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WELCOME TO THE TAVISTOCK DB PENSION TRANSFER TRAINING DAY

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Presentation on theme: "WELCOME TO THE TAVISTOCK DB PENSION TRANSFER TRAINING DAY"— Presentation transcript:

1 WELCOME TO THE TAVISTOCK DB PENSION TRANSFER TRAINING DAY

2 OVERALL OBJECTIVES Understand the benefits payable by a defined benefit scheme Understand the pension transfer process Understand the key issues for pension transfer advice

3 UNDERSTAND THE BENEFITS PAYABLE BY A DEFINED BENEFIT SCHEME

4 INCOME FOR THE REST OF YOUR LIFE!
Secure income based on a promise laid down in the scheme rules Could be on a final salary basis or a career average basis Definition of pensionable remuneration can vary Accrual rate can vary The risk is taken by the scheme For a money purchase scheme the income depends on the approach taken, and the size of the pension pot at the time. The risk is taken by the individual

5 STATUTORY ESCALATION RATES
Accrual period Escalation 6 April 1978 – 5 April 1988 GMP only: Full CPI protection previously provided by the State – not anymore! 6 April 1988 – 5 April 1997 GMP only: Scheme pays CPI up to a maximum of 3%, any balance up to CPI previously paid by the State – not anymore! Pre-6 April 1997 excess over GMP No statutory requirement to escalate benefits in payment 6 April 1997 – 5 April 2005 The whole pension is increased in line with increases in CPI to a maximum of 5% per annum (LPI) 6 April 2005 – The whole pension is increased in line with increases in CPI to a maximum of 2.5% per annum (LPI)

6 PENSION COMMENCEMENT LUMP SUMS
Private sector DB schemes typically pay PCLS by commutation The commutation factor used may not represent a ‘good exchange rate’ DB schemes can pay PCLS using in house money purchase AVCs This may be less than the PCLS payable via money purchase schemes which typically pay 25% of the fund value when PCLS is taken This however may not be the case when remaining lifetime allowance is an issue or transitional protection applies to the PCLS

7 Pension x Commutation Factor 1 + (0.15 x Commutation Factor)
PCLS Pension x Commutation Factor 1 + (0.15 x Commutation Factor)

8 NORMAL RETIREMENT AGE This is usually the age the employee will take benefits The employee can however retire earlier or later They may or may not be able to continue to accrue benefits beyond the NRA Most schemes have equalised their NRA for men and women at age 65 Some haven’t however due to problems caused with equalising GMP

9 EARLY LEAVER OPTIONS For Defined Benefit Schemes
0-3 Months’ Pensionable Service 3 Months’ – 2 Years’ Pensionable Service 2 Years’ Plus Pensionable Service Refund of Contributions (short service refund) Yes Yes (unless a preserved pension offered instead) No Preservation of Benefits Yes (unless refund of contributions offered instead) Transfer Out Vesting Benefits From Age 55 For Individual Defined Contribution Plans Funds either remain invested or are transferred out

10 EARLY RETIREMENT It is generally possible to retire early in a DB scheme from age 55 – though the scheme rules need to be checked Early retirement will result in an early retirement factor/percentage reduction applied to the pension accrued as at the actual date of retirement, typically 0.5% a month Transferring to a money purchase scheme may improve the early retirement position In a money purchase scheme the ill-health pension will be determined by the member’s age, the size of the fund and the income/lump sum option selected (enhanced/impaired annuity rates may be available) Flexi-access drawdown allows unrestricted withdrawals during the member’s remaining lifetime

11 THE SCHEME’S ACTUARY MAY USE THE FOLLOWING APPROACHES TO CALCULATE A MEMBER’S SCHEME PENSION IF THEY RETIRE EARLY DUE TO ILL-HEALTH: The scheme pension could be based on service to the date of ill-health early retirement Or it could be based on prospective service to the scheme’s normal retirement age and the salary at the date of ill-health early retirement Or somewhere between the above two approaches In all instances there would be no early retirement penalty

12 SERIOUS ILL HEALTH COMMUTATION
Life expectancy less than 12 months The whole fund may be commuted for a lump sum using a commutation factor if life expectancy is less than a year The capital value of the lump sum is calculated using a commutation factor selected by the scheme trustees For DB schemes the entitlement only applies to uncrystallised/unused pensions Satisfactory medical evidence required from a registered medical practitioner Otherwise classed as an Unauthorised Payment Pre-75: Tax free lump sum up to remaining lifetime allowance Excess taxed at 55% 75 & over: Taxed as pension income under PAYE

