Redress & remediation.
The firm undertakes loss-assessment and remediation calculations that give regulated firms a clear and defensible position on mis-sold or mis-handled pension matters — defined-benefit transfer redress under DISP App 4, and defined-contribution redress that covers the underlying assets within the wrap, including structured products and other esoteric instruments held inside DC arrangements. Single-case work and high-volume past-business reviews handled on the same calculation platform. Engagements are senior-led, audit-ready at scale.
Loss-assessment work for FCA-regulated firms in scope.
Loss calculations under DISP App 4 — the FCA’s prescribed methodology for pension-transfer redress — and equivalent FCA conduct provisions for related retail-financial redress. Performed by senior actuaries under TAS 100 (FRC) and APS (IFoA) standards, assured through the Congruent Quality Framework, with Congruent Actuarial Limited authorised and regulated by the FCA (FRN 831289). Senior partners lead each programme; Congruent carries the professional warranty.
The firm’s engagement is with the regulated firm in scope — the IFA, the pension-transfer firm, or the appointed skilled person — not with the consumer. The engagement is the firm supplying the actuarial calculation that the regulated firm-in-scope’s redress programme requires; the regulated firm in scope is responsible for redress to the consumer. Where redress matters escalate to FOS appeal, ombudsman determination, or Court proceedings, the appropriate Expert at Congruent acts under APS X3 (The Actuary as an Expert in Legal Proceedings) in those contexts; the institutional warranty applies to the broader programme.
Firm-instructed, skilled-person-instructed, and ombudsman-referred work.
Firm-instructed remediation
The regulated firm in scope of a redress matter commissions the firm directly to perform the loss-assessment calculations as part of its own remediation programme. The firm is engaged as the calculation specialist; the firm in scope retains overall responsibility for the programme and for engagement with the regulator.
Skilled-person-instructed
An appointed s166 skilled person commissions the firm to perform redress calculations within the broader review — either as benchmarking against the firm-in-scope’s own methodology or as a sample-reproducibility exercise. The deliverable is to the appointed skilled person; see also S166 engagement support.
Ombudsman-referred individual cases
Individual matters referred to the Financial Ombudsman Service where the firm prepares the calculation in support of the complainant or the firm in scope. Single-case work, prepared to the same methodology and audit-trail standards as volume engagements; the per-case CMC™ artefact supports independent verification of the figure.
Loss calculation following the FCA’s DISP App 4 methodology.
Loss assessment for defined-benefit pension transfer redress under DISP App 4, and defined-contribution redress covering the underlying assets within the pension wrap. Single-case work and high-volume past-business reviews handled on the same calculation platform. Senior-led, audit-ready, every output traceable.
DISP App 4 and the standards regime.
DISP App 4 is the FCA’s prescribed methodology for retail defined-benefit pension transfer redress. Calculations performed under TAS 100 and reviewed under APS X2; Bank of England data for inflation and gilt yields; FCA tables for the prescribed assumptions. DC redress engagements run under the same methodology architecture, scoped to the underlying assets and the FCA conduct provisions applicable to the case.
Pension redress, including the assets within the wrap.
Defined-benefit pension transfer redress under DISP App 4. Defined-contribution redress covering the underlying assets within the pension wrap — structured products, esoteric investments, and other complex instruments held inside SIPP and occupational DC arrangements. Single-case work and high-volume past-business reviews handled on the same platform.
Per-customer calculation receipts, audit-ready in aggregate.
Each customer's calculation produced as a discrete receipt with full disclosure of inputs, methodology, and the calculation chain. Aggregate documentation supports skilled-person review and regulator enquiry. Sample reproducibility built in.
Single point of contact throughout.
The senior pensions expert handling the engagement is responsible for methodology, sample treatment, regulator-facing correspondence and remediation board updates. No outsourcing of judgement at any stage.
Common questions about DB pension redress calculations.
Buyers come to the firm with several recurring questions about DB pension redress calculations. The methodology is consistent across engagement types — what changes is the scope: a single-case calculation, a defined-population past-business review, or the broader remediation work that follows a skilled-person review under FCA section 166.
What the firm calculates.
The firm calculates DB transfer redress — the most common case, where unsuitable advice led to a transfer out of a DB scheme — alongside DC redress where the unsuitable advice led to a DC arrangement that hasn’t performed as the DB scheme would have. Where significant redress liability is in prospect, the firm also projects the capital adequacy implications: the remediation cost set against the regulated firm’s own financial resources.
Past-business reviews.
Past-business reviews are large-scale engagements where an FCA-regulated firm assesses the suitability of its advice across a defined customer population — sometimes following a skilled-person review under section 166, sometimes pre-emptively as part of conduct remediation. The calculation methodology is the same as single-case redress; what differs is the volume, the data architecture, and the audit-traceability required at population level.
Independence and defensibility.
The firm is structurally independent of the regulated firms in scope — no advisory ties, no commission arrangements, no shared ownership. Independence carries methodological weight: the calculation is the calculation, and the buyer’s confidence in defending the result does not depend on the calculator’s distance from the work. Each calculation receipt is audit-traceable from inputs through assumptions to output, supporting both internal sign-off and external scrutiny by regulator, skilled person, or ombudsman.
Four buyer channels — pension redress reaches the firm through multiple instruction routes.
The FCA's pension-redress regime is engaged through several instruction paths: directly by the firm whose past advice or product is under review, through Skilled Persons under section 166, through the Financial Ombudsman, and through litigation. The buyer surface reflects that.
Workplace DC providers & advisor firms
Past-business review programmes, in-house complaints functions, advisor firms whose past DB-transfer advice is being reviewed via Skilled Person or supervisory engagement.
Insurers & reinsurers
Capital provisioning for pension-redress exposure carried on the balance sheet, scenario-based assessment of potential redress liability for board reporting and ICS submissions, and supporting calculations where the insurer is itself the regulated firm under review.
Law firms
Ombudsman appeal, court proceedings, litigation support. Cross-link from PODE work where a redress calculation is in scope. Expert-witness reports prepared to CPR Part 35.
Regulators & public bodies
Section 166 calculation reviews, thematic review preparation, supervisory engagement, technical narrative development, model and data integrity assessments.
The Redress Calculation Service runs on the Congruent Calculations™ platform — the firm’s audit-ready calculation engine. For specialist actuarial input within s166 engagements, see S166 engagement support. For methodology-defence work in regulatory contexts, see Regulatory engagement.
Standard quote.
The Redress Calculation Service is priced on a fixed-fee basis with a defined delivery window. Standard cases are quoted at the published fee; complex variants and volume programmes are scoped on instruction.
Actuarial Report and Redress CMC™ artefact, covering both the defined-benefit and defined-contribution elements of the calculation.
Complex cases are reviewed on a case-by-case basis. Volume work — past-business review and remediation programmes — is priced with discounts to the standard quote, structured by programme.
*Standard fee covers a single DB transfer into a DC pension plan: determination of the Primary Compensation Sum under DISP App 4, with the provisional determined redress illustrated in the Redress CMC™ artefact. Engagements outside this scope are quoted separately — the firm is happy to provide an indicative quote in advance.
For the firm’s standard Invitation Letter as a template for considering engagement: Request Invitation Letter →
Discuss a remediation.
Brief context, scope and timing — the firm responds within one working day with whether it can take the instruction and what it would need to scope it.