Grrrr.... Willis Towers Watson...

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Comments

  • artyboy
    artyboy Posts: 1,493 Forumite
    1,000 Posts Second Anniversary Name Dropper
    edited 8 September 2023 at 7:56PM
    Tommyjw said:
    artyboy said:
    Tommyjw said:
    artyboy said:
    Marcon said:
    artyboy said:
    WTW might be familiar to you as they are administrators for many occupational pension schemes. Specifically, they administered the scheme for my last employer, and I've got a sizeable amount that I want to move out.

    "Glacial" doesn't even begin to cut it in describing their pace. Not to mention how unnecessarily complicated they make everything - I requested a transfer out so I could be shot of them, and their response to me included 14 separate document attachments. Only 2 required any action. And one of those I had to pick through the bits that were needed with no guidance.

    And I've done a fair few transfers in the past year, but this was the only one where the administrators insisted that I sent them a copy of my passport, so they knew it really was me making the request 

    And now, 2 months on, they write to me saying that, as my receiving scheme (an II SIPP) contains "overseas investments", then I have to have a Pension Safeguarding Guidance session with MoneyHelper. Or sign yet another form to opt out.

    Are these guys serious?? Firstly it's a cash transfer so it's not like the transfer is directly into anything 'overseas'. And secondly, I'd be surprised if ANY pension these days didn't have overseas investments within it. So on the off chance this is a real regulatory requirement, why didn't they include this information/opt out form in the initial pack they sent me??

    As you can tell, this is a bit of a Friday morning rant, but this is just one of a number of issues I've had with WTW, and I can't wait to get shot of them 😡
    They are following hopelessly heavy-handed and frankly plain daft regulations. They can't win. If they follow them, people like you (understandably) start raging; if they don't and something goes wrong, doubtless you'll be first in the queue for 'compensation'.

    Get the paperwork completed and returned and don't waste your time ranting about something which isn't their fault.


    D'you know Marcon... immediately after getting this off my chest, that's exactly what I did.

    And then, because I can't help myself, I decided to revisit the documentation I previously completed. First thing, I should acknowledge that it was 'only' 12 attachments they sent me, not 14. So that's alright then.

    But then I found it - the PensionWise opt out that I signed and sent back to them. Although of course it wasn't the same opt out that I got this time, because the new one came with a bunch of 'on my own head be it' warnings, plus pointing out that the transfer would be discretionary rather than statutory.

    So, that's 2 opt outs for me now, they could I suppose have put the correct legalese in the first one, but why would they do that...? After all, it can't be more than 99.9% of transfers out that would require it...

    Give me strength. Muppets...
    The first opt out form will be for general pension wise nudge, where the leiglsation requires them to ask you to confirm if you have or have't asked spoken to them. See: https://www.fca.org.uk/publications/policy-statements/ps21-21-stronger-nudge-pensions-guidance-feedback-cp21-11-and-final-rules-and-guidance#:~:text=From 1 June 2022 pensions,and purpose of this guidance.

    The second is specific to the MoneyHelper amber flag requirement found because of the overseas investment, see: https://www.thepensionsregulator.gov.uk/en/document-library/scheme-management-detailed-guidance/administration-detailed-guidance/dealing-with-transfer-requests 

    So in both cases this is not a WTW problem, they are following the rules.

    Well ok, let's set aside the fact that WTW could at the very least join the dots that their own overzealous due diligence means that the second version will almost always be needed - and perhaps include it up front.

    Let's even leave aside dunstonh's good point that they could take a far more pragmatic approach.

    Let's instead look at the wording behind this Amber flag for Overseas investments:

    Amber flag 6: Overseas investments are included in the scheme

    The specific concern here is not whether the investment is in, for example, a global equity fund but whether the investment is in assets or funds where there is a lax, or non-existent, regulatory environment or in jurisdictions which allow opaque corporate structures. After carrying out due diligence you may consider the transfer is at a low risk of a scam and, where your scheme rules allow, you may consider granting a discretionary transfer.

