The FCA's proposals in CP 26/20: Adapting our rules for a changing market: self-invested personal pensions are set to cause significant challenge for SIPP providers.
As these proposals progress, we will be producing a number of articles to help inform and guide SIPP operators through these changes. This is the first article and provides an in-depth review of the proposed due diligence requirements set out in a new proposed COBS 19A.
This article explores the following key components:
- due diligence obligations arising from the involvement of relevant third parties;
- due diligence required on investments with varying requirements based on whether the SIPP operator is involved in arranging/acquiring the investments or whether a third party undertakes that role without operator involvement; and
- overarching governance, organisational and system and control requirements.
These proposals are likely to have significant operational implications, particularly for 'bespoke / full SIPPs', and raise important questions about proportionality, commercial viability and investor choice.
Please contact the author should you wish to discuss how CP26/20 may impact your firm and/or if you have any questions on regulatory requirements on SIPP operators more generally.
