How is PIMS changing on 1 July 2019?
With the final phase of the Isle of Man Conduct of Business Code (COB) coming into effect on 1 July, we look ahead to the changes we are making to PIMS, our personalised portfolio plan for lump sum investors, to be in line with the new regulations.
Enhancements to PIMS
We have 2 variants of PIMS – a life assurance version, and a capital redemption version. There’s no more Flexible or Focussed versions either, so PIMS is now fully open architecture.
There’s a new charging structure - we are removing the Percentage Administration Charge (AMC) structure and the £500 Flat Administration Charge. We have also introduced a Financial Adviser Fee of up to 1.5%.
We’ve also lowered the currency equivalent ratios we apply for all currencies (except Euro and Australian Dollars) and now use the following formulas: GBP1 / EUR1.2 / CHF1.3 / USD1.4 / AUD1.8 / HKD10 / JPY155.
This means that the minimum premium for a PIMS reduces for USD, CHF, HKD and JPY plans – for example to USD70,000 now, where previously it was USD80,000.
It also effectively reduces fee charges for USD, CHF, HKD and JPY plans compared to the current version of PIMS.
Personalised Key Information Document (KID)
One of the key pillars of the COB code is the introduction of a personalised KID. The KID describes the main features of a PIMS plan, who the product is aimed at and highlights all the fees and charges. The amount of commission you receive will also be shown in percentage terms.
COB rules state the KID document must be signed by the plan owner and submitted as part of the application process. To make life as easy as possible, we have designed the KID to be produced as part of the Illustration process (an illustration is now required for PIMS applications) So once the KID is printed out, the plan owner will need to sign it, and you’ll send it to us as with the completed application form and signed illustration.
If you make any changes to the terms of the plan after the application and KID have been sent to us, we would require you to produce a new, signed KID and re-submit it.
Brand new literature
We have changed all PIMS literature. This is not only the look and feel of the materials as they move into the new RL360 brand style, but also the range of literature that will be available. There will be separate Capital Redemption and Life Assurance versions of each of the following pre-sales items:
- Product Guide
- Application Form for individuals
- Terms and Conditions
- Application Form for Corporate Trustee (only available as a PDF)
- Application Form for Company and Individual Trustee (only available as a PDF)
There is no longer a requirement for a Key Features document, as these details are covered off in the KID which will be automatically produced as part of the illustration.
In addition there will be sales aids and servicing forms. Details for these will follow.
You can request printed copies from your local RL360 sales office. PDFs will be available on our dedicated adviser website www.rl360adviser.com from 1 July.
All new PIMS illustration system and an improved new charging structure
The new illustration system incorporates all the COB requirements, and the new charging structure. We will send you details of how to access the new illustration system before 1 July.
Acceptance of current version PIMS applications
New business applications for PIMS written on the current, pre-1 July 2019 basis, will be issued up until 31 December 2019 so long as the application was:
- signed before 1 July 2019. No applications dated after 30 June will be accepted without an updated KID that includes commission disclosure
- submitted and received by RL360 before 1 August 2019
Topping up a PIMS plan
Top ups on post 1 July plans (that is, COB compliant plans) are available from day one on the new illustration system.
Top-ups to existing PIMS plans written before 1 July 2019 will also be available on the new PIMS illustration system and will use the new charging basis. Advisers will need to enter the premiums paid to date and the date the policy commenced and the system calculates the relevant FX rates basis to use. The system generates a KID for the top-up which includes commission disclosed in percentage terms.
The Isle of Man COB code will set the regulatory benchmark for other jurisdictions to follow. We believe the Code will bring about better outcomes and even greater protection for your clients. It’s also an opportunity for you to write even better and more persistent business.
We have also just published a COB explainer video. You can view the video at www.rl360adviser.com/change
If you have any further queries, please contact websupport@rl360.com