    Some overseas advisers recommend members invest their pension funds in an offshore investment bond in an international self-invested personal pension. The FCA has warned that this may expose members to high or unnecessary charges and has stated that the tax benefits of such arrangements are redundant for a member investing in a UK personal pension.

    So... not the fact that they are overseas, but that they might be funds in jurisdictions with poor regulatory oversight. I'd wager that there are no such funds available to retail investors through a U.K. regulated SIPP provider such as II. So why is this flag even being triggered? Having an Irish domiciled fund that invests amongst other things in Tesla, Apple and the like, is hardly in scope of what is set out in the official guidance!

    Given you have already moaned on every single post about how much paperwork was sent, i reckon you'd have moaned yet again if they sent you every single form and guidance and note for every single possible amber flag outcome just so you have it in the first place.

    And in any event, no they cant provide it in the first place, because the legislation states they need to inform members when an amber flag is raised. 
    I 'moaned' because of all the useless twaddle that they sent, which totally obfuscated what was actually needed. Given that WTW's own due diligence approach means that this particular amber flag is going to be raised on pretty much every transfer they make, I find it incomprehensible that they can't pre-empt it.

    I was going to start talking about 'smart forms' and how the pensions industry seems to be 10 years behind banking in creating relevant, focused and intuitive customer documentation, but what's the point, clearly my card is marked as a moaner. Poor WTW, the victim of harsh regulation, and not their own inability to take a pragmatic risk-based approach. 🙄
  • Tommyjw
    Tommyjw Posts: 237 Forumite
    Eighth Anniversary 100 Posts Name Dropper Combo Breaker
    edited 8 September 2023 at 8:04PM
    artyboy said:
    Tommyjw said:
    artyboy said:
    Tommyjw said:
    artyboy said:
    Marcon said:
    artyboy said:
    WTW might be familiar to you as they are administrators for many occupational pension schemes. Specifically, they administered the scheme for my last employer, and I've got a sizeable amount that I want to move out.

    "Glacial" doesn't even begin to cut it in describing their pace. Not to mention how unnecessarily complicated they make everything - I requested a transfer out so I could be shot of them, and their response to me included 14 separate document attachments. Only 2 required any action. And one of those I had to pick through the bits that were needed with no guidance.

    And I've done a fair few transfers in the past year, but this was the only one where the administrators insisted that I sent them a copy of my passport, so they knew it really was me making the request 

    And now, 2 months on, they write to me saying that, as my receiving scheme (an II SIPP) contains "overseas investments", then I have to have a Pension Safeguarding Guidance session with MoneyHelper. Or sign yet another form to opt out.

    Are these guys serious?? Firstly it's a cash transfer so it's not like the transfer is directly into anything 'overseas'. And secondly, I'd be surprised if ANY pension these days didn't have overseas investments within it. So on the off chance this is a real regulatory requirement, why didn't they include this information/opt out form in the initial pack they sent me??

    As you can tell, this is a bit of a Friday morning rant, but this is just one of a number of issues I've had with WTW, and I can't wait to get shot of them 😡
    They are following hopelessly heavy-handed and frankly plain daft regulations. They can't win. If they follow them, people like you (understandably) start raging; if they don't and something goes wrong, doubtless you'll be first in the queue for 'compensation'.

    Get the paperwork completed and returned and don't waste your time ranting about something which isn't their fault.


    D'you know Marcon... immediately after getting this off my chest, that's exactly what I did.

    And then, because I can't help myself, I decided to revisit the documentation I previously completed. First thing, I should acknowledge that it was 'only' 12 attachments they sent me, not 14. So that's alright then.

    But then I found it - the PensionWise opt out that I signed and sent back to them. Although of course it wasn't the same opt out that I got this time, because the new one came with a bunch of 'on my own head be it' warnings, plus pointing out that the transfer would be discretionary rather than statutory.

