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  • FIRST POST
    • TonyWarwick
    • By TonyWarwick 26th Apr 17, 1:42 PM
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    TonyWarwick
    Hargreaves Lansdown transfer obstructions
    • #1
    • 26th Apr 17, 1:42 PM
    Hargreaves Lansdown transfer obstructions 26th Apr 17 at 1:42 PM
    Sorry this is a long post, but I hope interesting.

    Both my wife and I recently decided to transfer our ISA accounts from Hargreaves Lansdown to Interactive Investor. The reason is simple - it will save us more than £1600 pa in fees for the same holdings.

    We filled out the II transfer forms as required, and these were sent in to HL, but HL have declined both transfers:
    1. They declined mine on the grounds that the client number I had given was wrong. I had quoted the full client number beginning with 00xxxxxx (which is how THEY quoted it on their early documents) whereas they say I should have just quoted the xxxxxx part. Given that I had also given my full name, date of birth and full address, it seems absurd that they are unable to resolve this, and I suspect they are being deliberately obstructive, especially in light of ...
    2. They declined my wife's because she had "failed to pass money laundering regulations". They told II that they had requested AML documents from her (they hadn't) but had not received them. My wife's account with HL has been open and live since mid-2015.

    On challenging HL about these refusals, I was told that the first problem was all II's fault because they 'should have known the leading zeros were not needed'. This seems very thin, but on asking them to proceed they insist that II restart the process with a new transfer request.

    They then went on to inform my wife that they had not yet contacted her about this, but that they were 'about to' request AML documentation - and that this had to be done through the post and could take as much as 10 days to arrive. She asked why, when her account had been open for some years, they needed this, and she was told that it is a Statutory Requirement. She then observed that they hadn't requested this from her husband (me) and they said they 'probably would' in future.

    I have looked carefully at HMRCs guidance document for ISA managers (chapter 11) and can find absolutely no reference to AML requirements on the 'outgoing' manager on transferring out, so I am wondering if HLs claim that this is a Statutory Requirement is true. I suspect that they are simply being obstructive and instigating deliberate delays.

    Anyone with similar experiences?
    Last edited by TonyWarwick; 26-04-2017 at 1:44 PM. Reason: Minor correction
Page 1
    • bowlhead99
    • By bowlhead99 26th Apr 17, 2:44 PM
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    bowlhead99
    • #2
    • 26th Apr 17, 2:44 PM
    • #2
    • 26th Apr 17, 2:44 PM
    I don't have direct experience of a HL AML request, but regulated financial services businesses are required by law to carry out the identity checks they feel necessary to document the customers using their own procedures and and risk-based approach (which each business must implement as it sees fit to avoid falling foul of the law).

    It might not be mentioned for outgoing managers in a government ISA manager's guide because it is assumed to have already been done at time of account opening, and the fact it is an ISA account doesn't change their basic duties compared to any other account they offer anyway.

    As your wife is leaving, there is not a cat in hell's chance she would send them whatever documentation they request after she is no longer a customer and they have no practical leverage on her to make her comply. So unfortunately they will see this as the last chance saloon to collect her information properly before they allow her to leave. And clearly giving her "clean" investment proceeds to walk away with, without properly identifying her, is bad form in the world of AML. So she'll probably just have to suck it up, although she should complain that these things weren't requested in the last two years (if they genuinely weren't and now it is delaying her move).

    As an aside, crying "but you never asked for these documents for my husband" is not a particularly good way to get them to drop a burdensome request. If anything, that is only going to encourage them to want to check him out too - it is not going to make a compliance officer decide that he is going to forget he ever asked her for her docs. The compliance guy doesn't want to write on his anti terrorism files, "She didn't want to provide any documents to prove she was who she said she was, so we let her off and paid her out anyway".


