There is an update from the FCA (see link above) – they have updated the “Allowing for ongoing product charges and ongoing adviser charges” section
That is not a controversial update in our view. The regulator’s reasonable expectation is that the complainant is compensated for personal pension charges that he will incur in this flexible personal pension arrangement – that is both product and advisor charges. The “on-going” part merely refers to the fact that the calculation determines the present value at normal retirement and discounts this value to the calculation date – that pre-retirement discount rate incorporates both product and advisor charges.
What the regulator does not want to see is advisors gaming the system by “switching” off advisor charges – in practice the consumer would need on-going advice whether it is from the current advisor or some future advisor.
Users of our Congruent CalculationsTM portal are able to specify product and advisor charges separately.