    So, that's 2 opt outs for me now, they could I suppose have put the correct legalese in the first one, but why would they do that...? After all, it can't be more than 99.9% of transfers out that would require it...

    Give me strength. Muppets...
    The first opt out form will be for general pension wise nudge, where the leiglsation requires them to ask you to confirm if you have or have't asked spoken to them. See: https://www.fca.org.uk/publications/policy-statements/ps21-21-stronger-nudge-pensions-guidance-feedback-cp21-11-and-final-rules-and-guidance#:~:text=From 1 June 2022 pensions,and purpose of this guidance.

    The second is specific to the MoneyHelper amber flag requirement found because of the overseas investment, see: https://www.thepensionsregulator.gov.uk/en/document-library/scheme-management-detailed-guidance/administration-detailed-guidance/dealing-with-transfer-requests 

    So in both cases this is not a WTW problem, they are following the rules.

    Well ok, let's set aside the fact that WTW could at the very least join the dots that their own overzealous due diligence means that the second version will almost always be needed - and perhaps include it up front.

    Let's even leave aside dunstonh's good point that they could take a far more pragmatic approach.

    Let's instead look at the wording behind this Amber flag for Overseas investments:

    Amber flag 6: Overseas investments are included in the scheme

    The specific concern here is not whether the investment is in, for example, a global equity fund but whether the investment is in assets or funds where there is a lax, or non-existent, regulatory environment or in jurisdictions which allow opaque corporate structures. After carrying out due diligence you may consider the transfer is at a low risk of a scam and, where your scheme rules allow, you may consider granting a discretionary transfer.

    Some overseas advisers recommend members invest their pension funds in an offshore investment bond in an international self-invested personal pension. The FCA has warned that this may expose members to high or unnecessary charges and has stated that the tax benefits of such arrangements are redundant for a member investing in a UK personal pension.

    So... not the fact that they are overseas, but that they might be funds in jurisdictions with poor regulatory oversight. I'd wager that there are no such funds available to retail investors through a U.K. regulated SIPP provider such as II. So why is this flag even being triggered? Having an Irish domiciled fund that invests amongst other things in Tesla, Apple and the like, is hardly in scope of what is set out in the official guidance!

    Given you have already moaned on every single post about how much paperwork was sent, i reckon you'd have moaned yet again if they sent you every single form and guidance and note for every single possible amber flag outcome just so you have it in the first place.

    And in any event, no they cant provide it in the first place, because the legislation states they need to inform members when an amber flag is raised. 
    I 'moaned' because of all the useless twaddle that they sent, which totally obfuscated what was actually needed. Given that WTW's own due diligence approach means that this particular amber flag is going to be raised on pretty much every transfer they make, I find it incomprehensible that they can't pre-empt it.

    I was going to start talking about 'smart forms' and how the pensions industry seems to be 10 years behind banking in creating relevant, focused and intuitive customer documentation, but what's the point, clearly my card is marked as a moaner. Poor WTW, the victim of harsh regulation, and not their own inability to take a pragmatic risk-based approach. 🙄
    Just because you dont like it does not make it "useless".

    Would you prefer someone opened up your mail, gave WTW a call, asked them to transfer money to somewhere and they did it? Prefer your old man got cold called and moved his funds overseas because thwey said so? Prefer your mate at work moved his money to a dodgy fund ebcause he was promsied 100% returns? Preferred a dodgy financial adviser faked forms on your behalf and move your pension somewhere else? No? then maybe paperwork has been designed for a reason. 

    It's been repeated it is not WTWs approach regarding the amebr flag, that is legislation, but do keep ignoring that.

    We can go even further, what you're even thinking could be WTW's fault, is actually not their fault, it is the Trustee of your pension schemes fault, because they are the ones who can say to apply discretion regarding amber flags, not WTW. There is absolutely zero people inside WTW as a company for your pension Scheme that can decide to skip the amber flag process, that is completely and utterly 100% on the Trustee.

