Pensions and the cobbled-together COBS 19

COBS 19, the section of the Financial Conduct Authority handbook that specifically deals with pensions, is "a modest building that has become gaudy and chaotic with all the extensions added to it." Time for a big picture re-think of this fast-growing set of rules, says Adam Samuel.

Adam SamuelBA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted at adamsamuel@aol.com. His book, 'Complaints and Compensation: a Guide to the Financial Services Market', is available from his website, www.adamsamuel.com.

COBS 19 is the provision of the rulebook that keeps on giving, or expanding, depending on your perspective. Originally drafted in time for the re-writing of COBS in November 2007, it replaced the suitability rules and guidance contained in COB 5.3.21-29. For its first two-and-a-half years, COBS 19.1-19.4 remained the refuge of pension transfer anoraks and an annoyance for pension companies trying to sell duff annuities to their faithful customers. Small changes to COBS 19.4.1, in both July 2010 and April 2011, hardly quickened the pulses. In 2012, the regulator recast chunks of 19.1 and fiddled with 19.2.2. Apart from that, things were quiet until Spring 2015.