Zurich Assurance Ltd · DRN-6184621

The complaint Mrs J has complained about the actions of Zurich Assurance Ltd when she transferred her personal pension to a Small Self-Administered Scheme (“SSAS”) in 2025. She says Zurich caused the process to become unnecessarily protracted, causing her financial losses and considerable distress and inconvenience. What happened Mrs J held a personal pension with Zurich, as did her husband (Mr J). In 2025, Mr and Mrs J decided to transfer their pensions (including pensions held with other providers) to a SSAS. Transfer papers were requested on 14 January. The transfer didn’t complete until 14 April. Mrs J says the transfer would have completed far sooner but for Zurich’s mistakes, “regulatory foot-dragging” and unnecessary paperwork. She wants Zurich to compensate her for the losses she says it caused. Mr J has made a similar complaint which has been looked at separately. Zurich accepted it caused a small delay towards the end of the transfer process, for which it offered compensation. But it didn’t think it had otherwise unnecessarily delayed the transfer. Our investigator looked into Mrs J’s complaint. She thought Zurich had done enough to settle the complaint. Mrs 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 two central issues of Mrs J’s complaint rather than address every point she 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 Mrs J has said, including her references to what she considers to be relevant legal precedent, rules and good industry practice 1. The extent of Zurich’s role in any delays A recap of the transfer timetable is helpful here. All dates are in 2025: • 16 January: Zurich responds to Mrs J’s request for transfer paperwork. It sends her 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 Mrs J’s connection to them (such as payslips and bank statements). A similar letter was sent to Mr J on the same day in relation to his Zurich pension. • 13 February: Mrs J returns transfer paperwork to Zurich by email. Zurich confirms receipt.

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• 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 emails Mrs J for further information, 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 Mrs J to warn her about pension scams and to ask her to attend a MoneyHelper safeguarding appointment. A similar letter is sent to Mr 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 the SSAS. Mrs 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, she hasn’t argued that Zurich was incorrect in conducting due diligence into her transfer request, or in referring her to MoneyHelper which extended the time the transfer took. Her point is that Zurich could have taken the necessary steps far quicker. In her view, there were preventable delays. Specifically, Mrs J points to Zurich sending its 19 February request for further information to an incorrect email address, the time it took to refer her to MoneyHelper and Zurich’s admission that confirmation of her attendance at her MoneyHelper appointment was forwarded to the wrong mailbox. On the first point, it’s not clear the 19 February email was sent to the incorrect email address. The version I’ve seen has Mrs J’s correct email address. And I note Zurich apologised for Mrs J not receiving it – but it went on to say that may have been because it went into her spam folder. However, my decision doesn’t turn on this because Zurich also wrote to Mr J on 17 February to say a SSAS was an occupational scheme and that he should therefore return the information requested for occupational transfers. I haven’t seen a similar letter to Mrs J, possibly because Zurich emailed her with its outstanding requirements on 19 February instead. But between Mr and Mrs J, I’m satisfied they would have known shortly after they had initially returned their transfer paperwork that they had further information and documents to send in. Furthermore, both the letter to Mr J and the email to Mrs J repeat what Zurich had originally asked for on 16 January. It would seem Mr and Mrs J hadn’t returned everything Zurich needed because they had overlooked the requirements for transfers to occupational schemes. But whatever the reason, it wouldn’t be fair and reasonable to hold Zurich responsible for any delays here because it was always in Mrs J’s gift to have progressed things more quickly. Likewise, I’m satisfied the referral to MoneyHelper wasn’t unduly delayed. It’s unclear

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precisely when Mrs 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 Mrs 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. Mrs J appears to have accepted that point following our investigator’s assessment, but her underlying argument stands – she doesn’t think it should have taken from 7 March until 18 March for Zurich to have referred her to MoneyHelper. But I don’t think it was unreasonable for it to have taken that long bearing in mind Zurich 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 Mrs J and the SSAS’s sponsoring employer – an issue that wasn’t clear-cut. Finally on this note, Mrs J has referred to the delay resulting from Zurich misdirecting her confirmation of attendance at a MoneyHelper appointment to the wrong mailbox. Zurich says this meant funds were paid on 14 April instead of 11 April, a three-day delay (although this straddled a weekend). I’m satisfied that delay had no bearing on Mrs J’s ability to use her SSAS to invest in a commercial property scheme as intended, not least because Mr J’s funds had yet to be transferred by that point and, as Mrs J will be aware, there were no undue delays with that transfer. Nevertheless, there may have been other financial losses resulting from the three-day delay. Zurich has already offered to compensate Mrs J for those losses should there have been any. I can see it contacted the SSAS shortly after the transfer to start that process and that it subsequently confirmed to us that the process was “underway”. Mrs J also requested Zurich complete that process (in addition to compensating her for the other delays she identified). So, all things considered, I’m satisfied that Zurich has acted in a fair and reasonable manner on this matter and that there is no longer any dispute between the parties about this specific aspect of the complaint. It’s not clear what the outcome of this process was. But Zurich should now complete it if it hasn’t already done so. 2. Differences in the amount transferred and earlier fund valuations Mrs J has complained that the amount she ended up transferring was approximately 8.6% lower than a valuation she had been given earlier in the process. At face value, this is a relatively straightforward matter. Mrs 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 her 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 are likely to fall or rise. Zurich also told Mrs J what its approach would be (more on which shortly). So I’m satisfied there is no wrongdoing here. Mrs J says she doesn’t trust Zurich’s numbers, not least because she says she hasn’t been provided with comprehensive enough information (despite requests) to allow her to verify what it has said. She says she wasn’t warned that her fund value was likely to fluctuate ahead of her transfer and that it could fall. And, of course, her arguments about Zurich’s delays play a part here too because if it hadn’t been for those delays, she says she may have avoided some, or all, of the drop in her 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

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satisfied Mrs J’s transfer value tracked the value of her underlying investments during the period in question. I note Mrs J’s concerns stem partly from the more significant fall in Mr J’s transfer value relative to her own – her point being that the value of the two pensions should, broadly, have tracked one another. But the dates of the earlier valuations she is using for at least one of her comparisons were different for her and Mr 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, the value of which was ‘locked in’ on 31 March. 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. The fact that the transfer values for both pensions were paid on the same date indicates Mrs J’s pension payment took longer to process once transfer values had been calculated, even after one adjusts for the three-day delay mentioned earlier. But I don’t consider the time it took to pay Mrs J’s transfer proceeds to be unreasonable and, in any event, her pension ended up being out of the market at the beginning of April which was advantageous for the reasons given above. In relation to whether Mrs J was given sufficient information about what would happen to her funds during the transfer process, I draw her attention to the pension paperwork she 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 authorised master trust scheme, authorised collective money purchase scheme or a public service pension scheme).” Zurich’s letter to Mrs J dated 18 March 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 Mrs J was told what would happen to her 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, to advise Mrs J about what her best course of action would have been whilst the transfer process was ongoing. Finally, Mrs 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, beyond the three-day delay which has

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already been addressed. It follows that I uphold this complaint but only in so far as Zurich Assurance Ltd must complete the three-day loss calculation referred to earlier if it hasn’t already done so. My final decision I uphold Mrs J’s complaint to the extent outlined above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs J to accept or reject my decision before 24 April 2026. Christian Wood Ombudsman

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