A Money Marketing survey of top Sipp providers - Feb 2015

1. Respondents:
City Trustees (Mattioli Woods)
Xafinity
Standard Life
James Hay
LV=
AJ Bell
Talbot & Muir
Hornbuckle
Suffolk Life
Dentons
Barnet Waddingham
Rowanmoor
Fidelity
Liberty Sipp
City Trustees (part of Mattioli Woods)
Number of Sipps – 2389 as at 30/11/2014
Number of Ssas – 296 as at 30/11/2014
Assets under administration - £942.5m
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria? No, City Trustees are
committed to provide advisers/clients access to a range of investments.
However, the maximum amount that we allow into a non-standard asset class is
50% of the value of the SIPP/SSAS and also require investors to be either a
sophisticated investor or a high net worth individual.
If so, have you made advisers aware of the changes? N/A
Have your refined your acceptance criteria for any assets you continue to
accept? The only amendment that we have implemented relates to our non-
standard investments requirements as per the comments under point 4.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter? No
Do you intend to do so within the next 6 months? Currently, there are no plans.
How are you treating property for capital adequacy calculations, as standard or
non-standard? Standard investment
Have you had any external assessment or accreditation of your service standards
in the last 3 years? We have achieved the maximum 5 star rating with
independent agency Defaqto for the last three consecutive years.
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
Primary asset classes:
Equity portfolio - 26%
Direct equity - 20%
Cash - 18%
Direct property - 14%

2. Xafinity
Number of Sipps 1,400
Number of SSASs 1,500
Assets under administration £1.5bn
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?
No, but we have even tighter controls now compared to 2 years ago. It is worth
noting that our controls were already much tighter than our competitors’ and we
do not have large numbers of non-standard investments on our books.
If so, have you made advisers aware of the changes?
Ongoing communication with advisers
Have your refined your acceptance criteria for any assets you continue to
accept?
Yes, as above, our controls are now tighter and under constant review
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
No, in fact our SIPP fees have not increased since September 2013
Do you intend to do so within the next 6 months?
No
How are you treating property for capital adequacy calculations, as standard or
non-standard?
Standard
Have you had any external assessment or accreditation of your service standards
in the last 3 years?
No
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
45% insured assets, unit trusts and OEICS and platform held investments
29% property
Standard Life
Number of Sipp
Not disclosed.
Number of Ssas
Not disclosed.
Assets under administration
Not disclosed.
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?

3. Standard Life conducts regular reviews of its control frameworks to identify
opportunities to strengthen processes, systems and risk management. We have
undertaken a review of our existing due diligence processes following the FCA’s
thematic review. We have not changed investment criteria but we have taken the
decision not to accept instructions for unregulated collective investment
schemes and similar investments.
If so, have you made advisers aware of the changes?
Advisers are aware of our position.
Have your refined your acceptance criteria for any assets you continue to accept?
No, other than to take the opportunity following the last thematic review to
undertake a review of existing control frameworks.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
No.
Do you intend to do so within the next 6 months?
No.
How are you treating property for capital adequacy calculations, as standard or
non-standard?
Standard Life is subject to separate insurance company rules and regulations and
not the FCA capital adequacy calculations for SIPP operators.
Have you had any external assessment or accreditation of your service standards
in the last 3 years?
No.
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
This information is not available.
James Hay
Number of Sipps – over 44,500
Number of SSASs – over 1,500
Assets under administration - £16bn
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria? We are undertaking a
review in terms of our investment criteria in light of these FCA requirements. We
have made the following changes to date:
Introduced a max % for non standard investments for direct clients.
Placed a requirement for NMPIs to only be accepted with financial advice.
Put in place a more robust governance structure for review and acceptance of
investments, particularly non standard investments via an Investment
Committee.
If so, have you made advisers aware of the changes? Yes.
Have your refined your acceptance criteria for any assets you continue to accept?
See above, however the Investment Committee reviews the acceptance criteria
regularly in line with regulatory developments and our own experience and risk
appetite, which may lead to further changes in the future.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter? No