13 DEATH BENEFITS In a DB scheme the scheme rules determine the death benefits payable These will differ pre- and post-retirement and whether pre-retirement the member is active or deferred, and if there is any GMP element Money purchase schemes offer greater choice and flexibility of options to the beneficiary

14 DEATH BENEFITS PRE-RETIREMENT
Active scheme member: DIS lump sum – could be directly from scheme assets or from a separate insured DIS scheme Spouse’s/civil partner’s/dependant’s pension – usually a percentage of the member’s remuneration at the date of death All continuing income benefits taxable on the recipient as scheme pension Any continuing income can only be paid to a dependant

15 DEATH BENEFITS PRE-RETIREMENT
Deferred members: Beneficiaries usually receive a percentage of the member’s preserved pension revalued to the date of death It is not common for defined benefit schemes to pay lump sum death benefits when a deferred member dies, as death- in-service benefits will cease when employment ends However, there are occasions where a scheme may pay a lump sum death benefit to a deferred member in addition to survivor pension benefits For example, member contributions may be returned

16 DEATH BENEFITS POST-RETIREMENT
There could be a guarantee period (max ten years, though typically five years) There may be a spouse’s/civil partner’s/dependant’s pension payable All benefits taxable on the recipient as scheme pension and continuing income can only be paid to a dependant

17 SIMILARITIES AND DIFFERENCES BETWEEN A DB SCHEME AND A DC SCHEME IN TERMS OF WHO DEATH BENEFITS CAN BE PAID TO ON THE MEMBER’S DEATH In both DB and money purchase schemes lump sum death benefits can be paid to anyone nominated by the member but payment remains at the scheme trustees’ discretion In a DB scheme a continuing income can only be paid to a spouse/civil partner/financial dependant/child of the member as defined by the scheme rules Whereas in a money purchase scheme a continuing income can be paid to anyone nominated by the member or the scheme administrator In a money purchase scheme, following the death of the nominee a successor can in turn inherit the remaining pension benefits

18 PENSIONS PROTECTION FUND
Compensation fund to protect existing and future pensioners of defined benefit schemes When employers become insolvent and the scheme is unable to meet its liabilities. PPF is funded by a levy on defined benefit pension schemes With a money purchase scheme the FSCS steps in if the pension provider fails and pays 100% of the claim, with no upper limit Member Overall Compensation Cap 100% All members who have reached scheme normal retirement age Ill health pensions Spouses pensions None 90% Other scheme members including Members under normal retirement age Early retirees receiving pensions 2017/18: £34, at age 65 (90% of £38,505.61)

19 UNDERSTAND THE PENSION TRANSFER ADVICE PROCESS

20 MEMBER’S OR SURVIVOR’S SAFEGUARDED BENEFITS > £30,000
WHEN IS ADVICE NEEDED? APPROPRIATE INDEPENDENT ADVICE NEEDED MEMBER’S OR SURVIVOR’S SAFEGUARDED BENEFITS > £30,000 FLEXIBLE BENEFITS If in any doubt then treat the benefits as being safeguarded

21 THE PENSION SCHEMES ACT 2015 DESCRIBES BENEFIT CATEGORIES WITHIN A SCHEME AS:
FLEXIBLE BENEFITS ARE MONEY PURCHASE BENEFITS, CASH BALANCE BENEFITS AND ANY BENEFIT WHICH IS CALCULATED BY REFERENCE TO AN AMOUNT AVAILABLE FOR THE PROVISION OF BENEFITS TO OR IN RESPECT OF THE MEMBER SAFEGUARDED BENEFITS ARE BENEFITS THAT ARE NEITHER MONEY PURCHASE OR CASH BALANCE BENEFITS

22 WHAT ARE SAFEGUARDED BENEFITS?
Benefits that are neither money purchase nor cash balance: A DB scheme pension – based on pensionable service, pensionable remuneration, and accrual rate A Guaranteed Annuity Rate – benefits are calculated by reference to the guarantee not just the plan value S32 policy containing Guaranteed Minimum Pension (GMP) – and so must guarantee to provide benefits at least equivalent to the GMP at SPA Guaranteed pension at retirement - a basic guaranteed pension increased by the addition of bonuses over time

