So, in summary, write down or otherwise record absolutely all communications you have had with all parties, not just the client, ensuring they are comprehensible, stored in a method that allows easy retrieval (at short notice), in chronological order, permanently, and with no risk of deletion, accidental or otherwise. Simple.

Stay up-to-date

Although reading the FCA’s Cobs rules is very few people’s idea of fun, it is particularly vital where DB transfers are concerned.

Cobs 19.1 will ensure that you get a lot of the basics right, and should the regulators want to review your processes and systems, Cobs is the lens through which they will do so. 

The FCA also issue non-handbook guidance and this is vital reading, with the inclusion of good/poor practice examples particularly helpful.

Tim Flippance is managing director of Grove Pension Solutions