4. Do you intend to do so within the next 6 months? We are reviewing all
investment types in light of the FCA developments which are likely to result in
some price increases.
How are you treating property for capital adequacy calculations, as standard or
non-standard? Standard, currently. But even with a change of approach we are
strongly capitalised enough to include commercial property in the calculations.
Have you had any external assessment or accreditation of your service standards
in the last 3 years?
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they? Based on MiPlan,
which was launched in Feb 2014, the most popular investment into SIPPs set up
in the last 12 months was into IM/DFM (over 39% of MiPlan SIPP AUA).
LV=
Number of Sipps 28,000 (12,000 SIPPs 16,000 insured plans / deferred SIPPs)
Number of Ssas 0
Assets under administration £3.2Bn
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria? No. We have always
maintained strict criteria, based around the old SIPP Permitted Investment list
(Joint Office Memorandum 101)
If so, have you made advisers aware of the changes? N/A
Have your refined your acceptance criteria for any assets you continue to accept?
See 4 above.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter? No
Do you intend to do so within the next 6 months? No
How are you treating property for capital adequacy calculations, as standard or
non-standard? We are still in the process of reviewing this
Have you had any external assessment or accreditation of your service standards
in the last 3 years? Nothing specific, but we have won a number of industry
awards over recent years based on our capabilities
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they? Cash 4%, Insured
Funds 56%, Unit Trusts / OEICs 26%, Investment Trusts 3%, Fixed Interest 2%,
Quoted equities 5%, UK commercial property 1%, other standard assets 3%.
AJ Bell
Please find Q&As below for your SIPP survey.
Number of Sipps
82,500 as at 30 September 2014
Number of Ssas
714 as at 30 September 2014

5. Assets under administration
Across the AJ Bell Group currently £23.7 billion
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?
Yes, we have adapted our investment criteria to more closely fit that of the FCA’s
standard investment list.
If so, have you made advisers aware of the changes?
Yes.
Have your refined your acceptance criteria for any assets you continue to accept?
No. We already had a stringent process for accepting new assets onto the AJ Bell
Investcentre platform. Our investment remit sits within the standard list of
assets for capital adequacy requirements.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
No.
Do you intend to do so within the next 6 months?
Nothing planned.
How are you treating property for capital adequacy calculations, as standard or
non-standard?
Standard asset.
Have you had any external assessment or accreditation of your service standards
in the last 3 years?
Although we haven’t received any service standard accreditation, we have over
the years won many awards voted for by Advisers, customers and industry
experts based on our business service and product offering.
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
Breakdown of SIPP assets is not something we generally disclose.
Talbot & Muir
Number of SIPPs
2186
Number of SSAS
703
Assets under administration
£1223 Million (£603M SSAS, £620M SIPP)
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?
Numerous thematic reviews brought to light greater focus on Sipp providers
when checking suitability of assets invested within their schemes, which means
we constantly review our allowable investment criteria, for instance we ceased
to accept UCIS in August 2013 because of concerns we held regarding the time it
takes to gain all the information to be able to judge if it was a SIPP suitable
investment.
If so, have you made advisers aware of the changes?
Advisers are made aware of the changes in stance by our consultants who work
closely with them on all aspects of new business. We request full details of

6. investment intentions before accepting business so there are no surprises for
either side during or after establishment of the SIPP or SSAS
Have your refined your acceptance criteria for any assets you continue to accept?
We have not refined acceptance criteria on any assets we continue to accept, we
like to try and take a clean approach, which states what we do and don’t accept
without the need for hidden criteria.
We are aware of providers that state that they offer assets and then have such
detailed criteria that they effectively make it impossible to find something that
would meet this detail.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
No we have not increased our fees in excess of inflationary levels, we do not
believe that there is a case for this because we are an efficient, profitable
company who charges according to the work we do. We do not operate any loss
leaders which could lead to an imbalance in the fees received if the type of
business we receive changes.
Do you intend to do so within the next 6 months?
We have no intention of increasing our headline fees in the next 6 months,
although changes to the options for clients such as the introduction of additional
retirement benefits (UFPLS) will mean additional reviews of add on charges.
This does not necessarily mean an increase and where some processes can be
streamlined with the new options then this saving will be taken into account.
How are you treating property for capital adequacy calculations, as standard or
non-standard?
We do not believe that it is as simple as is it or isn’t all commercial property a
standard or non-standard asset. We believe there is scope for some to fall into
either category and we will be reviewing our book accordingly and all new
properties we take on to ensure we are accounting for them correctly. The
likelihood is that the more complex cases will be deemed non-standard, such as
those which are owned with a third party. Simple, freehold and leasehold
properties held by a single member is as standard as possible for a SIPP to hold.
We hope that there will be a consensus amongst the industry which means we
are all working from a single a set of guidelines, by reviewing all our property,
how they are held and who is involved in each purchase will mean we will be
fully informed as and when we need to apply the set criteria.
Have you had any external assessment or accreditation of your service standards
in the last 3 years?
As a bespoke SIPP provider, our relationship with introducers and clients alike is
top of our agenda, and we pride ourselves on the service we offer to them.
Although, we have recently been highly commended by Money Observer for our
bespoke SIPP, however we have not commissioned any external research on our
service standards. We rely on advisers to tell us if we don’t meet their
expectations so we can rectify any issues as soon as we become aware. We work
closely with all our introducers who have a dedicated administrator who deals
with all their cases as well as a consultant. This cradle to grave approach means
that issues don’t get lost in ‘the system’ and everyone at Talbot and Muir is

