The NAPF responded to the Pension Regulator’s consultation on its DB Transfers Guidance. In our response we welcomed the very clear description of the role and responsibility of trustees with regard to the new advice safeguard. We also welcomed the brevity of the guidance, which signposts to other existing guidance and best practice ensuring the guidance remains relevant.

However, we do ask for the guidance to provide greater clarity in two areas:

• How trustees check the FCA register of financial advisers; and
• How to manage transfers to oversees pension arrangements

Finally, we urge the Regulator to be proportionate in any enforcement activity where schemes have made efforts to comply with the spirit of the new guidance.

We expect the final guidance to be published before 6 April 2015