    Your complete inability to understand whats happening does not make it WTW's fault. If you have an issue, complaint to your Trustee for their decisions as Trustee in which they tell WTW what to do, or complain to your MP to talk to DWP on their legislation wording.
  • xylophone said:
    How far in advance should I notify WTW about that? 

    Presumably you have full details of this pension (Scheme name and member reference number/ years worked/ statement of deferred benefits)?


    Do you receive any individual statements /scheme funding statements from WTW?


    You could always contact WTW at least six months in advance of Scheme NRA and request a scheme retirement pack?

    Yes I have full details.

    The only thing I receive, as routine, is an annual statement about the funding of the scheme, no personal information.
    I received a CETV and statement of benefits six or seven years ago, which I had enquired about.

    Yes, I'll probably request a scheme retirement pack Next Spring. I was just wondering if I needed to do it, one, three, six or more months before getting it into payment, and what documents etc they will be looking for. Which might be something I can sort out this winter, rather than it causing a hold up next year.
  • artyboy
    artyboy Posts: 1,493 Forumite
    1,000 Posts Second Anniversary Name Dropper
    edited 8 September 2023 at 8:16PM
    Tommyjw said:
    artyboy said:
    Tommyjw said:
    artyboy said:
    Tommyjw said:
    artyboy said:
    Marcon said:
    artyboy said:
    WTW might be familiar to you as they are administrators for many occupational pension schemes. Specifically, they administered the scheme for my last employer, and I've got a sizeable amount that I want to move out.

    "Glacial" doesn't even begin to cut it in describing their pace. Not to mention how unnecessarily complicated they make everything - I requested a transfer out so I could be shot of them, and their response to me included 14 separate document attachments. Only 2 required any action. And one of those I had to pick through the bits that were needed with no guidance.

    And I've done a fair few transfers in the past year, but this was the only one where the administrators insisted that I sent them a copy of my passport, so they knew it really was me making the request 

    And now, 2 months on, they write to me saying that, as my receiving scheme (an II SIPP) contains "overseas investments", then I have to have a Pension Safeguarding Guidance session with MoneyHelper. Or sign yet another form to opt out.

    Are these guys serious?? Firstly it's a cash transfer so it's not like the transfer is directly into anything 'overseas'. And secondly, I'd be surprised if ANY pension these days didn't have overseas investments within it. So on the off chance this is a real regulatory requirement, why didn't they include this information/opt out form in the initial pack they sent me??

    As you can tell, this is a bit of a Friday morning rant, but this is just one of a number of issues I've had with WTW, and I can't wait to get shot of them 😡
    They are following hopelessly heavy-handed and frankly plain daft regulations. They can't win. If they follow them, people like you (understandably) start raging; if they don't and something goes wrong, doubtless you'll be first in the queue for 'compensation'.

    Get the paperwork completed and returned and don't waste your time ranting about something which isn't their fault.


    D'you know Marcon... immediately after getting this off my chest, that's exactly what I did.

    And then, because I can't help myself, I decided to revisit the documentation I previously completed. First thing, I should acknowledge that it was 'only' 12 attachments they sent me, not 14. So that's alright then.

    But then I found it - the PensionWise opt out that I signed and sent back to them. Although of course it wasn't the same opt out that I got this time, because the new one came with a bunch of 'on my own head be it' warnings, plus pointing out that the transfer would be discretionary rather than statutory.

    So, that's 2 opt outs for me now, they could I suppose have put the correct legalese in the first one, but why would they do that...? After all, it can't be more than 99.9% of transfers out that would require it...

    Give me strength. Muppets...
    The first opt out form will be for general pension wise nudge, where the leiglsation requires them to ask you to confirm if you have or have't asked spoken to them. See: https://www.fca.org.uk/publications/policy-statements/ps21-21-stronger-nudge-pensions-guidance-feedback-cp21-11-and-final-rules-and-guidance#:~:text=From 1 June 2022 pensions,and purpose of this guidance.