7. accountable. We also offer direct access to our board for those that want to
discuss business processes.
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
Our total book of SIPP
Investment portfolio (3rd party, eg
DFM) 56.01%
Property 21.83%
Cash deposits 14.97%
Collectives 6.55%
Quoted equities 1.52%
Unquoted equities 0.74%
Borrowing -1.81%
Other (including outstanding rent etc) 0.03%
Loans 0.16%
However, the largest asset class purchased in the last year has been commercial
property through our bespoke SIPP and SSAS offerings, which is nearly 50% of
the new assets purchases within those products This is closely followed by DFM
or platform assets, our Simple Retirement Account is entirely DFM and cash,
with only minimal amounts of cash remaining in the cash account.
Hornbuckle
Number of SIPPs c12,500
Number of SSASs c600
Assets under administration c£4bn
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?
We have had no need to change our investment criteria as a result of the FCA
reviews. As a full service SIPP provider we support the majority of HMRC
permissible investments. Where we don’t support a particular investment we
will have observed poor customer outcomes and made a decision not to permit
based on quality, liquidity. We will also have specific counterparty restrictions in
place.
Our web-based Investment Selector tool is publicly available on our website. It
was launched in Sept 2014 and is widely used by our adviser network and
internal teams. In addition to the Investment Selector we publish our permitted
investment schedule which also sets out our liquidity requirements. All
investment due diligence, policies and processes are actively monitored and
managed by a group of technical pension and investment specialists.

8. Have your refined your acceptance criteria for any assets you continue to accept?
Where a SIPP plan or SSAS scheme holds any non-standard investments we will
require that 10% of the fund value should be held in standard investments
(including cash deposits).
There are also limits on how much of the fund value we will permit to be
invested in a select number of asset classes. They are as follows:
Unlisted securities 50%
Authorised employer loans (SSAS loanbacks) 50%
Other non-standard investments 75%
Have you increased your fees in excess of inflationary levels since the FCA
thematic review letter?
We made the last changes to our pricing across all pension wrappers in February
2014. The pricing revisions included a range of structural changes to our fee
structure to match it more directly to the complexity of our client activities. The
changes made reflect the market costs for delivering specialist pension products
and services, with appropriate risk controls. As a result, some fees decreased
and some increased.
Do you intend to do so within the next 6 months?
In the coming months we will bring to market a series of new services and
products driven by our investment in our new technology platform and
offering. This will allow us to further differentiate fee levels to activity risk and
complexity into a genuine “pay-as-you-go” structure for clients. The investment
we have made and the technology we are implementing will also ensure we can
continue to offer a range of specialist retirement products and services.
How are you treating property for capital adequacy calculations, as standard or
non-standard?
Ahead of the new regulatory framework coming into place, we will continue to
treat property as a non-standard. Our innovation efforts are focused on
designing different streamlined processes for different property types
and transactions. This will allow us to differentiate more clearly between any
standard and non-standard classification conditions in 2016.
Have you had any external assessment or accreditation of your service standards
in the last 3 years?

9. We are investing heavily in a complete digitisation and automation of our back
and middle office activities, and we were pleased that Nutmeg chose Hornbuckle
as their strategic partner on the basis of these new capabilities. In addition to
launching this new service platform to our existing clients in 2015, we are
in active negotiation with a number of further product and distribution partners,
each recognising the unique service capabilities our new technology offers.
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
Cash 70%
Portfolio services 19%
Specialist 3%
Property 7%
UCIS 1%
Data relates to new investments for all new SIPPs established in 2014 and
reflects numbers today so clear bias towards cash for new plans and schemes
established in 2014
Key points:
This does not include investments made in existing plans/schemes
It reflects the value of investments – not volume (i.e. doesn’t reflect number of
properties).
Suffolk Life
1. Number of Sipps
23,712
2. Number of Ssas
0
3. Assets under administration
£7.6 billion
4. As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?