23 APPROPRIATE INDEPENDENT ADVICE
Appropriate: the adviser is appropriately authorised and regulated Independent: of the scheme, and not necessarily an IFA; can be a restricted adviser also The trustees have a duty to check that appropriate independent advice has been received where the CETV exceeds £30,000 The trustee does not have to check that the advice is suitable

24 STATUTORY RIGHT TO TRANSFER
The member has a statutory right to transfer out: Exception = GMP Flexible Safeguarded enefits

25 THE STATUTORY PENSION TRANSFER PROCESS
Member applies for the statement of entitlement The trustees must inform the member of the need for financial advice within one month of the initial request The guarantee date must be set within three months of the initial request The trustees must provide the statement of entitlement to the member and inform them of the deadline for receiving confirmation of advice within ten days of the guarantee date The member must apply for the transfer in writing within three months of the guarantee date The member must provide proof of independent advice within three months of the date the statement of entitlement is provided to the member The trustees must make the transfer within six months of the guarantee date having already checked that independent advice has been received by the member

26 TYPES OF PENSION TRANSFER ADVICE
Pre-retirement advice: The client does not intend to access benefits within the next twelve months The focus is on capital growth over medium to long-term The critical yield will be more relevant At retirement advice: The client intends to start drawing benefits immediately or within the next twelve months Critical yield is less relevant Income and capital needs are accurately quantifiable

27 KEY STAGES IN THE ADVICE PROCESS
1 Establishing and defining the client relationship 2 Gathering client data and determining goals and expectations 3 Analysing and evaluating the client’s financial status 4 Developing and presenting the financial plan 5 Implementation of the financial planning recommendations 6 Monitoring and review

28 ESTABLISHING AND DEFINING THE CLIENT RELATIONSHIP
Necessary to establish the responsibilities of all parties: Who has the regulatory responsibility How the relationship will be conducted How the advice will be delivered Who the client should contact with any queries The tenure of the relationship Who will provide any ongoing advice

29 GATHERING DATA AND DETERMINING GOALS AND EXPECTATIONS
Hard facts – these are the factual details about the client’s personal and financial situation Soft facts – these are the client’s attitudes, beliefs, opinions and feelings

30 THE TWO ELEMENTS THAT COMPRISE A CLIENT’S ATTITUDE TO RISK
Tolerance for loss: This is the amount of risk that the client is willing to take. This will generally be based on the client’s previous experience, their understanding and knowledge of investments and risks, and their personality.

31 THE TWO ELEMENTS THAT COMPRISE A CLIENT’S ATTITUDE TO RISK
 Capacity for loss: This is the amount of risk that the client can take without their standard of living being affected. This should take account of: Timescale of the investment. The maximum amount of loss that can reasonably be absorbed by the client. The other assets the client may have access to.

32 THE SEVEN QUESTIONS SUGGESTED BY THE REGULATOR
Designed to investigate the subjective issues in relation to pension transfers: The security of pension funds Percentage of benefits Cash sums at retirement Early retirement Lump sum death benefits Spouse’s and dependant’s pension Risk and reward

33 MAIN DOCUMENTS TO OBTAIN
Statement of entitlement contains the CETV and information about the transfer value being offered The CETV notes provide useful technical information regarding the pension scheme The scheme member’s booklet sets out the terms and conditions of the scheme and provides scheme information relevant to the class of member Scheme funding booklet

34 ADDITIONAL IMPORTANT INFORMATION
If the member is deferred then a full breakdown of the deferred pension and how it is revalued is needed Details of the retirement options including commutation rate Details of death benefits pre- and post-retirement Details of early retirement Details of ill-health retirement Details of the financial security of the scheme including any recovery plan

35 ANALYSIS AND EVALUATION
The basis is set out in COBS 19.1 A transfer value analysis needs to be carried out typically using a TVA system (TVAS) – though this is not a regulatory requirement The benefits in the ceding DB scheme must be compared with the benefits available from a scheme that provides flexible benefits using reasonable assumptions

