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Warn members about high-risk transfers


Still in draft

The information on this page is still draft. It will be finalised during the next few weeks.

You should clearly communicate your concerns to scheme members who request a transfer from the pension where you believe there is a high risk of a scam.

If you have taken all appropriate due diligence measures and believe there is a risk that the transfer is a scam, you should contact the member in writing and by phone to share your concerns.


We are not able to waive a trustee or scheme manager’s legal duty to carry out a transfer within the statutory deadline. You are required by law to make a transfer when requested by a member if they have a statutory right to transfer (and they have taken regulated advice if the transfer is over £30,000).

Write to the member

You should ask for written consent from the member for the transfer by sending them a discharge form. This will show you have clearly communicated your concerns and they understand the risk. There is no obligation on the member to supply written consent.

You can use the discharge letter templates in the appendices of the Pension Scams Industry Group Code of Good Practice.

Call the member

You should call the scheme member to share your concerns.

Scammers may tell members to disregard any communications from their schemes as ‘scare tactics’. But speaking to someone over the phone can be the last chance to protect a member. Alerting members to the risks of a scam is not advice.

Read Financial Conduct Authority guidance on support for members looking to access their pension savings.

Keep records

You should keep a record of the communication you have had with the scheme member.

This ensures that you can show you have done everything possible to warn the member of the risks. This will be essential if they subsequently make a complaint to the Pensions Ombudsman.