Reporting concerning pension transfer requests

What we want to know about

Concerns could be because you have a number of red or amber flags or have decided to refuse a transfer. See The Pensions Regulator’s guidance on the specific checks when dealing with pension transfer requests.

We would like you to report to us about:

• individuals who provide unauthorised advice on pension transfers
• increases in the volume of transfers advised by the same adviser to the FCA
• if a member requested a transfer following a cold call or unsolicited contact
• if the member has been offered an incentive to make a transfer
• if the scheme has high risk or unregulated investments
• if the scheme charges are unclear or high
• if the scheme’s investment structure is unclear, complex or unorthodox
• potential scam activity

Information you should you give us 

Individuals who provide unauthorised advice on pension transfers  

This is where you have reason to believe that the member has been in contact with someone who agreed to or who has carried out any of the following regulated activities without the appropriate regulatory permissions from the FCA: 

• providing advice on a pension transfer  
• providing advice about where to invest their pension 
• making arrangements for the member to buy or sell investments or making arrangements with a view to the member buying or selling investments 

Helpful things to consider

If you think somebody may have carried out a regulated activity without the appropriate FCA permission: 

• A member may have been in contact with an unregulated introducer but has received advice from a regulated firm. If that introducer has been involved in the transfer process and has influenced or been instrumental in the member’s decision to transfer or buy investments, depending on the particular circumstances, the introducer may have been carrying out regulated activities without the appropriate regulatory permissions. 
• If the member lives abroad and wants to transfer their benefits overseas, a regulated firm in the UK who is advising on a pension transfer may work with an overseas adviser who is advising on investing the transferred benefits in overseas investments. Depending on the particular circumstances, this may not in itself be a cause for concern. 
• If there is not a regulated firm in the UK giving advice to a UK based member about leaving the UK scheme, and an overseas adviser has advised on overseas investments that would only be possible for the member to buy if they transfer out of the UK scheme, there may be cause for concern. In such circumstances there may be scope for you to have reason to believe that the overseas advisor has advised on the transfer without the appropriate regulatory permissions. 

Increases in the volume of transfers advised by the same firm

This is where you identify an unusual pattern of behaviour involving switches within a defined contribution scheme or a sharp or unusual rise in transfer requests involving the same firm.

Helpful things to consider 

• The risk of ‘factory gating’ (the practice of targeting specific workers in a situation which may make them more interested in transferring their pension) is significant in large or concentrated workforces. This can cause clusters of transfer requests to a particular scheme or using a particular firm over a short period of time.
• Transfers to a receiving scheme linked to a new employer following a corporate or TUPE (Transfer of Undertakings (Protection of Employment)) transaction are not necessarily a cause for concern. So it is important that you are aware of activity affecting sections of the workforce and whether these might trigger concerns.
• It is common for victims of scams to unknowingly persuade family, friends and colleagues to become involved in a pension or investment scam, believing it to be a good deal. This can cause a cluster of requests to transfer or switch using one firm.

You may request more information from the firm to help you decide if a high number of transfers or switches is of concern.

How to report information to us

Give us as much information as possible so that we can identify the firm involved and the number of customers. Relevant information includes the name and contact information of those involved, and related materials such as websites and brochures.

How to report:

• DB to DC transfers: [email protected]  
• DC to DC transfers: [email protected]

If you think a scam is involved 

You should report any knowledge or suspicions of pension scams and those involved. This allows us to investigate and prosecute scammers. It also allows law and policy makers to get a clearer picture of the effect that scams have on pensions. 

How to report:

• DB to DC transfers: [email protected]  
• DC to DC transfers: [email protected]

You can also share the following useful information with the member about pension scams. See our ScamSmart information[1] and pension scams leaflet[2].​​​​​