So my first month away from AMPS in six years and I was suffering from cold turkey when I saw the release of new guidance by the FCA together with the announcement of a third thematic review.
This past month also saw general attacks on the pensions industry by government and, for the first time to my knowledge, royalty.
The most important recent story for me, though, was the vetting process that HMRC have introduced before they give a pension scheme a tax reference number – that is, before the pension scheme can actually call itself a pension scheme and receive the tax breaks that come with it.
The industry have been calling for this approach for months or even years so it is generally a good move, provided of course that it does not slow down those cases where a quick turnaround is needed.
The warning point for pension providers and advisers is that, in these early days, care must be taken not to promise short turnaround times if you are now reliant on HMRC giving their blessing to your new legitimate scheme.
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In theory there should be no problem with having to wait until HMRC give their blessing to a scheme - we were in a similar position prior to 2006.
The point to takeaway is that you have to manage a client's expectations and you will have to be giving a different message from that a few months ago.
For bores like me, the interesting point was establishing how HMRC had the mandate to bring in this new process (which, for the avoidance of doubt, I think is a good thing).
Legislation [Section 153 of Finance Act 2004] says that HMRC must decide whether or not to register the pension scheme, and so it is clear that the decision rests with HMRC.
However, the legislation continues by clarifying that HMRC's decision must be to register the scheme unless any information contained in the application is incorrect, or any declaration accompanying it is false. So HMRC's powers are limited.
The legislation doesn't apply a timeframe for HMRC to make its decision though and this gives wriggle room for HMRC to review the application for its accuracy and then to decide whether the accompanying declaration is false. Either that, or they have found a way of trumping legislation for the overall good of UK plc.
A little inconvenience is a small price to pay to provide extra protection for consumers and ultimately create a more robust pension world and this small adjustment to the registration process is another small step in the right direction.
Andrew Roberts is a partner at Barnett Waddingham LLP. All views are personal.
@andrewddroberts
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