    The second is specific to the MoneyHelper amber flag requirement found because of the overseas investment, see: https://www.thepensionsregulator.gov.uk/en/document-library/scheme-management-detailed-guidance/administration-detailed-guidance/dealing-with-transfer-requests 

    So in both cases this is not a WTW problem, they are following the rules.

    Well ok, let's set aside the fact that WTW could at the very least join the dots that their own overzealous due diligence means that the second version will almost always be needed - and perhaps include it up front.

    Let's even leave aside dunstonh's good point that they could take a far more pragmatic approach.

    Let's instead look at the wording behind this Amber flag for Overseas investments:

    Amber flag 6: Overseas investments are included in the scheme

    The specific concern here is not whether the investment is in, for example, a global equity fund but whether the investment is in assets or funds where there is a lax, or non-existent, regulatory environment or in jurisdictions which allow opaque corporate structures. After carrying out due diligence you may consider the transfer is at a low risk of a scam and, where your scheme rules allow, you may consider granting a discretionary transfer.

    Some overseas advisers recommend members invest their pension funds in an offshore investment bond in an international self-invested personal pension. The FCA has warned that this may expose members to high or unnecessary charges and has stated that the tax benefits of such arrangements are redundant for a member investing in a UK personal pension.

    So... not the fact that they are overseas, but that they might be funds in jurisdictions with poor regulatory oversight. I'd wager that there are no such funds available to retail investors through a U.K. regulated SIPP provider such as II. So why is this flag even being triggered? Having an Irish domiciled fund that invests amongst other things in Tesla, Apple and the like, is hardly in scope of what is set out in the official guidance!

    Given you have already moaned on every single post about how much paperwork was sent, i reckon you'd have moaned yet again if they sent you every single form and guidance and note for every single possible amber flag outcome just so you have it in the first place.

    And in any event, no they cant provide it in the first place, because the legislation states they need to inform members when an amber flag is raised. 
    I 'moaned' because of all the useless twaddle that they sent, which totally obfuscated what was actually needed. Given that WTW's own due diligence approach means that this particular amber flag is going to be raised on pretty much every transfer they make, I find it incomprehensible that they can't pre-empt it.

    I was going to start talking about 'smart forms' and how the pensions industry seems to be 10 years behind banking in creating relevant, focused and intuitive customer documentation, but what's the point, clearly my card is marked as a moaner. Poor WTW, the victim of harsh regulation, and not their own inability to take a pragmatic risk-based approach. 🙄
    Just because you dont like it does not make it "useless".

    Would you prefer someone opened up your mail, gave WTW a call, asked them to transfer money to somewhere and they did it? Prefer your old man got cold called and moved his funds overseas because thwey said so? Prefer your mate at work moved his money to a dodgy fund ebcause he was promsied 100% returns? Preferred a dodgy financial adviser faked forms on your behalf and move your pension somewhere else? No? then maybe paperwork has been designed for a reason. 

    It's been repeated it is not WTWs approach regarding the amebr flag, that is legislation, but do keep ignoring that.

    We can go even further, what you're even thinking could be WTW's fault, is actually not their fault, it is the Trustee of your pension schemes fault, because they are the ones who can say to apply discretion regarding amber flags, not WTW. There is absolutely zero people inside WTW as a company for your pension Scheme that can decide to skip the amber flag process, that is completely and utterly 100% on the Trustee.

    Your complete inability to understand whats happening does not make it WTW's fault. If you have an issue, complaint to your Trustee for their decisions as Trustee in which they tell WTW what to do, or complain to your MP to talk to DWP on their legislation wording.
    Nope, sorry. If they are the victims of overzealous trustees, they should be pushing back as a starting point, and then (If I was WTW and I was seeing this operational inefficiency day in and day out) then I'd be saying - hang on, why don't I ask the 'overseas investments' question up front to the pension holder - that way if they say yes, we can do the amber flag there and then, get the specific moneyhelper appointment scheduled (or waiver completed) rather than wait 2 months and only then say they need it.

