The Standard Life 2019 final notice – another zeitgeist moment

The former assurance company has been extraordinarily unlucky to have caught the regulator’s eye both in 2010 and 2019 while acting similarly to the rest of the industry. The recent enforcement action involved a strategic problem – Standard Life’s systems and controls failed to protect customers from precisely the outcome that the firm was seeking from its staff: the retention and growth of pension business through the sale of its annuities, regardless of whether this was in clients’ best interests. Adam Samuel analyses lessons from the case.

Adam SamuelBA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted atadamsamuel@aol.com.For links to where you can buy the second edition of ‘Consumer Financial Services Complaints and Compensation’, see www.adamsamuel.com/book.

Occasionally, a regulatory final notice captures the very essence of the period to which it relates. It has been Standard Life’s dubious privilege to be the firm in two such cases. The first, in 2010, concerned a promotion for a pension cash fund that contained a variety of mortgage-backed securities and other ‘animals’. It reflected back on the misunderstanding of the nature of cash-like instruments that lay at the heart of the 2007-8 United Kingdom banking crisis. The 2010 case’s emphasis on financial promotions as a way of dealing with what was actually a product governance issue, similarly encapsulated the uncertainty on how to address underlying issues about asset quality which cost the British taxpayer so much when they affected institutions like Royal Bank of Scotland.