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The Investing and Saving Alliance (TISA) Calls for Changes to Privacy and Electronic Communications Regulations (PECR), to avoid ‘Communication Impasse’ for Roll Out of Targeted Support

February 13, 2025

The Investing and Saving Alliance (TISA) Calls for Changes to Privacy and Electronic Communications Regulations (PECR), to avoid ‘Communication Impasse’ for Roll Out of Targeted Support.

In a wide-ranging submission to the Financial Conduct Authority’s (FCA) consultation on ‘Proposed Targeted Support Reforms for Pensions (CP24/27)’, TISA has made several recommendations to help guide the potential implementation of targeted support, an initiative which could help millions get support for decisions around their pensions and wider financial wellbeing. Chief amongst them is the need to ensure that changes are made to the Privacy and Electronic Communication Regulations (PECR) which would give organisations the ability to reach out to the people most in need of support, namely those who tend to be disengaged and hard to reach, without facing significant fines.

Spokesperson for TISA, Sophie Legrand-Green said,

“Unless changes are made to PECR, the potential consumer benefits of targeted support will not be realised as organisations, fearful of incurring significant fines, will be stuck in a communication impasse – unable to reach out to those who could benefit the most from these proposals. Organisations are unlikely to have the required consents to communicate with disengaged consumers, which could block progress as these consumers will not grant the required permissions, as they are by definition hard to reach.

With this in mind, we urge the FCA to support efforts to amend PECR to allow such communications, ensuring that targeted support does not fall at the first hurdle and is able to support millions more people to prepare for retirement”.

In the consultation response, TISA also welcomes the overall ‘outcomes based’ approach taken by the FCA, endorsing their direction of travel in allowing organisations to develop their own wording around disclosures and in how to demonstrate success in relation to delivering better outcomes, and called for:

  1. Targeted support to be a distinct permission under the Regulated Activities Order (RAO) to ensure that it is only offered by appropriately resourced and skilled organisations and individuals
  2. The Financial Ombudsman Service (FOS) to be effectively  integrated into this policy area.
  3. A degree of foreseeability to be introduced to the targeted support definition and the better outcomes threshold.
  4. Adequate space to be given for Simplified Advice to give consumers a suite of financial support options

Mrs Legrand-Green added:

“Innovations, such as Targeted Support, are a significant step to improving financial well-being for consumers who find themselves caught in the advice gap, uncertain of making key financial decisions. Targeted Support could help turn millions of savers into investors, helping to make people’s money work harder for them and increase inclusive economic growth.  We’re heartened by the tone and approach of the FCA and look forward to working with them and the other key stakeholders in the months ahead.”

Ends 

Notes to Editors:

  1. The full consultation response can be seen at: https://www.tisa.uk.com/wp-content/uploads/2025/02/FCA-CP-24_27-TISA-Response.pdf
  2. The FCA Consultation Paper can be seen at: https://www.fca.org.uk/publications/consultation-papers/cp24-27-advice-guidance-boundary-review-targeted-support-reforms-pensions
  3. TISA is a not-for-profit membership organisation with the ambition to improve the financial wellbeing of all UK consumers. By working, collectively, with the financial services industry, TISA delivers evidence-based, strategic solutions that benefit people, industry and the nation.
  4. TISA has over 270 member firms involved in the supply and distribution of savings, investment products and associated services, including the UK’s major investment managers, retail banks, online platforms, insurance companies, pension providers, distributors, building societies, wealth managers, third party administrators, FinTechs, financial consultants, financial advisers, industry infrastructure providers and stockbrokers.