    WTW are the customer facing organisation for the pension scheme, plus as an operational service organisation, I would expect they would have targets around efficiency. All of this says they should be doing far better here than they are. 

    My career has been onboarding in banking. If I'd tried to fall back on the fact that 'compliance doesn't like it' or 'that's the law', then I wouldn't have lasted long. The vast majority of the time there are creative solutions, even within a fairly conservative risk appetite. But what I'm seeing here doesn't point to that mindset
  • dunstonh
    dunstonh Posts: 119,237 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Combo Breaker
    Incorrect on the stronger nudge, it is a requirement for them to ask and get an answer. It is no problem if a member says they havent spoken to Pensionwise, but they do have to say one way or the other.
    The reality is that all SIPPs and virtually all platform based pensions trigger the overseas investments flag because they offer ETFs.   SIPPs will also trigger the unregulated investments flag.  Yet retail pension providers are not asking the questions where the providers are considered low risk as they are using their discretion.

    The retail providers have created their own whitelist to allow them to be waived through.   They also have their blacklist that require checking.    Blacklist is perhaps an unfair word as genuine open architecture SIPPs are likely to appear on the blacklist rather than then whitelist but that is purely because the scale of unregulated investments is much greater than a platform based SIPP.  i.e. higher risk.




    I am an Independent Financial Adviser (IFA). The comments I make are just my opinion and are for discussion purposes only. They are not financial advice and you should not treat them as such. If you feel an area discussed may be relevant to you, then please seek advice from an Independent Financial Adviser local to you.
  • HeyYeah
    HeyYeah Posts: 76 Forumite
    Third Anniversary 10 Posts Name Dropper
    HeyYeah said:
    I just transferred one dc pension from WTW to another dc scheme with WTW, both were company pensions. The process was also glacial, eventually I just rang them up every Wednesday to work out what was going on. I think it took 2-3 months.

    The most surreal occurrence was when I phoned to discuss DC1 pension, but was told by the call centre employee (let’s call her ‘emily’) that I needed to speak to someone from DC2 pension. So I was transferred to someone from the DC2 pension, who turned out to be Emily! She was then able to help me.

    There was definitely a check box exercise going on which made it very stressful. Clearly they knew I was who I said I was and exactly who my employers were, but we had to go through the whole charade of sending payslips, passport photos, and all the other stuff! 
    Was that a current employer? As I have no payslips for previous employers.

    So she transferred her to herself?
    Yes I had to provide payslips to prove that I worked for my current employer, despite the fact they were contributing to my pension.

    and yes, she transferred me to herself! I assume it was some reason linked to the IT system but it all seemed pretty silly.
  • Tommyjw
    Tommyjw Posts: 237 Forumite
    Eighth Anniversary 100 Posts Name Dropper Combo Breaker
    edited 8 September 2023 at 9:51PM
    artyboy said:
    Tommyjw said:
    artyboy said:
    Tommyjw said:
    artyboy said:
    Tommyjw said:
    artyboy said:
    Marcon said:
    artyboy said:
    WTW might be familiar to you as they are administrators for many occupational pension schemes. Specifically, they administered the scheme for my last employer, and I've got a sizeable amount that I want to move out.

    "Glacial" doesn't even begin to cut it in describing their pace. Not to mention how unnecessarily complicated they make everything - I requested a transfer out so I could be shot of them, and their response to me included 14 separate document attachments. Only 2 required any action. And one of those I had to pick through the bits that were needed with no guidance.

