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PDCOB 5.1 Purpose

PDCOB 5.1.1 G
  1. (1)

    1This chapter requires firms to provide certain information and warnings to customers when they are using a pensions dashboard platform to enable them to understand the nature, limitations and risks relevant to the different stages of the pensions dashboard platform. This should manage customer expectations and support informed decision-making.

  2. (2)

    Save for the information set out in PDCOB 5.5.1R, firms can determine the specific point in time to provide the information and warnings which they would consider to be the most appropriate and effective, so long as it is provided by the points set out in the rules.

PDCOB 5.2 Form of messages

PDCOB 5.2.1 G

1The rules in this chapter do not prescribe the form in which the information and warnings should be communicated by firms to customers. Firms are able to:

  1. (1)

    choose the design, form, language and delivery of the information and warnings; and

  2. (2)

    determine the most effective and engaging way that they can convey the information and warnings to customers.

PDCOB 5.3 Information about a firm and its services and fees disclosure

PDCOB 5.3.1 R

1Before a customer is directed to the MaPS dashboards digital architecture to generate pensions dashboard find data, the firm must:

  1. (1)

    provide the customer with at least the following information:

    1. (a)

      the name and address of the firm, and the contact details necessary to enable a customer to communicate effectively with the firm;

    2. (b)

      appropriate information about the services offered by the firm, including regulated pensions dashboard activity and (if applicable) any data export and post-view services;

    3. (c)

      a statement that some pensions may not be displayed on a qualifying pensions dashboard service and at least 2 of the possible reasons;

    4. (d)

      a statement of the fact that the firm is authorised by the FCA;

    5. (e)

      if the firm has entered into a third-party dashboard arrangement, a statement of this fact, and the name of the third party that has given the customer access to the pensions dashboard platform;

    6. (f)

      information, or a link to a location containing information, about how a customer could register complaints about the firm with the firm and the Financial Ombudsman Service; and

    7. (g)

      any other information which the firm deems necessary so that the customer is reasonably able to understand the nature of the pensions dashboard platform that is being offered; and

  2. (2)

    inform the customer that:

    1. (a)

      the view services are free of charge; and

    2. (b)

      a fee may become payable for services other than view services, but only for those services which amount to permitted dashboard services.

PDCOB 5.3.2 R

1 PDCOB 5.3.1R applies each time a customer is directed to the MaPS dashboards digital architecture.

PDCOB 5.3.3 G

1A firm disclosing details of its authorisation should refer to the appropriate forms of words set out in GEN 4 Annex 1R.

PDCOB 5.3.4 G

1For the purposes of the statement in PDCOB 5.3.1R(1)(c), examples of the reasons why a pension might not be shown on a qualifying pensions dashboard service include:

  1. (1)

    if a pension provider is not connected to the MaPS pensions dashboards ecosystem; or

  2. (2)

    if the customer is entitled to the present payment of the pension benefits.

PDCOB 5.3.5 G

1 PDCOB 12.4 applies to a firm that imposes a fee in connection with any permitted dashboard service.

PDCOB 5.3.6 R

1Where a fee may become payable for a permitted dashboard service, the firm must inform the customer of the amount of the fee before the customer incurs a liability to pay the fee.

PDCOB 5.4 Disclosure warnings about the possibility of scams

PDCOB 5.4.1 R

1On each occasion that the customer uses the pensions dashboard platform, a firm must display the following:

  1. (1)

    a message warning the customer that if they are approached by a third party who asks for the customer’s data or asks to screen share, the customer should check who they are dealing with;

  2. (2)

    a message warning the customer about the risks of:

    1. (a)

      screen sharing with a third party; and

    2. (b)

      giving a third party access to the customer’s device, including remote access;

  3. (3)

    an explanation that a third party with control of the customer’s device can access and control more than what is visible on the screen, including one or more examples of what a third party can access remotely on a customer’s device; and

  4. (4)

    a reminder to the customer:

    1. (a)

      to think carefully about whether the third party needs to see the information on the screen; and

    2. (b)

      that pensions dashboard view data is sensitive, valuable and should be kept safe.

PDCOB 5.4.2 G

1 Firms should consider warning customers to use the Financial Services Register to check whether a third party that claims to be authorised or exempt is who they say they are.

PDCOB 5.4.3 G

1 Firms are reminded of the notification requirement relating to scams in PDCOB 15.2.

PDCOB 5.5 Disclosure information in relation to view data

PDCOB 5.5.1 R

1Immediately prior to the customer accessing their pensions dashboard view data, a firm must communicate to the customer the limitations of pensions dashboard view data, including that:

  1. (1)

    value data is supplied for illustrative purposes and the actual value could be higher or lower than those supplied;

  2. (2)

    the projected values are indicative of what a customer could receive, and are not guaranteed;

  3. (3)

    assumptions have been used to estimate the projected values;

  4. (4)

    projected values may change (increase or decrease) and may be influenced by changes in investment performance, contributions and the date the customer decides to take their pension;

  5. (5)

    more up-to-date figures and more details may be available from the pension provider or scheme administrator;

  6. (6)

    all figures are shown before tax; and

  7. (7)

    pensions dashboard view data may not be available in respect of some pensions.

PDCOB 5.5.2 G

1An example of where pensions dashboard view data may not be available is where the customer has started to draw their benefits.

PDCOB 5.5.3 G

1A firm should communicate the information in PDCOB 5.5.1R in a way which is fair, clear and not misleading.

PDCOB 5.6 Disclosure warnings about decision-making solely in reliance on view data and post-view services

PDCOB 5.6.1 R

1A firm must communicate a warning to a customer when that customer is to be provided with view services or post-view services stating that the customer should not make a financial decision based solely on the information displayed on the view services or (where applicable) post-view services.

PDCOB 5.6.2 R

1 PDCOB 5.6.1R applies each time the customer is to be provided with view services or post-view services.

PDCOB 5.6.3 R

1Where a firm offers customers the option of collapsing, hiding or dismissing the warning in PDCOB 5.6.1R, it must only do so if the customer has taken positive action to allow that.

PDCOB 5.7 Other specific disclosures

PDCOB 5.7.1 G

1 Firms are reminded that whether certain other specific disclosures must be made depends on how the firm chooses to operate its business. These disclosures include where the firm:

  1. (1)

    has entered into third-party dashboard arrangements (see PDCOB 9.6.1R);

  2. (2)

    provides data export to the customer (see PDCOB 11.4.1R, PDCOB 11.4.2R and PDCOB 11.4.6R);

  3. (3)

    provides data export to the firm (see PDCOB 11.5.1R); or

  4. (4)

    provides post-view services (see PDCOB 12.5.1R and PDCOB 12.5.2G).