Lyncombe Consultants Limited · DRN-5847171

The complaint Mr L complains that Lyncombe Consultants Limited trading as R A Armitage & Associates (Lyncombe) provided unsuitable ongoing advice regarding his pension investments. What happened Mr L was a client of the financial adviser – R A Armitage & Associates. RA Armitage & Associates became an appointed representative of Lyncombe in early 2023, having previously been an appointed representative of a different principal firm. Lyncombe is therefore the principal that is responsible for the activities of RA Armitage & Associates from January 2023, which includes the provision of the ongoing advice beyond that point. This decision is therefore limited to the activities from January 2023 until Mr L cancelled his agreement with it in early 2025. For simplicity I will simply refer to Lyncombe as the respondent business in the remainder of this decision. Lyncombe met with Mr L in February 2023 and updated his circumstances in a fact find. It established that it was Mr L’s likely intention to retire in 9 years time at state pension age. It reviewed his attitude to risk using a questionnaire as the basis for discussion. It then sent Mr L the outcome and recommendation of its review on 26 March 2023. Lyncombe met with Mr L again in January 2024 for another annual review. Mr L was still working and his circumstances and objectives were broadly the same as the meeting in 2023. It wrote to Mr L on 29 January 2024 with its review. In December 2024 a final meeting occurred between Mr L and Lyncombe in which it was agreed to terminate the client agreement. Mr L complained to Lyncombe that the funds he had been invested in were too volatile given his closeness to retirement. He also considered that the fees on his pension platform were too high. Lyncombe didn’t uphold Mr L’s complaint. It considered that it had carried out the annual reviews and made suitable recommendations based on the circumstances that it established at that time. Mr L didn’t accept Lyncombe’s answer and referred his complaint to our service. It was looked into by an investigator who didn’t think it should be upheld. I summarise the reasons as follows: • The agreed attitude to risk was suitable in the context of the recommendation. • The recommended investment funds appeared to achieve the agreed risk profile. • The fees for the pension platform did not appear to be high enough to have warranted Lyncombe recommending a switch to a different platform. Mr L disagreed with our investigator’s view and referred his complaint for an ombudsman’s decision.

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What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. I understand that Mr L is invested in his complaint and that it follows on from another issue for which he has been compensated. Having reviewed what has led to this complaint, I understand that Mr L’s relationship with Lyncombe broke down and that he lost trust in the service it provided. I therefore understand that he has questioned other elements of its service. But my role is to impartially consider the service that is at the heart of this specific complaint, and determine whether Lyncombe has done anything wrong. For much the same reasons that our investigator has already given, I am satisfied that Lyncombe didn’t treat Mr L unfairly, so I am not upholding this complaint. In this complaint I am limited to considering the ongoing service that Lyncombe was providing Mr L. Which essentially means looking at the annual reviews it carried out as part of its ongoing adviser service. Our investigator set out a detailed summary of the review activity which I am satisfied is accurate and will not repeat here. In summary, the frequency with which Lyncombe met Mr L to review his circumstances and objectives was reasonable. I have considered whether the reviewed investment strategy remained suitable for Mr L’s circumstances. And, the same as our investigator, I think it was. It used a questionnaire as a starting point to determine Mr L’s baseline attitude to risk. It then had a discussion about the most suitable investment strategy. Which I think was fair. Agreeing an approach to investment risk is not an exact science. I think it is appropriate for an adviser to engage with its client to explain the trade-off of risk and reward and agree a suitable strategy. It should be guided by a consumer’s term to investment and capacity to withstand loss. And I think Lyncombe did that. Lyncombe understood that Mr L did not intend to access his pension until age 67. He was working and able to make contributions to his pension. And he had savings outside of his pension which increased the likelihood that he could leave the pension invested until age 67. It recommended that Mr L should continue to invest in line with a risk grading of 7 out of 10. Which would improve the likelihood of better returns. But would also increase the risk of volatility in the short to medium term. It was important that Mr L understood this. And, from the report that Lyncombe sent to Mr L, I think it was made very clear. The investment strategy had been in place prior to the time that Lyncombe was responsible. So I think that it is also fair to recognise that Lyncombe was reviewing Mr L’s circumstances to determine whether the pension and investment strategy that had been put in place remained suitable for him. I would not expect it to be making changes to the platform or funds without good reason, such as a change in circumstances or identification that a particular fund was no longer suitable. Given that Mr L’s agreed attitude to risk and his goal for retirement remained unchanged in the reviews, then I don’t think that Lyncombe need necessarily have made dramatic changes. It made a recommendation for a fund switch which, broadly, maintained the overall portfolio risk. So was appropriate and in response to Mr L becoming uncomfortable with one of the funds his pension was invested in. Other than that however the underlying solution remained suitable for his needs. I understand that Mr L also considers that the pension platform had high fees. Those fees were not applied by Lyncombe, but by the platform provider. I understand that the platform fee was 0.45%, with fund fees in the region of 0.88%. As our investigator explains, whether fees are too expensive is subjective. But I am not persuaded that these fees were such that Lyncombe ought to have been recommending an alternative platform. The platform was already in place prior to Lyncombe’s reviews and it still met Mr L’s objectives of enabling him

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to invest for his retirement. It wouldn’t be reasonable in a routine review to have revisited the choice of platform unless there had been a significant change, such as the platform increasing its fees which may trigger the search for a better cost alternative. My final decision For the above reasons, I am not upholding Mr L’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr L to accept or reject my decision before 27 April 2026. Gary Lane Ombudsman

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