36 TRANSFER VALUE ANALYSIS
The FCA requires a comparison between the benefits likely to be paid from a DB scheme (or any other safeguarded benefits) with the benefits available on transfer to a scheme that provides flexible benefits This act of comparison is called a transfer value analysis The comparison must use assumptions laid down by the FCA in COBS The comparison must: Ensure there is sufficient information for the client to make an informed decision Draw the client’s attention to the benefits and drawbacks involved in transferring Be presented to the client in good time A Transfer Value Analysis System is usually used

37 ANALYSIS AND EVALUATION
The assumptions used in a TVAS are set out in COBS : Annuity interest rate – currently 1.3% Revaluation rates – currently RPI (2.5%) Indexation/escalation for RPI-linked schemes – currently 2.5% Indexation/escalation for CPI-linked schemes – currently 2.0% Mortality based on 2012 UK National Population projections

38 THE TVA COMPARISON SHOULD…..
The FCA states in COBS that the TVA comparison should: Demonstrate that the firm has taken into account all of the client’s relevant circumstances; Examine the benefits and options available under the ceding scheme, and the effect of replacing them with the benefits and options under the proposed scheme; Explain the assumptions on which the analysis is based and the rates of return required to match the benefits being given up; Use rates of return to illustrate potential benefits which take into account the likely expected returns of the assets in which the client’s funds will be invested; and Compare the benefits available at normal retirement age under that scheme where an immediate crystallisation of benefits is sought prior to that age.

39 SUITABILITY Rules relating to suitability applicable to any investment advice are found in COBS 9.2 with additional guidance relating to pension transfer advice in COBS 19.1 The starting point is that a pension transfer, conversion or opt-out would NOT be suitable for the client Firm needs to demonstrate clear evidence why such a change would be in the client’s best interests Advice should be in writing

40 SUITABILITY On 3 October 2017, the FCA issued an update to its work on DB pension transfers to assess the advice consumers are receiving from firms and whether they are at risk of harm The FCA had concerns regarding the suitability of transfer advice provided to clients: in 88 cases where the recommendation was to transfer, the FCA found that 17% were unsuitable, and in a further 36% of cases it was unclear if the recommendation was suitable the recommended product and fund were found to be unsuitable in 24% cases, and not clearly suitable in another 40%. As a result of the FCA’s DB transfers assessments, four firms have chosen to stop advising on DB transfers, with its wider work on scams leading to 32 firms choosing to stop providing advice or deciding to limit their pension transfer activity.

41 SUITABILITY The FCA is concerned that many firms had designed processes and procedures which result in transfers where the suitability of advice could not be established by the firm. This included firms: failing to obtain enough information about clients’ needs and personal circumstances failing to consider those needs alongside the client’s objectives when making a recommendation not making an adequate assessment of the risk a client is willing and able to take in relation to their pension benefits. In some cases, advisers had failed to make appropriate comparisons between the DB scheme and the intended receiving scheme. The findings from this work informed the FCA’s proposals in its recent consultation paper (CP17/16) on “Advising on Pension Transfers”, and will be taken into account in the FCA’s response to the consultation.

42 DEVELOPING AND PRESENTING THE PLAN
A full report with a covering letter summarising the main points could be worthwhile Report structure: Introduction Personal and financial circumstances Details and analysis of the scheme Recommendation Summary The client should be given sufficient time to make a decision without being rushed by the expiry of the guarantee date Due to the complexity, a face-to-face meeting is probably best – more than one meeting may be needed

43 SUITABILITY REPORT What three things does the FCA expect a suitability report to include? A summary of the advantages and disadvantages of the personal recommendation made. An analysis of the financial implications if the recommendation is to opt-out. A summary of any other material information.

44 SUITABILITY REPORT The report should inform the client about the benefits they will be giving up and the implications Specifically: That the replacement benefits may fall short of replicating those in the DB scheme The potential investment risk and annuity risk the client will be taking on The report should also cover the risk factors that are specific to the client

45 THE RISK FACTORS The risk factors are ‘attributes, characteristics, external factors or other variables that increase the risk associated with how the consumer has decided to access their pension savings’ The types of risk factors that the FCA expect to be covered in a suitability report are: The client’s state of health Loss of guarantees Whether the client has a partner or any dependants Inflation Sustainability of income in retirement Tax implications Charges Impact on means tested benefits Debt

