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Darren Winfield: How to meet FCA expectations through faster platform transfers

October 25, 2025
in Retirement
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Darren Winfield: How to meet FCA expectations through faster platform transfers


Platform transfer efficiency has become a defining Consumer Duty issue. Advisers are under growing pressure to ensure transfers are fast, fair, and transparent – not only to meet FCA expectations, but to deliver genuinely better outcomes for clients.

Darren Winfield

New Defaqto data reveals a wide variation in transfer times, from as little as five days to as long as 110 days, raising serious questions about platform consistency, client experience and fair value across the market.

Transfers may seem operational, but they sit at the heart of the FCA’s principle that firms must act honestly, fairly and professionally in clients’ best interests.

Advisers often recommend platform changes to secure better value, functionality or service for clients. However, lengthy or poorly managed transfers can disrupt investment strategies and damage trust.

Consumer Duty strengthens expectations around timeliness, clarity and accountability, while CASS rules ensure client assets are safeguarded in transit.

These frameworks make transfer performance a key indicator of whether firms are truly delivering fair value and avoiding foreseeable harm.

The transparency gap

Around 3.9m Letters of Authority (LOAs) are produced each year, costing the industry £442m in administration.

Some platforms now publish clear performance metrics, but others remain opaque, leaving advisers and clients without visibility of what to expect.

This inconsistency not only frustrates advisers, but also conflicts with the FCA’s move toward data-led accountability.

Transparent benchmarking of transfer times would help advisers make smarter decisions. An industry-wide standard, such as the STAR initiative, could build greater confidence and consistency across the market.

Transfer times now form part of the fair value conversation. Transparency is integral to Consumer Duty delivery.

Streamlining transfers: Adviser best practice

While advisers cannot control every element of a platform’s process, they can influence outcomes through due diligence, efficient processes, and proactive communication.

Creating an internal tracking system to monitor each transfer helps identify recurring delays and underperforming providers.

Partnering with platforms that publish service standards and belong to STAR or TISA schemes provides added assurance of quality and accountability.

Letters of authority: Getting it right first time

The LOA remains the critical first step in most transfers, and one of the biggest sources of delay. Errors, omissions or unclear wording frequently trigger rejections and repeat submissions.

Tips to improve efficiency:

  • Ensure LOAs are accurate, legible and digitally submitted wherever possible
  • Use centralised tracking to identify missing information early
  • Encourage platforms to use digital validation tools to reduce back-and-forth

A clear, complete LOA can save days in processing time and improve client confidence in the transfer journey.

Using FCA IAAT,RIATT & DBAAT templates

The templates are:

  • IAAT Investment Advice Assessment Tool
  • RIAAT Retirement Income Advice Assessment Tool
  • DBAAT Defined Benefit Advice Assessment Tool

Firms using these templates should experience fewer rejections, faster turnaround, and improved auditability. 

Digital vs manual transfers

The difference between digital and manual transfers is stark. Digitised processes allow for secure document uploads, instant submission, real-time progress tracking and automated updates. 

Under Consumer Duty, firms must consider whether outdated manual approaches could cause foreseeable harm by hindering clients from achieving good outcomes. 

Digital transfer capability is fundamental to efficient, fair, and compliant client outcomes.

Efficient transfers equal better outcomes

Efficient transfers are more than an operational goal, they reflect a firm’s commitment to service excellence and transparency.

Advisers who can move clients quickly and clearly between platforms demonstrate control, responsiveness and client focus.

Conversely, those unable to explain or manage long delays risk eroding trust and attracting regulatory scrutiny. 

Practical tips for advisers

  • Audit platform partners using objective Defaqto Engage data to evidence fair value
  • Communicate proactively with clients about expected timelines and any delays
  • Collaborate with STAR or TISA-affiliated providers for greater process consistency
  • Monitor and record transfer times to build internal benchmarks and identify issues early
  • Integrate digital transfer tracking into CRM systems for real-time visibility
  • Review and refresh LOA templates regularly, aligning them with FCA standards or via services such as Criterion.

Efficient transfers are a tangible expression of Consumer Duty in action. They show clients that good outcomes are more than just a promise.

The bottom line

Adviser platform transfers are a visible measure of how firms balance compliance, service quality, and commercial value.

By embedding measurable performance tracking, embracing digital tools, and partnering with transparent, data-driven platforms, advisers can deliver faster, smoother transfers that clearly demonstrate fair value and client-centric outcomes. 

Ultimately, efficient transfers are proof of Consumer Duty in practice, turning regulatory obligation into real-world service excellence that benefits everyone.

Darren Winfield is insight consultant at Defaqto

Editorial Team

Editorial Team

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