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Executive decisions

The FSA’s fourth life insurance newsletter issued last month warns insurers about the standard of advice given by their representatives.

It asks that advisers “take particular care to ensure that their recommendations are suitable” and draws attention to three distinct areas of advice leading up to A-Day. These are the choice of enhanced and primary protection, transfers to section 32s and the need to avoid unnecessary switches of group money-purchase schemes into new commission-bearing schemes. Advisers should take account of all the available options.

Many industry commentators highlight transfers to s32s from executive pension plans as a great opportunity. The initial driver of such transfers was the protection of tax-free cash. More recently, the push to transfer has received fresh impetus from the revelation that trustees of EPPs could end up having to do their own administration. The scheme administrator’s role requires a lot of form filling, with fines for late or inaccurate returns.

But for many EPP clients, this will not be the case. Some providers will do the form filling on their behalf. Standard Life’s centralised trust EPP (Stanplan A) is a good example. Its 200,000 members can rest assured that they have no need to get to grips with what amounts to another annual tax return. It is likely that other EPP providers will do likewise. Therefore, before recommending transfers out of EPPs, advisers should ensure that avoidance of form filling is a genuine reason on which to base their recommendation.

In both protection of tax-free cash and avoidance of form filling, EPP clients have three main options.

The first is to stay put. This is likely to be the best option for clients who are happy with their EPP, its fund choice and the insurer’s service. If this is the case, an EPP will prove to be as good a home for their retirement savings as any other product post-A-Day. Remember also that an EPP, like any occupational scheme, can pro- tect the entitlement of members to more than 25 per cent tax-free cash as readily as a s32. As noted above, only in some instances will insurers seek to transfer the new tax reporting requirements to the client. Even then, some trustees will be comfortable completing these forms.

The second option for EPP clients is to wait until after A-Day before making up their mind. For any EPP customer who has a desire to transfer, this is probably the best option as it allows them to look around the post-A-Day market for the most suitable plan. To transfer after A-Day without losing any entitlement to extra tax-free cash, the transfer needs to be a block transfer. This is a transfer of two or more people from the same transferring scheme to the same receiving scheme.

The final option is to transfer to a s32 before April 6, 2006. No matter how enticing some s32s might look today, once there, a client cannot transfer again after A-Day without losing their entitlement to extra tax-free cash so s32s are probably most suitable for deferred one-member EPP clients nd existing s32 clients who are not happy with the product they currently have.

Advisers must develop their own view of these issues. The best way to do this is to read and consult widely before deciding which option best suits clients’ needs.

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