Standards for the Single Financial Guidance Body and its delivery partners

The Single Financial Guidance Body (SFGB) is required to publish standards which apply to it, and its partners’ delivery of debt advice, money guidance, Pension Wise guidance and general pensions guidance.

Set out below are interim standards which will allow the SFGB to meet its statutory obligations when it begins to deliver advice and guidance. They have been designed to complement existing standards as far as possible to avoid any impact to service delivery. These standards will be updated alongside the development of the organisation’s corporate plan to reflect any changes to its approach to delivering its services. As such, these standards will be updated in due course, in accordance with the SFGB’s statutory obligations.

The standards set out, at a high-level, requirements in relation to delivery of services provided by the SFGB that must be met by both the SFGB and its delivery partners. The SFGB is responsible for monitoring and enforcing the standards and reporting on its findings through its annual reporting and business planning processes.

These standards are intended to set out clearly, and in once place, the principles of delivery of the SFGB advice and guidance functions and can be applied to direct provision of advice or guidance by the SFGB as it exists now, or in the future. They do not replace or supersede any existing grant agreements or contracts held with the SFGB, and they are in addition to any rules and regulatory requirements set by the FCA.

All services delivered by the SFGB
Must be independent and impartial; and
Free at point of delivery

Note - all references to ‘providers’ and ‘delivery partners’ in the following document are references to entities that are contracted to provide services for the SFGB in pursuit of its advice/guidance functions.

Debt advice

Scope of customer service

  1. Debt advice providers and the SFGB must:
    1. Maintain high quality and consistent standards in accordance with:
      1. the Debt Advice Quality Framework
      2. the Statements of Requirements in the grants and contracts for each service.
    2. Deliver tailored, high quality, consistent and timely debt advice.
    3. Aim to achieve positive client outcomes during the initial debt crisis and throughout the management of over-indebtedness.

Content of session

  1. A structured advice intervention must do the following:
    1. inform clients of the scope, purpose and limitations of the intervention;
    2. inform clients about the personal and financial information that the advice provider or the SFGB may request during the intervention;
    3. request information about the client’s financial and personal circumstances relevant to their creditors, debts and household;
    4. identify any emergency or urgent issues related to the client’s debts;
    5. alert clients to other sources of information, guidance and advice as appropriate and at relevant points during, or following the intervention;
    6. identify and provide the client with information and advice about the options relevant to them, the actions to be taken, and by whom;
    7. set out the next steps for the advice organisation / SFGB / client to take;
    8. provide clients with a record of their advice intervention and of agreed action;
    9. and create and maintain a detailed client record.
  2. Debt advice provider(s) may also deliver interventions which are outside of the structure and which may include self-help support or directing clients to other suitable channels upon assessment.

Delivery Channel

  1. Debt advice provider(s) must identify appropriate delivery channels through drawing on best available evidence about needs, client behaviours and preferences to ensure advice is delivered in accessible and convenient ways for clients. Where applicable, delivery of the service must be consistent across different delivery channels.
  2. Debt advice providers and the SFGB must:
    1. offer specified channels in accordance with service agreements;
    2. develop and maintain partnerships at the local and national level to coordinate signposting and referral of clients to alternative channels; and
    3. assess clients’ suitability for their selected channel and signpost them to alternative channels where appropriate.

Delivering debt advice

  1. Debt advice providers and the SFGB must provide tailored, accurate, consistent and timely high-quality advice.
  2. Debt advice providers and the SFGB must use clear tools and guidelines to support advisers to recognise and recommend other income opportunities that are relevant and specific to the client.
  3. Debt advice providers and the SFGB must use the most recent version of the Standard Financial Statement during the advice intervention.

Provision of advice

  1. Advice must be provided by an appropriately trained or qualified adviser and underpinned, where relevant, by support staff’s preparatory work.
  2. Advice must be presented in an easy-to-understand way, using sector established good practice materials/templates.
  3. Debt advice providers and the SFGB must ensure that clients are always given the option of taking actions themselves in relation to setting up their solution, including negotiating with creditors where appropriate.
  4. Debt advice providers and the SFGB must ask clients if they would like wider support materials offering information or guidance and if so, provide them with the materials they can refer back to.

