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Improving transfers and re-registrations

The Transfers and Re-registration Industry Group (TRIG), comprising representatives from ten major industry trade bodies, has published an industry Framework for firms to work on delivering fast, efficient transfers for the benefit of consumers.

You can see the Framework here.

Along with the Framework, TRIG has published an Request for Proposals for organisations interested in delivering the ongoing governance of the standards Framework. The deadline for submissions is Friday 31 August.

Please see below for Q&A on the framework and the Background to TRIG.


In February 2016, the leading investment and pension trade associations established the Transfers and Re-registration Industry Group (TRIG) to drive forward best practice in transfers and re-registration of customer assets.

This group is chaired by Tom McPhail of Hargreaves Lansdown, and includes the Association of British Insurers, the Association of Member Directed Pension Schemes, the Investment Association, the Pensions Administration Standards Association, the Pension and Lifetime Savings Association, the Personal Investment Management and Financial Advice Association, the Society of Pension Professionals, the Tax Incentivised Savings Association, UK Finance and the UK Platform Group.

During 2016, the TRIG conducted a series of workshops and a scoping exercise. This exercise looked at the institutions involved in the transfers and re-registration landscape, customer expectations, and the product wrappers and assets within the retail investment and pensions market. This enabled us to better understand the scale and complexity of the challenge, which covers a total of 549 different processes.

After this scoping process, a consultation paper was published in December 2016 outlining five proposals to improve the process of transferring pension and investment assets. Submissions for the consultation paper closed on 31 January 2017. A total of 44 responses to the consultation paper were received from various stakeholders across the retail investment and pensions industry.

In August 2017, the group published a Progress Update on this initiative. It includes a brief overview of the responses received to our December 2016 consultation paper, as well as the Group’s proposed next steps, and can be accessed here.

If you have any questions about this initiative, or wish to become involved, please contact Rob Yuille.

Q&A on the framework

  • 1. Why does the framework differ from the scope of the original consultation?

    The TRIG decided to focus the framework on what it can deliver, and which had a direct impact on customer outcomes: transfer times, monitoring data and customer communications. Any wider goals for how the industry conducts transfers and re-registrations were seen to be beyond TRIG's control.

  • 2. Will the governance and standards body take on other projects or functions?

    The original TRIG consultation asked whether a new governance body should be established and whether such a body should take on other functions. There was strong support for a governance body to take this on, but not to establish a new one, and a preference to appoint a body only for the purpose of the industry framework. It may be the case that the successful party from the Request for Proposals takes on other projects. 

  • 3. Why are there different standards for different types of transfer?

    When this project was initiated the aspiration was for a single set of standards, whatever the type of transfer. However, there was a clear desire among stakeholders for end-to-end standards for some types of transfer, and a concern that in transfers with multiple counterparties, parties should not be held responsible for the failures of others. 

    This is intended to be a framework for the industry as it currently is. Given that the industry continues to evolve, there may be further convergence of transfer practice in future. We expect that one role for the governance and standards organisation, which we are seeking in the Request for Proposals document, is to ensure that the standards remain relevant.   

  • 4. When should industry implement the framework?

    This is already good practice, and reflects the standards to which much of the industry already generally adheres. As it is voluntary, there is no implementation deadline, but the framework encourages firms to meet the timescales more consistently; and we expect the FCA, DWP and TPR to use it as a tool with which to monitor the progress of individual firms and parts of the industry. 

  • 5. Why is it voluntary?

    The associations in the TRIG are not in a position to compel, supervise and enforce against their members. The intention of the industry in taking the lead has been that the FCA need not make rules, and DWP need not legislate to achieve the same outcomes; but both have indicated that they will consider further action if they do not see improvements. 

  • 6. What role will TRIG have on an ongoing basis?

    The TRIG will manage the RfP process, and may have a role in future governance arrangements. The associations will continue to take an interest in transfers and re-registrations.