This word is normally used to describe a process of deciding the relative seriousness of patient conditions before deciding who gets treated first. Never the most sophisticated of wordsmiths, our regulator is using it to describe an initial conversation, without stepping across the advice boundary, providing generic, balanced information on the merits or otherwise of DB pension transfers. In their turgid, 58 page, policy document ‘Improving the Quality of Pension Transfer Advice’ the regulator says advisers should not be including a TVC in the Triage process to avoid the risk of straying into financial advice.

Triage (COBS 19.1.11)

The Handbook states that investment advice is being given when a ‘recommendation is made to buy, sell, subscribe for, exchange, redeem, hold or underwrite a particular investment’. How is providing a TVC, without comment, advice? It is information. And information moreover without which any conversation about a transfer would be pretty barren. We recommend that any ‘triage’ activity by firms is limited mainly to the provision of explanatory documents. Remember the FCAs dictum ‘Customer perception is paramount’. However well intentioned, their ‘Triage’ initiative threatens to create a nice little nursery for future complaints.


The above is the lead article in our latest monthly News Notes – December 2018. Other topics in this edition include:

  • Email Scams
  • Cost Disclosure Rules
  • IR35

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Haven Risk Management : FCA Compliance Consultants