incentivised Savings Association
• UK Finance
• The UK Platform Group

2. 2
THE PENSIONS AND INVESTMENT LANDSCAPE
Insurers
30+ firms
Third-party
administrator
25+ firms
Public sector
DB
in-house
220+ schemes
Master
trusts
70+ trusts
Private sector
DB
in-house
8,600+
schemes
30 million
pension
pots
18 million
pension
pots
11 million
pension
pots
6 million
pension pots
7 million
pension
pots
SIPP /personal
pension
130+ firms
4 million
pension
pots
Platforms,
Banks and
Stockbrokers
360+ firms
2.6 million
stocks and
shares ISAs
and ? GIAs
Over 60 million individual policies and accounts in the UK

3. STAKEHOLDER ENGAGEMENT TO DATE:
• Two stakeholder events:
o August 2016: 84 attendees from 58 organisations
o December 2016: 52 attendees from 46 organisations
• Two solution provider workshops
o July 2016: 14 individuals from 9 solution providers and the
UK Electronic Transfers & Reregistration Group
o August 2016: 14 individuals from 8 solution providers and
the UK Electronic Transfers & Reregistration Group
• Consultation process:
o December 2016– January 2017: 44 responses from
firms, trade bodies, and consumer advocacy
organisations.
• Four industry workshops in August 2017
o Workshop A: 45 attendees registered
o Workshop B: 16 attendees registered
o Workshop C: 10 attendees registered
o Workshop D: 11 attendees registered

4. THE SCALE OF THE CHALLENGE
Asset variable:
• Onshore Mutual Fund
• Offshore Mutual Fund
• Restricted Mutual Fund
• Equity
• Government Bond
• Corporate Bond
• Structured Product
• Physical
• Annuity
• Insured Fund
• CFD & Other Exotic
• Cash (Sterling)
• Cash (Not Sterling)
• Cash (Term Deposit)

5. THE SCALE OF THE CHALLENGE
Wrappers:
• Unwrapped (“GIA”)
• ISA/JISA
• Bond (on and offshore)
• DB/Final Salary Pension
• SSAS
• SIPP
• Insured PP/GPP
• Section 32
• Occupational Money Purchase (eg EPP)
After:
• removing illegal/impossible
• accounting for manual/automated
Total of 549 different processes

6. REVIEW AND CONSULTATION TIMELINE
2015: FCA undertakes Business Model and Sector Analysis of SIPP, Platform providers
December 2016: Consultation paper released
May/June 2016: Scoping
February 2016: FCA calls meeting with trade bodies
September 2016: Group reports back to FCA
June/July 2016: Consumer Research undertaken
November: Proposals discussed with FCA/tPR/DWP/HMT
July 2016: FSCP, FCA updated July/August 2016: The TRIG meets with solution providers
March 2016: TRIG formed
August 2016: Stakeholder event
December 2016: Stakeholder workshop
Summer 2017: The TRIG publish progress update, holds workshops
January 2017: Consultation closed

7. IMPROVING TRANSFERS AND RE-REGISTRATIONS: OUR PROPOSALS
1.Create clearer
service
expectations
2. Publish
management
information
3. Address
process
improvement
opportunities
4. Create
common
industry
standards
5.Intoduce an
independent
governance and
oversight body

8. SUMMARY OF PROGRESS UPDATE
1. Broad support for introduction of a standard for completing each step, but:
• Need to clarify definition
• Need to acknowledge exemptions
2. Broad support for proposed approach for collection of management information
3. Broad support for industry taking collective approach to addressing known barriers, but concern about overlap with
existing forums
4. Overwhelming support for development of one set of industry standards, and high level of support for multi-supplier,
interoperable model
5. Weak support for creation of a new independent governance body.

9. PURPOSE OF WORKSHOP
• To clarify the definition of a step
• To consider when the 48 hour standard will and won’t be
achievable, including when organisations should be exempted from
the 48 hour standard
• To identify how widespread such exemptions are likely to be, and
the likely impact of such exemptions on the experience of
consumers
• To consider when an end-to-end timeframe might be achievable
• To consider what high-level data should be collected on transfers
and re-registrations, and by whom
• To reconsider appropriate implementation timelines for different
parts of the sector

10. WHY A 48 HOUR ‘STANDARD’?
• Can be applied broadly across the whole sector.
• Enables each counterparty in a process to be equally accountable
for ensuring an efficient transfer and re-registration process is in
place.
• Ensures that organisations will not be accountable for the
underperformance of counterparties that are outside of their
control.
• Will highlight where there is scope for future improvements.

