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SIPP providers - how will new Capital Adequacy rules affect you?

As if you didn't know already, life is about to get tougher. The new Capital Adequacy rules, in force from September, will mean that many SIPP providers will have to significantly increase the amount of capital held. Hardest hit will be the smaller players, particularly those with large holdings of "non-standard" assets. 

The FCA is also stepping up pressure on governance and conduct with firms' systems and controls and third party arrangements coming under increasing scrutiny. The FCA's approach to some extent mirrors the Pensions Regulator's increase in governance requirements of those running occupational money purchase schemes. The net result of these pressures is increasing market consolidation, as some of the smaller operators decide to call it a day.
  
If you are affected by any of these developments, then TLT can help. Whether you are looking to exit the market or restructure your portfolio, we have the experience and the knowledge to assist you. We provide a full legal support service to the SIPP industry, with a specialist team that knows its way around both the pensions regulators. Our expert lawyers can provide the help you need to achieve your objectives as quickly and painlessly as possible.

Acquisitions and disposals of SIPP portfolios

We provide a complete solution for SIPP providers looking to acquire or dispose of a SIPP portfolio. 

We can:

  • undertake due diligence on even the largest SIPP portfolio (we have a fully scaleable facility), to identify any liabilities or risks that may lie hidden;
  • advise on the remedial work required prior to placing a portfolio on the market, or after acquisition;
  • prepare, advise on and negotiate the  full suite of legal documents required to give effect to the transaction;
  • advise on relevant FCA notifications and other regulatory requirements.

SIPP investment portfolios

For SIPP providers who wish to change the types of investments permitted in their schemes, we are able to:

  • advise on and draft any amendments required to SIPP documentation necessary to implement the changes;
  • advise on the relevant regulatory requirements applying to different types of investments; and
  • advise on the legal requirements and risks associated with certain SIPP investments, including taxable property issues and unauthorised payments.

Day-to-day support for your SIPP scheme

Our experienced team advises on all aspects of pensions and regulatory law applying to SIPPs, including trustees' duties, pensions taxation and all associated FCA requirements.

We draft all documentation required to establish and govern SIPP schemes. We also prepare and advise on SIPP providers’ terms and conditions, member application forms and key features documents and all associated literature.

Flexible pricing models

Our fees are competitive and provide excellent value for money. We offer fixed fee arrangements for specific projects.

We also offer 'menu pricing' allowing you to pay only for the services that you require and use.

TLT's SIPP team

As a national firm, with offices across the UK, we are always close at hand. The SIPP team consists of lawyers across Financial Services, Corporate, Pensions and Commercial Dispute Resolution ensuring that clients receive full coverage in this complex area.

Noline Matemera is a partner in our Financial Services Regulation team. She heads our SIPP team and is a highly experienced financial services regulatory lawyer with an in-depth knowledge of financial services law in the UK and the EU. 

T: +44 (0)333 006 0734
E: noline.matemera@TLTsolicitors.com

Richard Leigh is a legal director in our Pensions team and works alongside Noline providing advice to clients on pensions investment, SIPPs and SSASs.

T: +44 (0)333 006 0212
E: richard.leigh@TLTsolicitors.com

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at January 2016. Specific advice should be sought for specific cases. For more information see our terms & conditions on www.TLTsolicitors.com

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