DB Pension Advice for Insistent Clients

As one of the leading specialist pension bureaus in the UK, we are often asked our policy on insistent clients.

We do deal with insistent clients as long as they meet our criteria. You will find an outline of our process below.

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How our advice works

In most Defined Benefit advice cases, it is usually in the best interests of the client to retain their DB pension scheme for the secure benefits it will provide them in retirement.

One of our core principles is that we will not give advice that goes against the best interests of the client. However, some clients will wish to disregard our advice and proceed with a transfer.

If our Full Advice is to "maintain" the DB scheme, our policy is that we will accept an "Insistent Client" pension transfer request provided it passes our compliance requirements and follows the process outlined below.

What is an "Insistent Client"?

  1. Someone who receives a personal recommendation from an FCA-regulated firm
  2. They decide to proceed with a transfer even if the firm's recommendation says otherwise
  3. They want the firm to facilitate the transfer

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Our insistent client process


Full Advice has to be Delivered

The initial stage of our process is Abridged Advice, however, the client can only be determined as insistent once we have delivered our Full Advice recommendation at the end of the process. The client would have to inform their adviser that they wish to progress beyond the Abridged Advice stage to the Full Advice stage and commit to our fee, regardless of the Abridged advice outcome.


Objections and Considerations

If the client raises objections against a maintain recommendation during the advice call, and insist they want to transfer their pension, they will be asked to carefully consider the Suitability Report, and the disadvantages of transferring, at which point the client’s file is then automatically closed. Once the client has had ample time to digest the advice, they may contact Pension Works again if they still wish to pursue the insistent client process.


Insistent Client Factsheet

The company provides an "Insistent client factsheet" that explains the consequences of going against the recommendation. If the client insists on proceeding against our recommendation, they must provide their reasons and instructions in their own words.


Compliance Assessment

The case is then referred to the Head of Compliance or a senior Compliance Adviser who will ensure the client is fully informed and assess their circumstances, knowledge, and experience. If the client is not capable of understanding the risks and disadvantages, the company will refuse to facilitate the transfer.


Revised Suitability Report

A revised Suitability Report is prepared, highlighting the reasons for the change, the impact of disadvantages, and clear risk warnings. The original recommendation is restated and emphasised. Transactions will only be facilitated with FCA regulated providers and mainstream investments within the UK to ensure the protection of clients' funds.


Client Acknowledgement

The Suitability Report explains that the transfer is not recommended and outlines the risks associated with the client's proposed course of action. The client acknowledges this in a disclaimer form, providing their own explanation for proceeding against the recommendation.


Study and Advice Call

The Suitability Report is emailed to the client, who is given time to study it. An advice call will then reiterate that the transfer is not in the client’s best interests and is only being facilitated on their instruction.


Proceeding with the Case

If the client still wishes to proceed, the case continues as per the standard DB process, with all calls recorded and saved in the CRM system along with relevant documents.

Insistent client acceptance criteria

We will not accept insistent clients for the following reasons:

Unable to demonstrate an understanding of the guarantees that would be lost and the risks of transferring.

If the transfer would cause a shortfall in retirement income needs, a substantial lifetime loss or any financial irresponsibility.

Objectives that are vague, lacking in depth, unclear or of questionable importance.

Any suspicion of being coerced to pursue the insistent client process.

A request to transfer to an unregulated product provider or investment.