The skilled person must also verify that Holborn Assets is “adequately identifying and managing its conflicts of interest”.
Headquartered in Dubai, Holborn Assets also has offices in the UK and South Africa.
Simon Parker, chief operating officer of Holborn Assets, told International Adviser: “Our Holborn UK company, which is an entirely separate entity to our Dubai company, has not been closed down. Our ability to provide DB transfer advice has been put on hold pending a review of a number of client files.
“We are engaging independent auditors to go through those files and meet the FCA’s request and have every intention of working closely with the FCA to ensure they are happy with our processes and systems.”
He added: “Indeed we look forward to some clear guidelines and processes from the FCA about what it is they actually want from us in order to move forward.”
The action taken against Holborn Assets follows similar demands from the FCA that deVere UK “immediately cease” providing third-party companies with transfer value analysis (TVAS) reports or other similar reports of information “designed to assist third parties companies in transferring customers defined benefit pensions to an alternative arrangement”.
Past business review
In accordance with section 55L of the Financial Services and Markets Act (2000), Holborn must undertake a past business review of all pension transfer business, including business introduced by overseas and UK advisers, via a skilled person.
The skilled person will conduct 100% pre-sales monitoring for compliance against FCA regulatory requirements for the pension transfer advice business referred to it by UK advisers.
Pipeline business includes any business currently being processed which has not been finalised.
Where, following the review, the proposed advice is deemed to be unclear or unsuitable, the firm must not proceed with the transfer.