    However, for your other complaint, the "on your transfer form, you included the leading zeroes in your customer account number that we always show on your statement, so we couldn't identify your account number and consider your request invalid, please start again" is a completely ludicrous response and i would complain heartily about that.
    Last edited by bowlhead99; 26-04-2017 at 2:46 PM.
    • TonyWarwick
    • By TonyWarwick 26th Apr 17, 3:26 PM
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    TonyWarwick
    • #3
    • 26th Apr 17, 3:26 PM
    • #3
    • 26th Apr 17, 3:26 PM
    Thanks bowlhead99. I'm sure your comments are correct in relation to opening an account, but HL are not saying that AML information is missing or outstanding from their obligations in relation to holding my wife's account. They are saying that they are obliged to carry out AML proving AGAIN on receiving a transfer request. This is not a longstanding 'missing' piece of info, it's a fresh requirement and I can find no evidence of a statutory basis for it. It may be HL's policy to seek this info again, but is it a requirement or an obligation? if the former, then I must accept it, but cannot help suspecting that it is, at least in part, a contrived delay. In any event, HL's statement to II was untrue in that my wife had never 'failed to pass' an AML check, and she had received no request at that point.

    You're right, of course, that it would have been better had my wife not mentioned my case in her discussion, but she was understandably irritated by the whole position. I suspect that HL will now await the resubmission of the transfer request (without the zeros!) and will THEN send me an AML information request through the post. HL contact their clients by email and secure message for every other topic, but not this, apparently.
    • bowlhead99
    • By bowlhead99 26th Apr 17, 5:35 PM
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    bowlhead99
    • #4
    • 26th Apr 17, 5:35 PM
    • #4
    • 26th Apr 17, 5:35 PM
    Thanks bowlhead99. I'm sure your comments are correct in relation to opening an account, but HL are not saying that AML information is missing or outstanding from their obligations in relation to holding my wife's account.
    Originally posted by TonyWarwick
    Effectively, they are really. They're saying she's not been documented well enough, in terms of the documents they want/need to have on file in relation to her account; so she needs to be documented properly

    they are saying that they are obliged to carry out AML proving AGAIN on receiving a transfer request. This is not a longstanding 'missing' piece of info, it's a fresh requirement and I can find no evidence of a statutory basis for it.
    The basis is that she's not been documented well enough, and needs to be. Perhaps they forgot to ask when she joined so there's nothing on file, or something went missing (annoying but feasible with a massive client base) or they only got some basic info which they didn't get around to following up properly but now realise their records are inadequate.

    I get that a cynic might find the timing suspicious but it can be the case that trying to wrap up a customer file can be a trigger to remediate the missing documentation, even if you have had no reason to even open the customer master file for the last year or two.

    If it was one of the financial services businesses that had the multi million pound fines for having slack anti money laundering processes in recent years, they might say, "sod it, she's leaving anyway, i cant be bothered". However, better institutions will follow these things up, even though it doesn't feel like they are "better" in terms of your wife's customer experience.

    It may be HL's policy to seek this info again, but is it a requirement or an obligation? if the former, then I must accept it, but cannot help suspecting that it is, at least in part, a contrived delay.
    It isn't a requirement to "seek it again on exit" if they already have it. But if they never got it in the first place, or only partially got it (including, for example, for the reason that they simply didn't get round to asking for it in the first place due to some internal error or issue), they should ask for it, rather than letting her walk off with tens of thousands of pounds of clean assets.

    Still, say they are getting £10-15 a week in admin fees from her because she has £115k-175k of open ended funds in her ISA. Running round trying to fix documentation errors is the sort of thing that can easily burn through more than £20 of their time and effort so they are probably not doing it just for fun.
    In any event, HL's statement to II was untrue in that my wife had never 'failed to pass' an AML check, and she had received no request at that point.
    It sounds like it's factual that she had not "passed the AML check". Perhaps the reason she had not passed their check was because of your wife having never even previously received the request for AML /identity information in the time she'd been a customer. Still, that wouldn't make it a lie for them to tell the transferee manager that they couldn't release the assets pending completion of a check.

