Association of Member-Directed Pension Schemes | AMPS

SIPP Capital Adequacy
Written by Geoff Buck on 4th Aug 2014 11:50 am 43268


Capital Adequacy Consultation FCA

The FCA has this morning issued their response to the consultation on SIPP Capital Adequacy CP12/33.

Their response through policy statement PS14/12 is attached.

The AMPS committee is reviewing the document and expects to issue some commentary shortly.


The 30-day rule for property disposals is a worry. Yes, once everything is in place, new SIPP and lawyer identified etc., it may take a few days only per property. But not so obvious if new provider needs to register their new SIPP for VAT. And do we have resources to deal with all our properties in a single 30-day slot? Yes, we would like to argue that we may consider this on a per single property basis and 'in principle'. But once FCA have a rule in place, you can just see them tightening the screw in the futuire and arguing for a much more draconian interpretation so that many or most of our sites become non-standard. I am also troubled by the mixed message; if they are concerned only for strange one-off problem cases (e.g. non-registered sites at Land Registry, perhaps contamination cases) that may take 6-12 months to sort out, why focus on a 30-day turn-around. Also, surely we are reserving funds (i.e. even before non-standard cases) to keep the office open for much more than 30 days (if not the basic capital adequacy level is way too high). My suggestion is that we insist upon a 90-day turn-around or else get very clear and written guidance on what the 30-day timetable covers.
Robert Graham at 13th Aug 2014 9:09 am

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