In compliance with Financial Conduct Authority (FCA) rules, the purpose of this document is to explain the Dentons Pension Management Limited (Dentons) approach to fair value and to provide our distributors with product information relating to our Self Invested Personal Pensions (SIPPs).
Under Consumer Duty rules, the term ‘manufacturer’ refers to firms that create, develop, design, issue, manage, carry out, operate or (for insurance and credit purposes only) underwrite a product or service. Dentons is a service provider of SIPPs and therefore, falls within the definition of a manufacturer.
A 'distributor' relates to firms that offer, sell, recommend, advise on, propose, or provide a product or service. Dentons is a distributor for its SIPP products, however any advice is provided by independent financial advisers.
Some of Dentons customers are non-advised or execution only. This means they have not sought financial advice and have decided to make their own decisions
regarding their investments, so long as this is permitted by the providers of investments and by Dentons as the SIPP provider.
Dentons has made an assessment to ensure that its products provide fair value to retail customers in the target markets for those products and has made a commitment to review the assessment on an annual basis on the first of January each calendar year, prior to publication of fee renewals.
This assessment covers the product and any adaptation of the product in each case before it is marketed or distributed to a retail customer.
The main product is the Dentons SIPP which offers access to a comprehensive range of investment products as detailed in our permitted assets list (see below under Nature of the product). This is supported by the Sippchoice Bespoke SIPP which offers a single investment portfolio, which is a cheaper option for those customers who do not require access to a full range of investments.
These are the main product offerings made by Dentons which are regulated by the FCA. It is not anticipated that any new products will be created in the foreseeable future.
The products are a type of personal pension designed for self-investment. The pension plan is designed to provide Dentons clients with considerable investment flexibility.
The range of investment opportunities is extensive and includes stocks and shares and authorised OEICs, commercial property, unquoted UK equities (subject to individual consideration), unit trusts and investment trusts, insurance company managed funds and unit-linked funds, deposit accounts with authorised
financial institutions, secured commercial loans to unconnected UK limited companies.
There are limitations to our products designed to ensure that HM Revenue and Customs (HMRC) permits the investments and that they are unlikely to give rise to tax penalties.
A full list of the permitted and non-permitted assets can be accessed on our website.
If a client is not taking advantage of the wide range of available investments via the Dentons SIPP, Dentons will contact him/her at the next periodic review and
offer the transfer to the Sippchoice Bespoke SIPP with a lower fee tariff.
Dentons fees are listed in the fees schedule and are a combination of the standard fees for establishment, standard administration (full asset range or single investment portfolio), default bank account fees, investment fees (see permitted assets list above) and services including pension transfers (in and out) and drawing
In addition to the standard administration fees, any additional services are charged on a time-cost basis and reflect the level of work involved and not the value of your fund. This time-cost assessment works across the whole business for additional services and provides a fair method to deal with complex and lengthy administration services. The establishment fee is deducted at outset, but all other fees are invoiced six months in arrears.
A full list of fees and charges can be found on our website.
It is important to note that cost does not equal value and while in some instances our fees may appear higher than our peers, it is our belief that this is reflected in the level of service we provide. Each of our administration teams operate on a cradle-to-grave basis. Furthermore, each client has their own dedicated administrator and highly experienced pension consultant.
Product: Dentons SIPP and Sippchoice Bespoke SIPP
Included within our assessment of fair value are the following factors:
Approximately 70% of SIPP members are advised by IFAs. For the 30% of direct clients, they approach us for services which are either conducted on a non-advised
or execution only basis. Following our Consumer Duty Review. We have amended our procedures so that the checklist has a new action point to send the client a letter to confirm that they have satisfied themselves of the costs and charges associated with the proposed investment. We will not allow the investment to proceed
until we have received this confirmation.
With due diligence procedures and questionnaires, Dentons will continue to assess the comparable costs and services of all investment houses, platforms, fund managers, IFAs, other SIPP providers, regulated introducers, and distributors. Our clients will also be approached for feedback on how we can improve our services.
All data will be analysed at regular MI meetings and investment committee meetings to provide an objective assessment of fair value and any adjustments to our service offering will be made based on the outcomes.
Dentons receives no rebates or commission received from external parties. Dentons does not pay any commission to introducers. Dentons does not operate panels or restrictions - we offer a whole-of market approach when it comes to investment selection, subject to the caveat that Dentons approve them.
Dentons has been recognised for its service by receiving the coveted 5-star award from Financial Adviser Service Awards, as voted for by IFAs ten times. For the 2013 and 2015 awards, Dentons was also awarded top performer in the Life & Pensions category of these awards.
Whatever your retirement needs, one of our experts will be happy to discuss how we can help you achieve your goals.