    Just so you don't shoot the messenger, I'm not an HL worker or owner, or even customer (my parents have accounts with them but I don't). The comments are just to help you try to make sense of it all and I agree it's not great service of course.
    Last edited by bowlhead99; 26-04-2017 at 5:47 PM.
    • dunstonh
    • By dunstonh 26th Apr 17, 5:58 PM
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    dunstonh
    • #5
    • 26th Apr 17, 5:58 PM
    • #5
    • 26th Apr 17, 5:58 PM
    The AML requirements changed a few years back to include money out as well as money in. So, they are correctly making a check on closure. If the electronic method fails, they have to revert to the old paper method.

    I have transferred people out of HL many times and never found them to be obstructive or difficult.
    I am an Independent Financial Adviser (IFA). Comments are for discussion purposes only. They are not financial advice. Different people have different needs and what is right for one person may not be for another. If you feel an area discussed may be relevant to you, then please seek advice from a Financial Adviser local to you.
    • TonyWarwick
    • By TonyWarwick 28th Apr 17, 1:24 PM
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    TonyWarwick
    • #6
    • 28th Apr 17, 1:24 PM
    • #6
    • 28th Apr 17, 1:24 PM
    Thanks to both of you (bowlhead99 and dunstonh) for your advice. I think I failed to state the situation as clearly as I should, because HL are indeed definitely seeking AML evidence 'again on exit'. They have now confirmed this because, (as dunstonh states in his/her response), it seems they have a statutory obligation to do so. Apparently this is normally achieved 'invisibly' by online data checks but in my wife's case that seems not to satisfy the case. I guess it is likely to prove the same for me once HL get round to ignoring my 'leading zeros'.

    Thanks again for your help. TW
    • dunstonh
    • By dunstonh 28th Apr 17, 3:30 PM
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    dunstonh
    • #7
    • 28th Apr 17, 3:30 PM
    • #7
    • 28th Apr 17, 3:30 PM
    Don't assume yours will fail. Like most financial firms, we also use electronic methods and you frequently find one passes but the other does not. This often happens in households where all the bills are in the husbands name. Or credit agreements etc. So, the spouse has very little recorded in her name and there isnt enough public domain information to build a sufficient pass score.
    I am an Independent Financial Adviser (IFA). Comments are for discussion purposes only. They are not financial advice. Different people have different needs and what is right for one person may not be for another. If you feel an area discussed may be relevant to you, then please seek advice from a Financial Adviser local to you.
    • Chordeiles
    • By Chordeiles 9th May 17, 9:27 PM
    • 89 Posts
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    Chordeiles
    • #8
    • 9th May 17, 9:27 PM
    • #8
    • 9th May 17, 9:27 PM
    I have transferred people out of HL many times and never found them to be obstructive or difficult.
    Originally posted by dunstonh
    This might be because you are an IFA who can bring them (or take away) lots of clients
    As a simple customer with not much more than £600,000 invested through them I find they can be arrogant and yes, obstructive.
    Right now I am waiting for the answer to a very simple (transferring-out related) query. My mistake was probably to mark it "urgent", I should have realised this will have irked them and they will have put it to the bottom of the pile.
    • george4064
    • By george4064 9th May 17, 9:39 PM
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    george4064
    • #9
    • 9th May 17, 9:39 PM
    • #9
    • 9th May 17, 9:39 PM
    This might be because you are an IFA who can bring them (or take away) lots of clients
    As a simple customer with not much more than £600,000 invested through them I find they can be arrogant and yes, obstructive.
    Right now I am waiting for the answer to a very simple (transferring-out related) query. My mistake was probably to mark it "urgent", I should have realised this will have irked them and they will have put it to the bottom of the pile.
    Originally posted by Chordeiles
    I have about 1/10 of what you have with HL and currently going through an ISA transfer right now, going very smoothly.