    And I've done a fair few transfers in the past year, but this was the only one where the administrators insisted that I sent them a copy of my passport, so they knew it really was me making the request 

    And now, 2 months on, they write to me saying that, as my receiving scheme (an II SIPP) contains "overseas investments", then I have to have a Pension Safeguarding Guidance session with MoneyHelper. Or sign yet another form to opt out.

    Are these guys serious?? Firstly it's a cash transfer so it's not like the transfer is directly into anything 'overseas'. And secondly, I'd be surprised if ANY pension these days didn't have overseas investments within it. So on the off chance this is a real regulatory requirement, why didn't they include this information/opt out form in the initial pack they sent me??

    As you can tell, this is a bit of a Friday morning rant, but this is just one of a number of issues I've had with WTW, and I can't wait to get shot of them 😡
    They are following hopelessly heavy-handed and frankly plain daft regulations. They can't win. If they follow them, people like you (understandably) start raging; if they don't and something goes wrong, doubtless you'll be first in the queue for 'compensation'.

    Get the paperwork completed and returned and don't waste your time ranting about something which isn't their fault.


    D'you know Marcon... immediately after getting this off my chest, that's exactly what I did.

    And then, because I can't help myself, I decided to revisit the documentation I previously completed. First thing, I should acknowledge that it was 'only' 12 attachments they sent me, not 14. So that's alright then.

    But then I found it - the PensionWise opt out that I signed and sent back to them. Although of course it wasn't the same opt out that I got this time, because the new one came with a bunch of 'on my own head be it' warnings, plus pointing out that the transfer would be discretionary rather than statutory.

    So, that's 2 opt outs for me now, they could I suppose have put the correct legalese in the first one, but why would they do that...? After all, it can't be more than 99.9% of transfers out that would require it...

    Give me strength. Muppets...
    The first opt out form will be for general pension wise nudge, where the leiglsation requires them to ask you to confirm if you have or have't asked spoken to them. See: https://www.fca.org.uk/publications/policy-statements/ps21-21-stronger-nudge-pensions-guidance-feedback-cp21-11-and-final-rules-and-guidance#:~:text=From 1 June 2022 pensions,and purpose of this guidance.

    The second is specific to the MoneyHelper amber flag requirement found because of the overseas investment, see: https://www.thepensionsregulator.gov.uk/en/document-library/scheme-management-detailed-guidance/administration-detailed-guidance/dealing-with-transfer-requests 

    So in both cases this is not a WTW problem, they are following the rules.

    Well ok, let's set aside the fact that WTW could at the very least join the dots that their own overzealous due diligence means that the second version will almost always be needed - and perhaps include it up front.

    Let's even leave aside dunstonh's good point that they could take a far more pragmatic approach.

    Let's instead look at the wording behind this Amber flag for Overseas investments:

    Amber flag 6: Overseas investments are included in the scheme

    The specific concern here is not whether the investment is in, for example, a global equity fund but whether the investment is in assets or funds where there is a lax, or non-existent, regulatory environment or in jurisdictions which allow opaque corporate structures. After carrying out due diligence you may consider the transfer is at a low risk of a scam and, where your scheme rules allow, you may consider granting a discretionary transfer.

    Some overseas advisers recommend members invest their pension funds in an offshore investment bond in an international self-invested personal pension. The FCA has warned that this may expose members to high or unnecessary charges and has stated that the tax benefits of such arrangements are redundant for a member investing in a UK personal pension.

    So... not the fact that they are overseas, but that they might be funds in jurisdictions with poor regulatory oversight. I'd wager that there are no such funds available to retail investors through a U.K. regulated SIPP provider such as II. So why is this flag even being triggered? Having an Irish domiciled fund that invests amongst other things in Tesla, Apple and the like, is hardly in scope of what is set out in the official guidance!

    Given you have already moaned on every single post about how much paperwork was sent, i reckon you'd have moaned yet again if they sent you every single form and guidance and note for every single possible amber flag outcome just so you have it in the first place.

