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FCA on STAR – New Consumer Duty rules and transfers

Press Release

FCA’s recent comments on STAR, Consumer Duty and the importance of Full MI

16 February 2023

The Financial Conduct Authority (FCA) recently wrote a series of Dear CEO letters to the Consumer Investment sector, outlining their expectations of firms regarding the new Consumer Duty rules.

The Consumer Duty rules are an entirely new set of conduct rules aimed at protecting retail consumers. These rule changes have already been described as the most significant regulatory and cultural shift over recent years and focus on producing good outcomes for consumers – something that has been neglected when it comes to transfers.

The STAR transfers initiative can help companies evidence their support of new Consumer Duty rules. Participating STAR firms who put themselves forward for accreditation can showcase that they are focused on achieving timely transfers and good consumer outcomes.

STAR is a new award scheme, to tackle the issue of the amount of time it takes to transfer savings, investments, and pensions from one company to another. Transfers involve platforms, insurers, fund managers, re-registration and transfer intermediaries, custodians, third-party administrators and trustees. It also falls across multiple regulatory jurisdictions, with the FCA, Pensions Regulator and Department of Work and Pensions, all having an interest in different elements of the system. The STAR initiative was introduced as an alternative to regulation or legislation, to enable the industry to voluntarily get its house in order. For this reason, two independent and not-for-profit organisations (Criterion and TeX), joined forces to manage the improvements for the industry.

The STAR initiative awarded its first accreditations in November 2022, which is measured and accredited transfer performance across the industry. The awards are designed to both reward good performance and encourage improved performance.

The FCA has made specific references to STAR and transfers in its recent CEO letters, stating:

“we also consider that more needs to be done to speed up transfers between investment platforms, and “we expect firms to do more to reduce platform switching times. The Duty guidance states ‘firms should make it easy to switch product, leave their service or make a change, as it is to buy the product or service in the first place. We continue to support the efforts of STAR, and we will continue to take action where we see firms falling below the standards we would expect.”

“Improving transfer times is critical in improving consumers’ ability to shop around and switch to a platform that better meets their needs. The FCA is supportive of the progress STAR has made to date which aims to bring down transfer times. Reducing transfer times remains a priority for the FCA and Full MI will play an important role in ensuring this. Therefore, we are supportive of STAR continuing to pursue the Full MI and its publication. We will be actively following STAR’s progress towards its objectives.”

“We know there are pension companies and administrators that are happy doing things badly, relying on outdated systems and processes; sending pieces of paper in the post and waiting weeks to get things signed off. The only way to get these laggards and poor performers to improve is to normalise adherence to a commonly agreed set of standards. The FCA Consumer Duty guidance has prompted questions on who the new rules apply to, how firms can implement and monitor these changes, and how they will provide better consumer protection. Good consumer outcomes include firms being required to act in good faith and avoid causing foreseeable harm - the STAR initiative fits with these new rules. Namely, firms provide consumers the support they need throughout the lifecycle of their products and services, and a key area of focus for this is timely investment transfers. We encourage all firms not involved with STAR to join – it shows that you care about good customer outcomes, remain focused on timely investment transfers, and can evidence it with an accreditation.”

Criterion and TeX strongly encourage all pension, savings and investment providers to join STAR – the biggest cross-industry collaboration in decades.   

Notes

For further information please contact:

Matthew Dransfield
Commercial and Marketing Director
Criterion
0773 765 0010
media@criterion.org.uk

About STAR

STAR was created as a collaboration between Criterion and TeX, combining the industry-reach, unique strengths, experience and shared ambition of the two not-for-profit organisations.

Criterion was formed for the industry in July 2017, as an independent, not-for-profit industry body providing Standards and Governance services. It was originally part of Origo Services Ltd and has been publishing process and integration standards for over 25 years. Criterion is uniquely positioned to facilitate and drive cross-industry engagement, helping organisations achieve higher levels of collaboration, reduce costs and achieve better outcomes for their consumers.

TeX is a not-for-profit organisation which works with the industry to ensure that the maximum benefit is provided to all members. This new company is financially independent from TISA but benefits from being linked to the TISA brand through name, the expertise provided by the two corporate entity directorships and the administrative support provided by TISA.

SERVICING AGREEMENT

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1. APPLICANT COVERED BY THIS REGISTRATION.
Please note this registration will not be processed if Step 1 has not been completed.
If your organisation is acting only as an affiliate, you do not need to complete Step 2.
2a. CHOOSE YOUR BRAND
STAR manages the administration of third-party access to the portal, rather than the member firm. This allows for a smoother transition for the member firm and allowing immediate access to the supplier to submit MI on their behalf. STAR will hold an approved list of users per supplier, which will be allocated to your account at the point of registration. This ensures each ‘external’ user has the same access across all their client accounts. Supplier access is restricted and they do not have any ability to see any company information for any client other than what they submit on your behalf. You as the member control access for any other users within your organisation. We will include a more detailed description about the user access on your welcome email and it is clearly defined as part of the User Guide.
STAR RELATIONSHIP MANAGER FOR FIRST BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
2b.
STAR RELATIONSHIP MANAGER FOR THE SECOND BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
2c.
STAR RELATIONSHIP MANAGER FOR THE THIRD BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
2d.
STAR RELATIONSHIP MANAGER FOR THE FOURTH BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
3. INVOICE INFORMATION
Invoices are sent by email as standard, if a printed invoice is required please note the address and your requirements in the additional information section.
4. DECLARATION
Before we can process your Brand Registration a STAR Servicing Agreement needs to be signed. Your signatory must be duly authorised for and on behalf of the organisation named in this application.
We only require one signed STAR Servicing Agreement which will cover all brands that you wish to register. Upon completion of this form we will check our records to ensure an agreement hasn't already been signed, if so a new contract will not be sent to your signatory.
STAR will email the servicing contract to the signatory email address (provided below) through our electronic platform Yoti. This declaration must be signed in order for your application to complete, once we receive the signed agreement we will instruct our finance department to issue your invoice.

Application submitted successfully

Thank you for applying to join the STAR accreditation scheme. We will endeavour to respond as soon as possible using the contact information you’ve provided to us.