Follow-up and record of advice

  1. Debt advice providers and the SFGB must establish clear action(s), follow up and future contact points where relevant. Follow up must provide the opportunity for clients to provide feedback on their experience.
  2. Debt advice providers and the SFGB must send a concise, tailored confirmation of advice letter clearly outlining:
    1. an overview of what was discussed;
    2. what the options would mean for the client;
    3. what the service will do next;
    4. what the client will do next;
    5. how to get in touch;
    6. a reminder that if the client left out any information/if their situation changes, other options may be better; and
    7. a separate document/attachment that outlines all options available to the client (this can be generic).
  3. Debt advice providers and the SFGB must establish clear referral pathways (in-house or externally) for the full range of available statutory and non-statutory debt solutions which best meet the client’s needs.

Professional Standards

  1. Debt advisers must undertake continuous professional development, keeping up to date and developing their knowledge base further, to help clients achieve lasting and positive outcomes from advice.
  2. Debt advisers must be trained or qualified appropriately for the debt advice related activity that they undertake with clients as set out in the Debt Advice Quality Framework.
  3. All Debt advisers must have access to frequent supervision.
  4. Debt advisers must meet the standards and parameters set out in the Performance Management Framework (PMF) for delivery partners of debt advice.

Communications

  1. Debt advice providers and the SFGB must ensure that first contact feels easy, timely and reassuring.
  2. Debt advice providers and the SFGB must support clients to reach the service that’s right for them including through collaboration between advice providers to ensure needs are met in a holistic manner.
  3. Debt advice organisations and the SFGB must consider the information needs of clients using the service, and communicate information to them in an appropriate, clear and impartial manner.
  4. Debt advice providers and the SFGB must ensure that sources of information, guidance, advice, and tools are periodically assessed to ensure they are up to date and of a good quality.

Promotion and Access

  1. Where relevant to the channel of the intervention, debt advice providers and the SFGB must provide premises that are physically accessible, including for clients with mobility issues.
  2. Where the debt advice provider or SFGB has a digital presence (i.e. a website) it must have up-to-date information about access to the service including locations (where appropriate) and contact details. Digital content must use clear language.
  3. Debt advice providers and the SFGB must engage in advertising and/or outreach/ messenger referral.
  4. Debt advice providers and the SFGB must co-ordinate client access to translation services, including for BSL users.

Record of advice intervention

  1. Debt advice providers and SFGB must evidence all debt advice interventions with a comprehensive case record. This will include client and third-party interactions and any work undertaken to progress or review the case.

Systems and controls

  1. Debt advice providers and the SFGB must deliver the service with due diligence, and independent control audits provide assurance that agreements are being managed effectively and risks mitigated.
  2. Debt advice providers and the SFGB must assess whether they are required to be regulated to provide advice (or exempt).
  3. Debt advice providers must enable the SFGB to measure client outcomes to assess effectiveness of advice interventions.
  4. Debt advice providers and the SFGB must be independently quality assured (unless exempt) by a standard accredited to the Quality Framework to ensure they are set up to facilitate the consistent provision of effective, high quality debt advice.
  5. Debt advice providers and the SFGB must collect and make available high quality data to enable accurate reporting and analysis.
  6. Debt advice providers and the SFGB must monitor the level of client satisfaction pre, post and during the advice intervention along with the impact of the intervention, to aid improvement of service delivery.
  7. Debt advice providers and the SFGB must ensure compliance with statutory requirements and support Public Sector Equality Duty obligations.
  8. Debt advice providers and the SFGB must ensure compliance with relevant data protection laws.

Complaints management

  1. Debt advice providers and the SFGB must have in place a complaints policy for customers that ensures complaints in connection with the delivery of the advice service are investigated fairly, consistently and promptly and the outcome and process is clearly communicated to customers. The policy must be clearly communicated to customers and guidance providers must keep an accurate record of complaints. The complaints process will have routine monitoring to inform service improvement.

Money guidance

Scope of customer service

  1. The SFGB and its delivery partners must maintain high quality and consistent standards across money guidance services administered or commissioned by the SFGB. This should aim to ensure that money guidance and information is delivered effectively and enables its target audience to make informed decisions.

Content of session

  1. The SFGB and its delivery partners will provide information and guidance which improves the ability of members of the public to make informed financial decisions [Financial Guidance and Claims Act 2(a)], increase their financial knowledge and skills, encourages them to understand their attitudes and motivations and enables them to make good decisions about their money.
  2. SFGB and its delivery partners will not provide regulated advice through its money guidance duty. If a customer needs to access regulated advice, SFGB and its delivery partners will identify and recommend this and set out to the customer how they can access regulated advice.

