Zurich Assurance Ltd · DRN-6174912

The complaint Mr J has complained about the actions of Zurich Assurance Ltd when he transferred his personal pension to a Small Self-Administered Scheme (“SSAS”) in 2025. He says Zurich caused the process to become unnecessarily protracted, causing him financial losses and considerable distress and inconvenience. What happened Mr J held a personal pension with Zurich, as did his wife (Mrs J). In 2025, Mr and Mrs J decided to transfer their pensions (including pensions held with other providers) to their SSAS. Mr J requested transfer papers from Zurich on 14 January. The transfer didn’t complete until 14 April. He says the transfer would have completed far sooner but for Zurich’s mistakes, “regulatory foot-dragging” and unnecessary paperwork. He wants Zurich to compensate him for the losses he says were caused by the delays. Mrs J has made a similar complaint which is being looked at separately. Zurich didn’t think it had done anything wrong. Our investigator agreed. Mr J asked for an ombudsman to decide on the matter. 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. Before moving on to my findings, it’s worth noting that I will focus my attention on what I consider to be the central issues of the complaint rather than address every point Mr J has made. No discourtesy is intended by this – it reflects our remit to resolve disputes quickly and with minimum formality. For the avoidance of doubt, I have considered everything he has said, including his references to what he considers to be relevant legal precedent, rules and good industry practice. Mr J’s complaint is wide-ranging but can be distilled into three main concerns: Zurich caused unnecessary delays to his transfer, his transfer value fell as a result and the extent of that fall was inexplicably severe. To address the first point, a recap of the transfer timetable is helpful. All dates are in 2025: • 14 January: Mr J emails Zurich requesting a transfer-out pack to complete a transfer to a SSAS. • 16 January: Zurich responds to Mr J’s request. It sends him its requirements, which included a claim form to be completed, the HMRC approval letter for the receiving scheme and (for occupational schemes) information and evidence relating to the receiving scheme and sponsoring employer and Mr J’s connection to them (such as payslips and bank statements). A similar letter was sent to Mrs J on the same day in relation to her pension.

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• 13 February: Transfer paperwork returned to Zurich. • 17 February: Zurich writes to Mr J to confirm receipt of his transfer paperwork and to request the information that it had previously asked for. It refers to the fact that a SSAS is an occupational scheme and that Mr J should therefore return the documents required for an “occupational transfer” as listed in its claim form. • 19 February: Zurich requests further information from Mrs J, including information and evidence relating to the receiving scheme and sponsoring employer – in other words, a repeat of its 16 January request. • 3 March: Mrs J emails Zurich requesting an update on her transfer. • 4 March: Zurich resends its 19 February email to Mrs J. • 7 March: Mrs J sends in transfer paperwork for both her and Mr J; Zurich says this is the point at which it was able to review their transfer requests in their entirety. • 18 March: Zurich writes to Mr J to warn him about pension scams and to ask him to attend a MoneyHelper safeguarding appointment. A similar letter was sent to Mrs J on the same day. • 28 March: Mrs J’s attendance at a MoneyHelper appointment is confirmed. • 8 April: Mr J’s attendance at a MoneyHelper appointment is confirmed. • 14 April: Transfer completes for both Mr and Mrs J and funds paid to their SSAS. Mr J appears to have accepted (or has come to accept) the parameters within which Zurich was operating, specifically The Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 and the industry guidance that sits alongside it. As such, he hasn’t argued that Zurich was incorrect in conducting due diligence into his transfer request, or in referring him to MoneyHelper which extended the time the transfer took. His point is that Zurich could have taken the necessary steps far quicker. In his view, there were preventable delays. Partly this is due to the ‘headline’ length of time it took to complete the transfer, which was at least two months from when he returned his transfer paperwork (and three months from when transfer papers were initially requested). And partly it’s due to delays Zurich has admitted to in relation to Mrs J’s transfer. He also points to the time it took to refer him to MoneyHelper. Zurich responded promptly to Mr J’s request for transfer paperwork in January 2025. When this was returned, Zurich again responded promptly to tell him he hadn’t provided all that it had originally asked for. That problem appears to have stemmed from Mr J not providing the information required for an occupational transfer. Zurich explained in its 17 February mailing that because the SSAS was an occupational scheme, Mr J had to return the documents required for an occupational transfer. I’m therefore satisfied Zurich didn’t cause any unnecessary delays in this period. It acted promptly and explained what it needed and why. Likewise, I’m satisfied the referral to MoneyHelper wasn’t unduly delayed. It’s unclear precisely when Mr J thinks Zurich should have made that referral – I’ve seen at least one reference to “immediately”. Zurich had all the information it needed from Mr J on 7 March, so this is a more reasonable starting point bearing in mind a referral to MoneyHelper isn’t always necessary and would be contingent on the specific circumstances of a transfer request. Mr J appears to have accepted that point following our investigator’s assessment,