10. Yes, as a result of the thematic review and also of EMIR (European Market
Infrastructure Regulation). The forthcoming capital requirements have not
impacted the investments we allow
5. If so, have you made advisers aware of the changes?
Yes, and we’re writing to all advisers and investors shortly as part of a wider
exercise to introduce new pension access options as originally outlined in the
2014 March Budget
6. Have your refined your acceptance criteria for any assets you continue to
accept?
Yes
7. Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
No
8. Do you intend to do so within the next 6 months?
We keep our fees under regular review and continue to review them in light of
heightened regulatory expectations and the introduction of the pension access
options
9. How are you treating property for capital adequacy calculations, as
standard or non-standard?
Directly held UK commercial property cannot be proven to be realised or
transferred under normal conditions within 30 days, therefore the regulator’s
expectation is that it should be treated as a non-standard asset
10. Have you had any external assessment or accreditation of your service
standards in the last 3 years?
We have undertaken Investor in Customers assessments and regularly win
industry awards for our service and proposition
11. Can you breakdown into asset classes as a percentage, the primary asset
class of new SIPP established in the last 12 months? What are they?
TBA
Liberty Sipp
Number of Sipps 4,000
Number of Ssas 0

11. Assets under administration £380,000,000
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria? Yes. Since November
2013 we have only accepted standard assets from clients in line with the FCA’s
definition
If so, have you made advisers aware of the changes? Yes
Have your refined your acceptance criteria for any assets you continue to accept?
N/A
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter? No
Do you intend to do so within the next 6 months? No but we are reviewing
drawdown fees for post April 2015
How are you treating property for capital adequacy calculations, as standard or
non-standard? We, like most of the SIPP industry, hope for clarification on this
point from the FCA. We are currently counting it as standard.
Have you had any external assessment or accreditation of your service standards
in the last 3 years? Defaqto 5 stars since 2012
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
FSA Regulated CIS 23.96%
Bank Account 2.19%
Quoted Shares 62.54%
Property 3.46%
Rowanmoor
1. Number of Sipps
4219 and 746 Family Sipps as at 31 December 2014
2. Number of Ssas
Figures will be available in Money Management’s February SSAS survey
http://www.ftadviser.com/r/FT%20Publications/FTA/Money%20Management
/Assets/Pdf/MON_0215_p055Tab1.pdf
3. Assets under administration
£3.7bn (as at 1/10/14)
4. As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?
Our investment criteria are under constant review and all investments undergo
rigorous due diligence. Due diligence is a crucial part of our administration and
operating processes.
5. If so, have you made advisers aware of the changes?
See Q4. All investment options are readily available at
http://www.rowanmoor.co.uk/sipp/investments-options/
6. Have your refined your acceptance criteria for any assets you continue to
accept?
See Q4. Investments are continually monitored. We aim to give the most
comprehensive range of investment choice available under current legislation,
subject to strict criteria.

12. 7. Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
No
8. Do you intend to do so within the next 6 months?
Our fees are under review but we don’t anticipate any significant material
changes and not necessarily as a result of the thematic review.
9. How are you treating property for capital adequacy calculations, as standard
or non-standard?
We are still awaiting clarification from the FCA regarding the 30 day transfer
requirement.
10. Have you had any external assessment or accreditation of your service
standards in the last 3 years?
No, we do not; we are not convinced of the value of external service
accreditations as our own service standards are strictly monitored each
month. Our administration services are monitored against demanding
processing timescales. http://www.rowanmoor.co.uk/service-charter/service-
standards/
11. Can you breakdown into asset classes as a percentage, the primary asset
class of new SIPP established in the last 12 months? What are they?
We are unable to provide a response to this within the timescale we were asked
to respond.
Barnett Waddingham
Number of Sipps – Approx 3,000
Number of Ssas – Approx 2,400
Assets under administration – SIPP c.£1.2bn | SSAS c.£4.1bn
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria? – No. However, we
have launched a new SIPP, the Barnett Waddingham Flexible SIPP, and closed
the Barnett Waddingham SIPP to new business. The Flexible SIPP does not allow
certain investments which, in practice were either rare or unused in the Barnett
Waddingham SIPP.
If so, have you made advisers aware of the changes? – N/A
Have your refined your acceptance criteria for any assets you continue to accept?
– We keep our due diligence process under review to try to keep up with
developments in investments and scams to ensure it remains thorough and
effective.
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter? – No
Do you intend to do so within the next 6 months? – No
How are you treating property for capital adequacy calculations, as standard or
non-standard? – Until the FCA provide further clarification on the requirements,
we cannot give a definitive answer. If we decide that we need to classify it as
non-standard, it will significantly increase our capital adequacy requirement but