Delivery Channel

  1. Money guidance provider(s) should identify appropriate delivery channels through drawing on best available evidence about needs, consumer behaviours and preferences to ensure guidance is delivered in accessible and convenient ways for consumers. Where applicable, delivery of the service must be consistent across different delivery channels.

Delivering the guidance

  1. Guidance delivered must:
    1. be impartial and accurate;
    2. be accessible and easy-to-use;
    3. maintain a clear boundary with regulated activities and, where applicable, must form part of the consumer journey, with effective referrals and hand-offs;
    4. be timely and relevant to its audience and seek to influence people’s behaviour and perceptions;
    5. be subject to proportionate evaluation of its effectiveness in order to adapt and improve the guidance service;
    6. seek to drive financially capable decisions and actions. Where applicable, SFGB and it delivery partners must provide clear calls to action, next steps or hand-offs to other organisations; and
    7. when providing a consumer with information about their options, a designated guidance provider may:
      1. provide the consumer with information about particular types of financial products or services that may be relevant and the potential advantages and disadvantages of those options;
      2. refer a consumer to a directory or other list of financial advisers or providers of financial services or products; and
      3. refer a consumer to their existing product provider where the consumer needs that provider to take action to implement one of their options.
  2. A designated guidance provider must not:
    1. introduce or, explicitly or implicitly, recommend a provider of a financial service or product, or a financial adviser;
    2. sell, arrange or facilitate the sale of, or explicitly or implicitly recommend, a financial service or product.
  3. A guidance session must do the following:
    1. inform consumers of the scope, purpose and limitations of the session
    2. inform consumers about the personal and financial information that the designated guidance provider may request from them during the session
    3. request information about the consumer’s financial and personal circumstances
    4. alert the consumer to other sources of information and advice as appropriate and at relevant points during the session
    5. identify and provide for the consumer relevant information, options and next steps for the consumer to take

Communications

  1. Where applicable, money guidance must be provided in an engaging tone and using clear language that is relevant to its target audience.
  2. Money guidance providers must seek to raise awareness of guidance in ways that are be focused, timely and relevant. This includes, but is not limited to, targeting specific audiences of consumers most in need and working through trusted messengers to reach and engage that audience.
  3. Money guidance providers must actively tackle known barriers consumers face to accessing help with money, including boosting awareness of guidance available, building trust in impartial unbiased guidance and providing guidance in ways that address consumers’ financial confidence.
  4. Where providing money guidance through a one-to-one interaction, guidance providers must enable customers to take action by identifying, recording and helping prioritise the customer’s follow-up actions.

Record of guidance session

  1. Records are kept for sessions that involve personal interaction (e.g. face-to-face, telephone sessions, webchat, e-mail, post) and are recorded in line with relevant data protection laws.

Systems and controls

  1. A designated guidance provider must arrange for orderly records in its provision of the service which, where applicable, must be sufficient to enable the Financial Conduct Authority to monitor the designated guidance provider’s compliance with these standards, to be kept for a period of two years.

Complaints management

  1. Money guidance providers must have in place a complaints policy for customers that ensures complaints in connection with the delivery of the guidance service are investigated fairly, consistently and promptly and the outcome and process is clearly communicated to customers. The policy must be clearly communicated to customers and guidance providers must keep an accurate record of complaints.

General pension guidance

Scope of customer service

  1. The general pensions guidance service will give information & guidance on matters relating to occupational and personal pensions

Content of session

  1. Pensions technical and guidance specialists must tell the client that the guidance provided is not regulated advice and the guidance provider cannot tell customers what to do, nor will they provide a definitive course of action.

Delivery Channel

  1. The provider must identify appropriate delivery channels through drawing on best available evidence about needs and consumer behaviours and preferences to ensure guidance is delivered in accessible and convenient ways for consumers

Delivering the guidance

  1. Pensions technical guidance specialists will deliver the service with due skill, care and diligence.
  2. Pensions technical guidance specialists must provide information and guidance on an independent and impartial basis.
  3. Pensions technical guidance specialists have the skills, knowledge and expertise necessary to deliver guidance to the consumer.
  4. A Pensions technical guidance specialist must not:
    1. introduce or, explicitly or implicitly, recommend a provider of a financial service or product, or a financial adviser; and
    2. sell, arrange or facilitate the sale of, or explicitly or implicitly recommend, a financial service or product.

