PDCOB 12.3 Permitted post-view services
1A firm must only offer or provide post-view services that:
- (1)
relate to pensions and retirement planning or are a type of service that supports customers in understanding their pensions and view data to enable them to better understand and consider their retirement planning;
- (2)
have been user-tested in accordance with PDCOB 12.6.1R;
- (3)
do not include:
- (a)
an offer to sell (which includes sending an application form for a product);
- (b)
an offer to arrange for the sale or purchase of;
- (c)
selling; or
- (d)
arranging for the sale or purchase of (which includes sending an application form for a product),
an investment to or for a customer; and
- (a)
- (4)
do not include investment advice or advising on pension transfers and pension opt-outs .
1A firm is permitted to ask a customer to input data into the post-view service, such that post-view services can be provided, either by way of auto-populated data from the view services, pensions dashboard self-asserted data or a mixture of both.
1Firms are reminded that they may require permission to carry on regulated activities other than regulated pensions dashboard activity if any post-view services amount to regulated activities.
1Firms are reminded that when they provide post-view services, they must comply with their obligations in PRIN, including:
- (1)
acting to deliver good outcomes for retail customers (Principle 12);
- (2)
enabling and supporting retail customers to pursue their financial objectives (PRIN 2A.2.14R); and
- (3)
designing and delivering support to retail customers such that it meets the needs of retail customers, including those with characteristics of vulnerability (PRIN 2A.6.2R).
1Pursuant to PDCOB 12.3.1R(4), a firm is not permitted to offer a post-view service which amounts to advising on pension transfers and pension opt-outs. This includes abridged advice. However, a firm is permitted to offer post-view services which support and engage customers with their safeguarded benefits. A firm should ensure that such support and engagement does not stray into the regulated activity of advising on pension transfers and pension opt-outs and should consider the guidance in PERG 2.7.16GG.
1Firms should consider how assumptions about future investment returns and charges can influence customers’ decision-making on transferring or converting safeguarded benefits. Firms should ensure that such assumptions do not result in the firm advising on pension transfers and pension opt-outs.