    Just remember that a smooth transfer requires both parties to be efficient and co-operative, its not all down to the firm who currently hold the assets.
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    • dunstonh
    • By dunstonh 9th May 17, 10:02 PM
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    dunstonh
    This might be because you are an IFA who can bring them (or take away) lots of clients
    Certainly, wouldn't bring them to HL!!!
    I am an Independent Financial Adviser (IFA). Comments are for discussion purposes only. They are not financial advice. Different people have different needs and what is right for one person may not be for another. If you feel an area discussed may be relevant to you, then please seek advice from a Financial Adviser local to you.
    • Chordeiles
    • By Chordeiles 13th May 17, 4:29 PM
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    Chordeiles
    Just remember that a smooth transfer requires both parties to be efficient and co-operative, its not all down to the firm who currently hold the assets.
    Originally posted by george4064
    How true. But I didn't even send my transfer forms off to the new platform yet, so they haven't had their chance to foul things up ! But HL know I'm going. Doubtless the "other party" responsible for this situation is myself. It's true that if I'm unhappy about the service I receive then I'll say so rather than lying down and taking it, so I'm probably not the perfect customer as far as they are concerned . But actually I'm sort of grateful to them, if they hadn't p****d me off then I might have continued to pay their fees unthinkingly, this way my drawdown can stand to be about £1500 more each year.

    They perhaps haven't worked out yet that my ISA might stay with them, it has only shares, ITs and ETFs, so I'm only paying £45 per annum for it, which is far more comfortable than the thousands I have been paying them to look after my SIPP.

    I've noticed I no longer get the usual emails from them. In particular they stopped emailing me when a new "secure message" is available, but also the general stuff my wife has received from them these past 2 weeks has not been mirrored in my own inbox. Interestingly one of those was an invitation to take part in a survey about how the HL SIPP operates. My wife completed it (making mention of the way the charges get uncompetitive as one's funds rise) but by the final pages it becomes clear that the main aim of the "survey" is to recruit more punters to be case studies in their advertising.
    • Chordeiles
    • By Chordeiles 29th Jun 17, 12:38 PM
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    Chordeiles
    I've noticed I no longer get the usual emails from them
    Originally posted by Chordeiles
    It turns out this was a glitch in their systems (and not just a problem for me). In the early hours of 1st June a whole bunch of emails I should have received during May seemed to get released !

    And the problem on which they seemed reluctant to reply, well after chasing it I got a typiclal HL support "cut and paste" reply that told me lots I already knew, but failed to address my actual question (I wish I had a pound for every time they did this to me). So at the second attempt I did get them to acknowledge the problem I was reporting, I received a very courteous 'phone call thanking me for bringing the error to their attention, and assuring me it would be fixed. But more than six weeks later the problem still isn't fixed. It's a fund that every other platform calls "class B" but HL call it "class I". Yes, I know HL frequently offer different classes, but in this case the ISIN code is the same ! Hence should transfer neatly to my new SIPP provider except the wordy description is plain wrong.

    However, having said all that, I should probably retract any accusation that they are being deliberately obstructive in the matter of my transfer. On reflection I don't think there is anything personal involved, it's just that they aren't as good as their level of fees might lead one to expect.
    • Thrugelmir
    • By Thrugelmir 29th Jun 17, 1:43 PM
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    Thrugelmir
    On reflection I don't think there is anything personal involved, it's just that they aren't as good as their level of fees might lead one to expect.
    Originally posted by Chordeiles
    As a business they'll protect themselves foremost from any risk of imposed financial penalty. Simply not worth the risk. Nor the bad publicity that's generated from the ensuring media coverage.
    “ “Bull markets are born on pessimism, grow on skepticism, mature on optimism, and die on euphoria. The time of maximum pessimism is the best time to buy, and the time of maximum optimism is the best time to sell.” Sir John Marks Templeton
    • seacaitch
    • By seacaitch 29th Jun 17, 1:45 PM
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    seacaitch
    It's a fund that every other platform calls "class B" but HL call it "class I". Yes, I know HL frequently offer different classes, but in this case the ISIN code is the same ! Hence should transfer neatly to my new SIPP provider except the wordy description is plain wrong.
    Originally posted by Chordeiles
    Which fund is this exactly?
    • soulsaver
    • By soulsaver 29th Jun 17, 1:55 PM
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    soulsaver
    Don't forget to check HL for later divis arriving in your account... they'll not email you about them.
    There are 24 bottles of beer in a crate. There are 24 hours in a day. Coincidence? I think not....
    • Chordeiles
    • By Chordeiles 29th Jun 17, 2:57 PM
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    Chordeiles
    Which fund is this exactly?
    Originally posted by seacaitch
    FP Miton Income (ISIN code for accumulation version is GB00B29LZ803). Since you asked the question I thought I'd post links to this fund on the HL website and the same fund on another platform. But when I went to the HL website I see they finally fixed it within the last day ! Maybe they read this forum

