LTA protection checks when crystallising pension benefits
HMRC has recently implemented a requirement to check whether a customer’s Lifetime Allowance (LTA) protection is still valid when a client’s pension fund is being crystallised.
We do this by cross-checking the client’s Protection Notification Number and Scheme Administrator Reference with a real-time HMRC online portal.
We will initially check the customer file for this information, but if we don’t hold both references we may have to delay authorisation of the crystallisation and contact the adviser to source the missing information.
For new accounts or new protection, please ensure that the certificate or written acknowledgement from HMRC confirming both of the above references is provided at outset so this does not delay future crystallisation.
We are also investigating the use of Platform scans and other back office information we already hold to try and proactively identify cases where we currently don’t have what we would need to authorise a pension crystallisation immediately. More news will follow on this.
Adding ETIs on platform
One of the investment solutions we offer is Exchange Traded Instruments (ETIs).
Whilst the ETI universe is vast and the client has the choice to invest in almost anything they choose, there are often ETI we do not have. This is not normally an issue as they can be added to the platform, but in order to do so they must meet the below criteria:
1 Not CREST restricted
2 Trades on the London Stock Exchange
3 Trades in GBP
If the ETI fulfils this criteria, you can send an email request to our funds team mailbox to get it added - email@example.com
As a minimum standard, please include the following information in the request (which is all available on the London Stock Exchange website):
1 Name of ETI
2 Citi code
As well as adding the ETI to the platform, if you wish to invest a client into an ETI and haven’t done so previously, you'll need to answer the MiFID II national identifier questions for the client. These will need to be added by our back office before any trades can be placed.
If the client is a person, we will need to know all of their nationalities, with a prescribed national identifier for the priority nationality based on rules set by the regulator. This will most likely be the client’s national identity number or passport number.
For UK nationals, we require the National Insurance number, which we’ll already hold. For some countries (such as Germany and France), the identifier is a combination of their nationality, surname and date of birth. If the client is a company, trust, or charity, we will require a Legal Entity Identifier (LEI).
Once the details have been collected, they should be sent to the Zurich portfolio team to add to the client’s customer details on platform. Only once these customer details have been saved will you be able to trade in ETIs for that portfolio.
Taking pension benefits early due to ill health
If you wish to find out in advance whether your client will be eligible to take benefits from their Retirement Account prior to age 55 (assuming they don’t have a protected pension age), an Ill health medical evidence form (under 'Retirement account' select 'Documents' and see under 'Forms') will need to be completed
If the client is in serious ill health (i.e. has a life expectancy of less than one year), they can take the whole of the Retirement Account as a cash lump sum which is tax free if they have not yet reached 75. In those circumstances, a 'serious ill health claim form' will need to be completed.
Whilst the adviser may have other evidence of health we will always require the above forms to be completed. If a registered medical practitioner signs and stamps the relevant form we will process the claim accordingly (there's nothing for us to underwrite in the traditional assurance sense).