Who is responsible for reporting the transfers?

Pensions A-Day seems such a long time ago and after the subsequent changes of benefits, did not do exactly what it said on the tin.

However, some of the reporting requirements to both HMRC and The Pensions Regulator were introduced and did not subsequently change.

So this raises the question: If you, as an IFA, are providing transfer advice to say owner directors of SMEs, who should be doing the HMRC Registered Pension Scheme Event Report (APSS 300) and the subsequent Pensions Regulator form (PR12)?

Officially, it is the trustees to the scheme, but the onus, directions and forms are as clear as the proverbial mud!

So who carries the can when your client picks up a fine for your transfer advice? Time will tell as to whether this is a further service we are expected to provide.

We all know the insurance companies who have written to their existing executive pension clients to relinquish any responsibility of these issues, leaving the client to hope that their IFA knows what to do.

To help, Scottish Widows have just produced a brochure called Scheme Administrator: A guide to the role and responsibilities.

Have a read of the responsibilities and the fines for failure to comply. It raises the question “who is reporting the transfer news?”

Keith Churchouse is director of Churchouse Financial Planning and owner of www.pensionsmadesimple.com

The views expressed are those of the author and not those of the company he represents.