11. DEFINITION OF A STEP
The Consultation Paper takes a principles based approach to defining a step, in recognition that systems and processes
will vary between products and organisations.
• The proposed definition of a step is ‘the execution of a complete instruction received and the dispatch, where
necessary, of the next complete instruction.’
• For the purposes of measurement, each step in the process would begin at the point that an organisation can begin
processing, rather than when the organisation does start processing. Similarly, each step would be deemed complete
at the point when the relevant communication has been sent to the consecutive counterparty, to enable it to
commence the following step.
• This 48-hour window would comprise two business days, with a ‘business day’ defined as a day when the London
Stock Exchange is open. Each firm would process its step by 17:30 of the second business day following the day of
receipt.
• Exemptions would be allowed in the event of legitimate delays
For discussion:
• How can we clarify the definition of a step, without going down the route of detailing workflows for individual
processes?

12. EXAMPLE OF STEPS: STOCKS AND SHARES ISA RE-REGISTRATION
Step 1: Client completes
and signs transfer form, and
sends to acquiring party
Step 2: Acquiring party
receives, validates and
processes forms, and sends
discovery request to ceding
party
Step 3: Ceding party
receives, validates and
processes forms, and sends
valuation to acquiring party
Step 4: Acquiring party
receives valuation,
processes, sends
acceptance to ceding party,
and arranges transfer date
Step 7: Ceding party
processes confirmation on
client’s account, notifies the
client and sends ISA
declaration (and cash if
applicable) to acquiring
party
Step 6: Custodian receives
transfer request and
allocates to acquiring
party’s account
Step 5: Ceding party
contacts custodian/fund
manager to arrange
transfer to acquiring party’s
account (as appropriate)
Step 8: Acquiring party
processes confirmation on
client’s account and notifies
client

13. POSSIBLE EXEMPTIONS TO THE 48 HOURS (1)
Some steps will not be achievable within the 48 hour standard. Consultation responses highlighted the
following instances where more than 48 hours would be required to execute a step:
A. Where legislation requires a ‘cooling off period’
B. Where ceding provider is awaiting a contribution from a third party
C. Where multiple signatories could be required in order for a transaction to be agreed and authorised
D. Where disinvestment is required, and will take more than 48 hours
E. Where other party doesn’t agree to proposed timeline
F. Where there are unpaid fees
G. Where ceding firm has concerns about the legitimacy of advice received and/or the receiving scheme
For discussion:
• Are these reasonable exemptions?
• Are there other broad categories of exemptions?

14. POSSIBLE EXEMPTIONS TO THE 48 HOURS (2)
For discussion:
1. Within which wrappers, or asset classes, or in what circumstances, is an exemption likely to be
required?
2. For each issue above, when is the issue typically flagged (advisor, discovery, transfer, payment)?
3. How common are these issues – what proportion of transfers or re-registrations are likely to be
impacted?
4. How does the 48 hours map against existing workflows adopted within the industry (TeX/Origo SLAs)?
5. Are there some standard processes where an end-to-end timeframe is achievable in the short or
medium term?

15. INDUSTRY DATA NEEDS (1)
In addition to compliance with the 48 hour standard, the following information would assist the industry understand
the overall timeliness of transfers. This would need to be collected from organisations who have not signed up to the
initiative.
Possible data request:
• The number of transfers in and out, or transferred/reregistered (if intermediate counterparty)
• The value of transfers in/out, or transferred/reregistered (if intermediate counterparty)
• The average end to end timeline in/out for ceding and receiving parties
Organisations could also be asked to respond yes or no to the following high-level questions:
• Do you provide more granular data as part of the ‘improving transfers and re-registrations’ initiative?
• Do you use electronic solutions, and if yes, which?

16. INDUSTRY DATA NEEDS (2)
For discussion:
• Who should collect this information?
• How difficult and costly will this information be for
firms to collect and submit?
• Is this the most useful, high-level information for
industry to be collecting, to track its overall
performance?

17. IMPLEMENTATION TIMEFRAMES
The consultation feedback highlighted what we already knew: that different parts of the wider sector face different
challenges for improving transfers.
However, as consumers aren’t able to distinguish between the large number of different retail investment products,
and there is an increasing amount of transfers that are not intermediated, this is a industry-wide reputational issue
that requires an industry-wide solution.
For discussion:
• Within what timeframes is it realistic for different parts of the sector to adopt the 48 hour standard?
• When would firms be able to provide the information discussed in the previous slide?
• When should the industry look to publicly publish data on compliance?

18. NEXT STEPS
• Draft industry statement on scope,
exemptions, and implementation timeframes
for 48 hour standard by end of 2017
o Hold further workshop/s as required
o Test acceptability with FCA, DWP and
TPR
• Discuss industry data needs with FCA, DWP
and TPR in September
• Revisit governance arrangements at end of
2017