Communications

  1. Pensions technical guidance specialists must consider the information needs of consumers using the service and communicate information to them in a way that is clear, fair and not misleading.
  2. Pensions technical guidance specialists have good interpersonal skills including listening skills and verbal communication skills.

Record of guidance session

  1. Records of the guidance session are made and kept according to the privacy policy and in compliance with relevant data protection laws.

Systems and controls

  1. The general pensions guidance service must ensure compliance with relevant data protection laws.
  2. There should be a systematic approach to continuous improvement. This should include:
    1. a robust quality assurance system;
    2. technical training;
    3. review of technical content by subject matter experts; and
    4. feedback to guidance specialists and their line managers.

Complaints management

  1. The general pensions guidance service must have in place a complaints policy for customers that ensures complaints in connection with the delivery of the guidance service are investigated fairly, consistently and promptly and the outcome and process is clearly communicated to customers. The policy must be clearly communicated to customers and guidance providers must keep an accurate record of complaints.

Pension Wise Guidance

Scope of customer service

  1. Specific pensions guidance sessions must provide information and guidance for the purpose of helping people to make decisions about what to do with their flexible benefits.

Content of session

  1. A structured guidance session must do the following:
    1. inform consumers of the scope, purpose and limitations of the session;
    2. inform consumers about the pension entitlement and other personal and financial information that the Pension Wise guidance provider may request from them during the session;
    3. request information from the consumer about their accumulated pension pots, including the information specified in [Annex A];
    4. request information about the consumer’s financial and personal circumstances that is relevant to their retirement options, including the information specified in [Annex A];
    5. alert the consumer to other sources of information and advice as appropriate and at relevant points during the session;
    6. identify for the consumer and provide them with information about:
      1. the options relevant to the consumer;
      2. to the extent that they are relevant to the consumer’s options, the factors in [standard 13(d)] and the other issues in [standard 13(g)]; and
      3. the potential tax implications and/or debt obligations.
    7. set out the next steps for the consumer to take under [standard 16];
    8. provide consumers with a record of their guidance session in accordance with standard 18.

Delivery Channel

  1. A pension wise guidance provider must, by itself or, where appropriate, working with other pension wise guidance providers ensure that:
    1. the delivery of a structured guidance session is consistent across all the delivery channels under [standard 4];
    2. consumers using the service are able to change to a different delivery channel;
    3. where consumers change delivery channels delivery channels, duplication of the content set out in [standard 1] is minimised; and
    4. the service is accessible to consumers under relevant equalities legislation.

Delivering the guidance

  1. A Pension Wise guidance provider must co-operate and work with other Pension Wise guidance providers to deliver the service in accordance with the standards.
  2. Pension Wise guidance providers must work together to establish a consistent process for delivering the content of a structured guidance session, including the content specified in [standard 1]
  3. A structured guidance session may consist of one or more appointments.
  4. A Pension Wise guidance provider must ensure that the service is available to consumers in a timely manner.
  5. A Pension Wise guidance provider must deliver the service with due skill, care and diligence.
  6. A Pension Wise guidance provider must ensure that the service it delivers is of a good quality.
  7. A Pension Wise guidance provider must not receive any financial or other incentive in connection with the service (other than funding under Section 11 and 5(4) of the Financial Guidance and Claims Act).
  8. When providing a consumer with information about their retirement options, a Pension Wise guidance provider may:
    1. provide the consumer with information about particular types of financial products or services that may be relevant to those retirement options and the potential advantages and disadvantages of those options;
    2. refer a consumer to a directory or other list of financial advisers or providers of financial services or products; and
    3. refer a consumer to their existing pension product provider where the consumer needs that provider to take action to implement one of the retirement options.
  9. A Pension Wise guidance provider must not:
    1. introduce or, explicitly or implicitly, recommend a provider of a financial service or product, or a financial adviser, except as set out in [standard 10(b) or (c)]; and
    2. sell, arrange or facilitate the sale of, or explicitly or implicitly recommend, a financial service or product, except as set out in [standard 10(a)].