13. we will nonetheless be able to meet this from the existing resources of our
parent, Barnett Waddingham LLP.
Have you had any external assessment or accreditation of your service standards
in the last 3 years? – Yes. Our SIPP and SSAS businesses jointly submitted to an
assessment conducted by independent experts Investor in Customers in April /
May 2014. As a result of this, we obtained a two star (out of three) accreditation,
which is deemed as ‘Outstanding’.
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they? – Most are direct UK
commercial property or investments via DFMs - Flexible SIPP is DFM portfolios
at 55.01%
Fidelity – launched Sep 2013, too soon to comment
Dentons
As a result of the FCA’s thematic review and the new capital adequacy
requirements, have you changed your investment criteria?
No, we are still able to accept all the asset classes that we have always offered
If so, have you made advisers aware of the changes?
No changes made but see below
Have your refined your acceptance criteria for any assets you continue to accept?
We have refined some acceptance criteria for example in respect of loans to
unconnected parties: What we have tried to do provide intermediaries with
proformas of the information we would need to assess the acceptance of a given
investment: As an example the attached form relates to unconnected loans and
sets out the percentage of a fund we would permit to be loaned depending on
whether the loan is secured or unsecured: We also set out the need to see
company accounts etc so if accounts are not available, it won’t meet our criteria:
Have you increased you fees in excess of inflationary levels since the FCA
thematic review letter?
We had not increased our standard annual fees for three years (which we
reserve the right to do) so this year the increase was marginally in excess of the
last years inflation but still lower than the cumulative inflation since it was last
previously set. We have introduced only one new fee relating to the need to
include certain assets on our annual return to HMRC of £50per scheme that
includes certain reportable (but not all) non standard assets
Do you intend to do so within the next 6 months?
We envisage no fee increases until they are next due for renewal on 1st January
2016

14. How are you treating property for capital adequacy calculations, as standard or
non-standard?
If the property is held freehold or leasehold without mortgage or where the
mortgage is covered by other liquid assets of the SIPP, we intend to treat the
property as a Standard Asset. If a mortgage exceeds scheme liquid assets or if the
property is held jointly with an external party we are intending to treat the
property as non Standard. We are hoping that we will get some form of industry
consensus so that all operators are taking a common approach. We have already
undergone a data cleansing operation so we have accurate management
information on our properties so whatever the criteria actually is used we
should be able to accurately identify which of our properties fall into each
category.
Have you had any external assessment or accreditation of your service standards
in the last 3 years?
Yes, we were awarded 5 star service providers by another publication through
voting by IFA’s but more appropriately we periodically commission Investors In
Customers to survey our clients and who provide feedback. This is a hugely
valuable exercise for any firm that is customer focussed as it reports on not only
what you are doing well but on what your customers think you can do better. We
originally undertook the process in 2009 and learned from it which meant that
when we subsequently recommisioned IIC in 2014 we received their highest 3
star “Exceptional Award”
See further details of service awards on the attached due diligence document
that also sets out assets we won’t accept:
Can you breakdown into asset classes as a percentage, the primary asset class of
new SIPP established in the last 12 months? What are they?
Yes, our database can provide a wealth of creative management information
reports: The list below sets out the primary asset stated as being the reason for
creation of the new SIPPs established:
Directly held commercial property 48%
Equity/regulated collective portfolios 39%
Other collectives 3%
Cash 6%
Other non standard assets 4%
The latter category consists of unquoted UK equity, unconnected loans and
intellectual property
We firmly believe in providing as much information as we can to enable the
intermediary to make an informed choice about the proposition we are offering:
The due diligence document attached is updated regularly to reflect any changes
in the proposition as well as new numbers of SIPPs/assets etc. I’d be interested
to know how open your responses are from other SIPP providers to the degree
that if there is anything else IFA’s would like to know, we’re happy to try and put
it out there.