46 IMPLEMENTATION The receiving scheme will require a transfer in form and possibly confirmation of advice has been provided The ceding scheme’s requirements can vary: Confirmation that appropriate independent advice has been received Confirmation of ID Confirmation of age A transfer request and discharge form completed by the member A receiving scheme warranty will usually need to be completed confirming that the receiving scheme can receive the transfer and is a registered pension scheme Possibly a questionnaire for the member to describe how they were approached and their reasons for wanting to transfer Possible requirement for the member’s spouse to also sign the paperwork All completed paperwork needs to be completed within the three month period starting from the guarantee date

47 MONITORING AND REVIEW Ongoing monitoring should occur in relation to:
The performance of the investments and whether the critical yield is being achieved Any changes that will impact on the financial plan whether personal/legislative or taxation When drawdown has commenced a review of the client’s capital and income needs

48 KEY ISSUES FOR PENSION TRANSFER ADVICE

49 THE FCA’S GUIDANCE ON SUITABILITY OF A TRANSFER
The advice should clearly demonstrate the client’s income needs and expectations and how these can be achieved The receiving scheme and investments selected should be suitable for the client’s requirements and risk profile The manner in which the funds will be accessed needs to be taken into account Alternative ways of achieving the client’s objectives need to be considered The relevant wider circumstances need to be considered

50 DEMONSTRATING INCOME REQUIREMENTS – ACCUMULATION PHASE
The same analysis is needed but it is more difficult to establish needs and expectations precisely Therefore important to agree assumptions with the client Completing a budget planner could be helpful

51 DEMONSTRATING INCOME REQUIREMENTS – AT OR NEAR RETIREMENT
Proximity to retirement will impact on this For those close to retirement it is important to establish base line income required i.e. the minimum standard of living the client is willing to accept Lifestyle and aspirational expenditure also need to be established There needs to be a comparison as to how agreed needs and expectations can be met using existing safeguarded and proposed flexible benefits

52 THE RECEIVING SCHEME When assessing the suitability of a product, the following should be considered: The flexibility of income Options for payment of death benefits Investment options The cost of administration and services provided

53 INVESTMENT STRATEGY This should be suitable to achieve the client’s needs and objectives as well as being suitable for their attitude to risk Factors that affect attitude to risk: Timescale Wealth Past experience Other investments Any ethical considerations

54 THE MANNER IN WHICH THE FUNDS WILL BE ACCESSED
Lifetime annuity – conventional or flexible? Flexi-access drawdown? UFPLS? Phased retirement?

55 LIFETIME ANNUITIES Purchased from insurance company
May offer annuity protection May offer guarantee period – no longer a maximum of 10 years Payable for life, at least annually, in advance or arrears Purchased from insurance company

56 THE CIRCUMSTANCES IN WHICH A LIFETIME ANNUITY MAY BE SUITABLE FOR AN INDIVIDUAL HAVING TRANSFERRED INTO A MONEY PURCHASE SCHEME A lifetime annuity may be suitable where the individual: Has a low appetite for risk Has low or no capacity for loss Needs a guaranteed income Has no desire to manage investment or their pension Has a longer life expectancy based on family history Has a medical condition that will allow them to obtain an enhanced annuity Is single and can purchase a higher income than they may obtain under their DB scheme Part of the transferred fund is used to purchase a lifetime annuity to cover base line living expenses

57 FLEXI-ACCESS DRAWDOWN (FAD)
PCLS normally 25% and balance designated for drawdown No restriction on withdrawals and therefore no review system Flexible drawdown before 6 April 2015 converted to flexi access drawdown from 6 April 2015 Newly designated FAD: MPAA triggered once income taken from FAD fund

58 UNCRYSTALLISED FUNDS PENSION LUMP SUM (UFPLS)
No PCLS but normally 25% of funds taken will be tax-free Remainder will be taxable as non-savings-income Must be made from uncrystallised MP fund Must have reached the NMPA (currently age 55) or retired early through ill-health/protected pension age Must have some lifetime allowance remaining

59 UFPLS NOT AVAILABLE UFPLS cannot be taken from uncrystallised funds where the member has: Primary protection or enhanced protection on lump sum rights of more than £375,000 Lifetime allowance enhancement factor (and available portion of lump sum allowance is less than 25% of proposed UFPLS) UFPLS cannot be taken from a MP plan which has scheme-specific tax- free cash protection

60 PHASED RETIREMENT It is unusual for a defined benefit scheme to allow the phased introduction of benefits, though it is available under ‘enabling’ legislation Methods of phasing: Phased annuity purchase Phased capped drawdown Periodic UFPLS Phased flexi-access drawdown

61 EXPLORE OTHER OPTIONS FOR ACHIEVING THE CLIENT’S OBJECTIVES
PCLS at retirement is typically used to clear debts or for a major item of capital expenditure – is there another way to achieve this? Leaving behind a lump sum death benefit is often cited as a reason for transferring - is there another way to achieve this? Flexibility of income is often cited as a reason for transferring – is a partial transfer available?