    Me, I had finally decided to sell it anyway before the transfer (could not have waited this long), I guess if I had still held it I would have had an email from them advising of the correction.
    Last edited by Chordeiles; 29-06-2017 at 3:13 PM.
    • Chordeiles
    • By Chordeiles 29th Jun 17, 3:05 PM
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    Chordeiles
    Don't forget to check HL for later divis arriving in your account... they'll not email you about them.
    Originally posted by soulsaver
    Are you saying they won't transfer across automatically, albeit in dribs and drabs for six months after the transfer ?

    I thought Selftrade were bad (I left them during their "money laundering" crisis of 2014 and sale from SocGen to Equiniti) but at least all the trailing dividends arrived safely at HL, I did check but needed to chase nothing (on that front, everything else was a mess !).
    Last edited by Chordeiles; 29-06-2017 at 3:09 PM.
    • Chordeiles
    • By Chordeiles 11th Jul 17, 4:52 PM
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    Chordeiles
    It's eight weeks to the day since Alliance Trust Savings received my SIPP transfer application, and today I received a letter from Hargreaves Lansdown asking me to fill in their own "SIPP Transfer Out Form". Now the eight weeks is pretty abysmal but I'm not blaming HL for that, it took a couple of weeks (and a chase-up) to even get ATS to look at my transfer application (they apologised for the backlog in that department, but it doesn't look good). Happily I'm transferring out "in specie", otherwise the loss so far over 8 weeks would be £4905.22

    However the form that HL have just sent me tells them nothing that wasn't already on the form that I sent to ATS - information that was on a page bearing my signature and thus clearly designed to be sent to the previous SIPP provider. So this extra form is clearly designed to delay the transfer. It is accompanied by a letter asking me if I really want to transfer out, an invitation to discuss it to see if there is "anything we can do" - so I called them yet again but they were still not interested in addressing my main issue (increase in SIPP charges in phased drawdown, because of the way they will spit the SIPP into two accounts and apply charges separately to each).
    Last edited by Chordeiles; 11-07-2017 at 6:47 PM.
    • jamiex
    • By jamiex 11th Jul 17, 11:55 PM
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    jamiex
    I'm currently in the process of transferring my Standard Life pension into a SIPP with II.

    It's been about 6 weeks so far. Took about a month for me to receive Standard Life's transfer out paperwork after sending in the II form, and it's been almost 2 weeks since I posted that to SL. I haven't heard anything yet.

    Once I login and see the funds have been sold, I'll know the transfer is happening. Not sure why the process takes so long though.

    Looks like Standard Life work a lot quicker than HL though!
    • dunstonh
    • By dunstonh 15th Jul 17, 12:36 PM
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    dunstonh
    It's been about 6 weeks so far. Took about a month for me to receive Standard Life's transfer out paperwork after sending in the II form, and it's been almost 2 weeks since I posted that to SL. I haven't heard anything yet.
    Std Life dont issue discharge forms any more. Havent done for many years. They usually action transfers within 24 hours of receiving the instruction via ORIGO or the paper instructions.

    Not sure why the process takes so long though.
    Probably as you are not doing it quite right. You are requesting things not needed. If SL had to generate that stuff, it would take longer as they probably need to do it manually. Plus, when that stuff is completed, you return it to the receiving scheme. You do not send it back to the originating scheme.

    Typically, if the receiving scheme informs SL on Monday, the pension is transferred by the Wednesday. SL is one of the fastest out there.
    I am an Independent Financial Adviser (IFA). Comments are for discussion purposes only. They are not financial advice. Different people have different needs and what is right for one person may not be for another. If you feel an area discussed may be relevant to you, then please seek advice from a Financial Adviser local to you.
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