Professional standards

  1. A Pension Wise guidance provider must ensure that its personnel who:
    1. deliver the service over the phone, in person or through the internet;
    2. design or approve any processes, models or tools, including internet-based material, related to the service have the skills, knowledge and expertise necessary for the discharge of the responsibilities allocated to them.
  2. A Pension Wise guidance provider must ensure that the personnel who are referred to in [standard 12] have knowledge of:
    1. the different types of pension schemes;
    2. the impact of fees and charges for both accumulation and decumulation pension products;
    3. the options available to consumers when accessing their pension savings;
    4. the factors relevant to the selection of options when accessing pension savings, including the impact of guarantees, special features, restrictions or conditions, protected rights, and exit charges;
    5. the tax treatment of pensions and income generally;
    6. the circumstances when a consumer may require further specialist help, for example debt advice, or regulated advice;
    7. other issues that are relevant to consumers considering their retirement options, for example long-term care needs, sustainability of income in retirement and life expectancy; and
    8. the conduct that a Pension Wise guidance provider may or must not engage in under [standards 10 and 11], respectively.

Communications

  1. A Pension Wise guidance provider must consider the information needs of consumers using the service and communicate information to them in a way that is clear, fair and not misleading.
  2. At the end of a structured guidance session, a Pension Wise guidance provider must:
    1. subject to [standard 11], refer the consumer to relevant sources of further information, guidance, specialist advice, regulated advice, support tools or directories;
    2. draw the consumer’s attention to the importance of shopping around when making decisions about retirement options; and
    3. draw the consumer’s attention to the potential tax implications and/or debt obligations under [standard 1(f)(iii)] and refer them to support services, as appropriate.
  3. A Pension Wise guidance provider must ensure that sources of further information, guidance, specialist advice, regulated advice, support tools and directories referred to in [standard 16] have been periodically assessed to be of a good quality.

Record of a structured guidance session

  1. A Pension Wise guidance provider must provide a consumer with a record of a structured guidance session in the standard format set out in [standard 19].
  2. Pension Wise guidance providers must work together to agree a standard format for providing records of structured guidance sessions which includes the following:
    1. the options discussed with the consumer;
    2. the factors relevant to the exercise of the consumer’s options, as identified during the session;
    3. sources of information or specialist advice;
    4. information on how to shop around for any products that are relevant to the consumer’s retirement options; and
    5. a statement that the consumer is responsible for any decisions they make.

Systems and controls

  1. A Pension Wise guidance provider must ensure compliance with relevant data protection laws.
  2. A Pension Wise guidance provider must arrange for orderly records in its provision of the service, which must be sufficient to enable the [SFGB] to monitor the Pension Wise guidance provider’s compliance with these standards, to be kept for a period of two years.

Complaints management

  1. A Pension Wise guidance provider must ensure that consumers have access to a complaint management system that fairly, consistently and promptly investigates complaints arising in connection with the delivery of the service by the Pension Wise guidance provider.
  2. A Pension Wise guidance provider must ensure that:
    1. consumers are informed of the availability of the complaint management system; and
    2. details of the complaints handling procedures are made available to consumers on a website, with copies supplied to consumers who request them or make a complaint.
  3. A Pension Wise guidance provider must ensure that a record of each complaint received and the measures taken for its resolution is kept and retained for at least two years from the date the complaint was received.

[Annex A Relevant information]

This Part relates to [standard 1].

  1. Information about accumulated pension pots
    1. Relevant information from the consumer about their accumulated pension pots includes information about:
      1. the sum of money that will be available to exercise options in retirement
      2. whether any guarantees apply
      3. any benefits, exit fees and ongoing charges
      4. any other relevant special features, restrictions, or conditions that apply, such as (for with-profits funds)
      5. any market value reduction conditions in place, and
      6. any other information relevant to the exercise of the consumer’s options
  2. Relevant information about the consumer’s financial and personal circumstances includes the following.
    1. Financial information
      1. spouse/partner’s pension pots or benefits and other income
      2. current and future sources of income
      3. capital expectations
      4. tax status
      5. entitlement to state benefits (current and future)
      6. home owner or renting
      7. debt position
    2. Personal circumstances
      1. dependants
      2. spouse/partner
      3. state of health
      4. potential long-term care needs
      5. the consumer’s plan and objectives for retirement, to identify retirement income needs