    And in any event, no they cant provide it in the first place, because the legislation states they need to inform members when an amber flag is raised. 
    I 'moaned' because of all the useless twaddle that they sent, which totally obfuscated what was actually needed. Given that WTW's own due diligence approach means that this particular amber flag is going to be raised on pretty much every transfer they make, I find it incomprehensible that they can't pre-empt it.

    I was going to start talking about 'smart forms' and how the pensions industry seems to be 10 years behind banking in creating relevant, focused and intuitive customer documentation, but what's the point, clearly my card is marked as a moaner. Poor WTW, the victim of harsh regulation, and not their own inability to take a pragmatic risk-based approach. 🙄
    Just because you dont like it does not make it "useless".

    Would you prefer someone opened up your mail, gave WTW a call, asked them to transfer money to somewhere and they did it? Prefer your old man got cold called and moved his funds overseas because thwey said so? Prefer your mate at work moved his money to a dodgy fund ebcause he was promsied 100% returns? Preferred a dodgy financial adviser faked forms on your behalf and move your pension somewhere else? No? then maybe paperwork has been designed for a reason. 

    It's been repeated it is not WTWs approach regarding the amebr flag, that is legislation, but do keep ignoring that.

    We can go even further, what you're even thinking could be WTW's fault, is actually not their fault, it is the Trustee of your pension schemes fault, because they are the ones who can say to apply discretion regarding amber flags, not WTW. There is absolutely zero people inside WTW as a company for your pension Scheme that can decide to skip the amber flag process, that is completely and utterly 100% on the Trustee.

    Your complete inability to understand whats happening does not make it WTW's fault. If you have an issue, complaint to your Trustee for their decisions as Trustee in which they tell WTW what to do, or complain to your MP to talk to DWP on their legislation wording.
    Nope, sorry. If they are the victims of overzealous trustees, they should be pushing back as a starting point, and then (If I was WTW and I was seeing this operational inefficiency day in and day out) then I'd be saying - hang on, why don't I ask the 'overseas investments' question up front to the pension holder - that way if they say yes, we can do the amber flag there and then, get the specific moneyhelper appointment scheduled (or waiver completed) rather than wait 2 months and only then say they need it.

    WTW are the customer facing organisation for the pension scheme, plus as an operational service organisation, I would expect they would have targets around efficiency. All of this says they should be doing far better here than they are. 

    My career has been onboarding in banking. If I'd tried to fall back on the fact that 'compliance doesn't like it' or 'that's the law', then I wouldn't have lasted long. The vast majority of the time there are creative solutions, even within a fairly conservative risk appetite. But what I'm seeing here doesn't point to that mindset
    Following legislation is not being over-zealous. 

    The administrator does not have ultimate decision over the Trustee, it is the other way around. 

    what if you have a MoneyHelper call straight away, and they give you an amber flag for one of the other reasons, and request you have the call again? What if a red flag is spotted and your transfer declined after they had made you speak to MoneyHelper? What if you or your IFA then dont return the paperwork in time and the transfer is void anyway?  you'd likely be coming here to moan at that too?.  It is quite obviously the best practice to wait until all information is available and known 

    As stated, you continue to wholly misunderstand where the issue lies. I (not at WTW but similar) have clients (Trustees) who have told me to blanket proceed with any overseas ivnestment amber flag, i have those who have said they still wish for the MoneyHelper process to proceed, we take their instruction, if you dont like that your Scheme is doing, thats for your Trustee. 
  • xylophone
    xylophone Posts: 45,552 Forumite
    Part of the Furniture 10,000 Posts Name Dropper
    The only thing I receive, as routine, is an annual statement about the funding of the scheme, no personal information.

    I think this is quite common with deferred DB Schemes.

    You have the  scheme details you need to claim your deferred pension and presumably can supply such documents as passport/driving licence if evidence of identity is required.

    And be sure to contact WTW at least six months before Scheme NRA.

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