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PAST BUSINESS REVIEW (PBR)

TCC has conducted Past Business Reviews (PBR) on a wide range of financial products, including mortgages and UCIS, for a variety of firms many of which have been performed as ‘Skilled Persons’ following approval by the FSA.

As an example of the services provided by TCC the following covers a Past Business Review of Pension Switching.  Please contact us for details of our work with regard to any other area of financial services.

The Past Business Review outlined below is provided by TCC’s Operations Centre where our PBR work, along with many other services, are carried out.

Methodology

The precise review methodology will be agreed with the client before commencement. TCC will apply our methodology which has been used to deliver a number of similar projects successfully.

Project stages can run simultaneously to ensure agreed project timescales are met:

  • Initial Case Review - TCC will assess the suitability of advice based on the file evidence
  • Further Investigation - where it is not possible to determine whether the advice was/wasn’t suitable from the client’s internal records, TCC will undertaken further investigation (which could include contacting and obtaining further information from clients, providers or adviser) to establish the final grading for the case
  • Remediation - where advice is deemed to be ‘Unsuitable’ TCC will perform an appropriate loss assessment to establish if the customer has been financially disadvantaged as a consequence of unsuitable advice. Where this is the case TCC will complete the remediation process.

Initial Case Review

The initial case review will be based on the file information provided by the client and on the understanding that all relevant information available internally has been provided for review.

The assessment of each case will primarily focus on the suitability of the advice. Each review will be conducted using the FSA Pension Switching Suitability Checklist which will allow each case to be tested against defined unsuitable outcomes.

Additionally, TCC will follow the guidance outlined in the FSA publications of December 2008 and April 2010 relating to pension switching.  Cases will be graded initially as:

  • Suitable: cases where there is sufficient information on the file to demonstrate that the recommended product was suitable at the time of sale.
  • Unclear: cases where there is insufficient information on file to assess the suitability of the recommendation and, as a result, further investigation is required.
  • Unsuitable: cases where it is reasonable to conclude that the recommendation was unsuitable and the customer could have suffered financial loss
Cases graded as ‘Suitable’ will be closed as no further action required. Cases graded as ‘Unsuitable’ will be fast tracked to stage 3; remediation.
Further Investigations
For any cases graded as ‘Unclear’ as a result of the initial case review, TCC is able to undertake further investigations so that a final conclusion can be reached.
The further investigations needed to establish whether the advice was suitable or not will depend on the nature of the issues identified during the initial case review. However, it is expected that the further investigation will involve contacting one or more of the following for further information: Advisers, Product Providers, Customers, Other third parties, for example, ceding scheme trustees where the advice relates to pension switching.
 
It should be noted that all communications with third parties will be made under the client brand. When contacting customers, TCC will follow one of two approaches, both of which have previously been deemed acceptable by the FSA.

Option 1 - Fully informed process

Under this approach, TCC will issue a letter to the customer informing them of the review and of the issues identified. Customers will be asked if they require an investigation to be undertaken. Only cases where the customer requests a review will be investigated further.
Reminder letters will be sent to customers who do not respond and these cases closed once sufficient attempts have been made.
Option 2 - Automatic Review
Under this option TCC will proactively review the case, obtaining the required information from all relevant sources as necessary in order to complete the review and reach a final conclusion.
Where customer contact is required it is envisaged that this will be carried out using a combination of letter and telephone.  
Remediation
Where it is concluded that advice was unsuitable, TCC can seek to identify whether any customers have suffered financial loss by performing an appropriate loss assessment calculation. Where a loss is identified, TCC will calculate the redress required to restore the customer to the position they would have been in had the advice not been given and the transfer/switch had not taken place. In order to undertake this assessment information will be gathered from relevant sources including: the customer, ceding schemes, receiving schemes.
                         
Loss assessments will be carried out in accordance with FOS’ publication issued in October 2005 entitled “Redress for Pension Mis-sale cases that fall outside the Pension Review”
 
Upon completion of the loss assessment, TCC will send an appropriate offer letter to customers providing details of the loss identified and information on the calculation methodology followed. Upon receipt of acceptance from customers, cases will be passed the remediation team for settlement

Resources
TCC will provide a dedicated team of suitably qualified and experienced individuals to undertake past business review projects.  All resources allocated will have the requisite skills, knowledge and qualifications to undertake the various relevant activities.

Training & Competence and Quality Assurance

All resources allocated to the project will be included in TCC’s Training and Competence Scheme. All Case Officers and Remediation Officers will undergo formal training and an initial assessment of competence prior to commencement of the project. The outcomes and results of this training and initial assessment can be made available to the client for review.

Beyond this, regular monitoring will be undertaken. For a competent resource, this will involve checking a minimum of 10% of cases worked.

Records

Records will be maintained using a workflow system. This system will facilitate workflow management and detailed reporting as well as providing a robust record of the project and case outcomes.

Reporting and Management Information

The specification for reports and reporting timetable will be agreed with the client before commencement.

TCC’s Project/Relationship Manager will attend meetings with the client and other external parties as required.

For further information on TCC’s past business review services please call 020 3008 6020 or email info@theconsultingconsortium.com.

 

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