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but his underlying argument stands – he doesn’t think it should have taken from 7 March until 18 March for Zurich to have referred him to MoneyHelper. But I don’t think it was unreasonable for Zurich to have taken that amount of time bearing in mind it was completing a number of steps as part of its due diligence process, including (but not limited to) whether there was an employment link between Mr J and the SSAS’s sponsoring employer. Mr J’s other main complaint point is that the amount he ended up transferring was approximately 16% lower than a valuation he had been given earlier in the process. At face value, this is a relatively straightforward matter. Mr J’s pension remained invested until Zurich had everything it needed to allow the transfer. It fell in value in the run-up to that point just as it would have done over the same period had there been no transfer request. Of course, the fact that his pension remained invested in this period is the real question here. But this is common practice. It’s a neutral, ‘rules based’, approach – that is, every transfer is dealt with in the same way by the transferring firm without consideration of whether markets will fall or rise. Zurich also told Mr J what its approach would be (more on which shortly). So I’m satisfied there is no wrongdoing here. Mr J says he doesn’t trust Zurich’s numbers, not least because he says he hasn’t been provided with comprehensive enough information (despite requests) to allow him to verify what it has said. He says he wasn’t warned that his fund value was likely to fluctuate ahead of his transfer and that it could fall. And, of course, his arguments about Zurich’s delays play a part here too because if it hadn’t been for those delays, he says he may have avoided some, or all, of the drop in his transfer value. Zurich provided Mr and Mrs J with a 12-month unit, and unit price, history for their pensions on 14 May 2025. This included surrender dates and values. Mr and Mrs J have used that as part of their challenge to Zurich and as part of their submissions to us. So I’m satisfied Zurich hasn’t acted improperly when dealing with their information requests. For completeness, I’m satisfied Mr J’s transfer value tracked the value of his underlying investments during the period in question. I note Mr J’s concerns stem partly from the more significant fall in his transfer value relative to Mrs J’s – his point being that the value of the two pensions should, broadly, have mirrored one another. But the dates of the earlier valuations he is using for comparison were different for him and Mrs J which is reason enough for the different trajectories of the two pensions. More importantly, the days on which Zurich calculated transfer values for Mr and Mrs J’s pensions (which it did on the next working day after it had received everything it needed) were also different – 9 April and 31 March respectively. The beginning of April 2025 saw significant declines in financial markets (prompted by the announcement of tariffs by the US on 2 April). Mr J’s pension was therefore exposed to those declines to an extent that didn’t apply to Mrs J’s pension. With all this in mind, I’m satisfied the more extreme drop in Mr J’s transfer value relative to Mrs J’s transfer value isn’t an indication of wrongdoing by Zurich. It’s a reflection of the longer time it took Mr J to meet MoneyHelper and the sharp falls in financial markets in that period. In relation to whether Mr J was given sufficient information about what would happen to his funds during the transfer process, I draw his attention to the pension paperwork he signed on 27 January: It said: “I understand that the final transfer value will be calculated on the next valuation date following receipt of all documentation and information required…I understand that my transfer request will be declined if it does not meet the transfer conditions set out in DWP and HMRC legislation…I understand that if the transfer is to an occupational pension scheme then I must provide the information requested (unless the receiving scheme is an

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authorised master trust scheme, authorised collective money purchase scheme or a public service pension scheme).” Zurich’s letter to Mr J dated 18 March 2025 also said the following: “In the meantime, I would confirm your funds will remain invested in the funds you have chosen until we have received all of the information necessary to enable your transfer to proceed. This means that the value of your fund will continue to be subject to fluctuations, i.e. the value can go up or down, in line with the unit price movements of the respective funds in which you have chosen to invest.” It means Mr J was told what would happen to his funds during the transfer process, what the potential implications of that would be, and why the transfer was dependent on certain information being provided. It wasn’t Zurich’s role to be any more proactive than that – for instance, advise Mr J about what his best course of action would have been. Finally, Mr J’s point about being unnecessarily exposed to unfavourable fund performance because of Zurich’s delays falls away because I’m satisfied Zurich wasn’t responsible for any unnecessary delays for the reasons given above. It follows that I don’t uphold Mr J’s complaint. There is nothing further for Zurich to do. My final decision For the reasons explained above, I don’t uphold Mr J’s complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr J to accept or reject my decision before 17 April 2026. Christian Wood Ombudsman

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