62 THE RELEVANT WIDER CIRCUMSTANCES NEED TO BE CONSIDERED……
Is an enhanced transfer value being offered? Is a pension increase exchange being offered? Will there potentially be a lifetime allowance charge? Is the client in serious ill health? The client’s willingness to take on the risks The issue of tax The big ‘What Ifs’….

63 ENHANCED TRANSFER VALUE
Offered by schemes as schemes are becoming more expensive to run Offered to deferred members of the scheme Reduces the scheme’s liabilities and future risk Usually offered for a limited period e.g. 3 months The cost of providing the enhancement is usually covered by the company to ensure the security of the remaining members is not compromised

64 PENSION INCREASE EXCHANGE
The member gives up future guaranteed increases to their pension in return for a higher initial pension with no future increases It can only be applied to non-statutory increases

65 PIE BENEFITS & DRAWBACKS
Higher initial income Higher PCLS May be beneficial for a member in poor health Higher spouse’s pension DRAWBACKS If the member lives longer than average they may be worse off Value for testing against the LTA will be higher Pension input in the final year before retirement will be higher for an active member The higher initial pension may affect the member’s State benefits

66 LIFETIME ALLOWANCE Benefit Crystallisation Events Taking pensions
Taking lump sums Reaching age 75 Dying Transferring to a QROPS Fund value calculation – differs between money purchase and defined benefit schemes Taking benefits in stages – benefits taken previously will impact on the lifetime allowance available now 25 x factor pre-A day 20 x factor post-A day

67 THE IMPACT OF SERIOUS ILL HEALTH
It is important to make the member aware that transferring out of a DB scheme while in serious ill health could potentially result in the resulting money purchase scheme being subject to IHT if they die within two years of making the transfer 60% of something is better than 100% of nothing

68 INCREASED FLEXIBILITY = INCREASED RISK!
Investment risk The value of the fund can go down as well as up Withdrawals in drawdown can amplify the investment risk Sequencing risk – the order in which profits and losses are made can make a big difference Mortality risk – mortality drag Increases with age (especially beyond age 75) Much lighter with a spouse’s pension Longevity risk – the risk of outliving your pension Inflation risk – very important when giving up DB escalation Annuity risk – the risk that annuity rates will not increase/will fall in the future

69 THE ISSUE OF TAX…. The main tax considerations are:
The member’s desire to manage their tax position Where the member has fixed/enhanced protection from the lifetime allowance then transferring could potentially result in loss of their transitional protection Where the member has scheme specific lump sum protection that would be lost on transfer Whether the act of transferring out will either potentially increase or reduce the sum available tax- free If the member wishes to make ongoing contributions whether or not they have triggered the MPAA The potential for high transfer values to create lifetime allowance problems The differential between taxation of death benefits under a DB scheme and a money purchase scheme

70 THE BIG ‘WHAT IFs’ - STRESS TESTING THE ADVICE
A cashflow model can demonstrate how the pension portfolio might perform in a range of scenarios: Where future returns are lower than expected Where living longer than expected Where future inflation is higher than historically suggested Where there is a need for an ad hoc withdrawal Where there is a need to increase income Where there is a sudden or permanent loss of assets

71 CP17/16: ADVISING ON PENSION TRANSFERS
Published June 2017, and resulting policy statement (PS) will be issued in early 2018 Main proposals: All advice on safeguarded benefits must result in a personal recommendation Handbook guidance on assessing suitability to be updated Introducing guidance on the role of a pension transfer specialist Replace TVA requirement with appropriate pension transfer analysis using a prescribed comparator still based on future annuitisation

72 OVERALL OBJECTIVES Understand the benefits payable by a defined benefit scheme Understand the pension transfer process Understand the key issues for pension transfer advice


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