As you are probably aware, new legislation will come into effect on 3 January 2018. Therefore, we have updated the EBS SIPP Terms of Business document to reflect the below point.
Legislation now requires firms to undertake more extensive reporting of client transactions to the FCA. This means firms need to be able to correctly identify who the client behind the transaction is to complete a report. A client’s National Insurance Number is a key client identifier and therefore if we do not hold a client’s National Insurance Number on our records, then unless we hold sufficient alternative information on a client we will not be able to accurately report the transaction. Because we will not be able to accurately report the identity of the client, the legislation rules prevent us from proceeding with the instruction to execute the transaction.
To view the updated SIPP Terms of Business, click here.