Cash & Investment Savings Technical Committee

Industry challenge

The industry needs to continually improve the way it engages with consumers

Group purpose

The Cash & Investment Savings Technical Committee aims to improve the reputation and effectiveness of the financial service industry through better engagement with consumers and promoting their interests.

Areas of focus

• Since the ISA regulations changed on 6 April 24, TISA, with the help of the Cash & Investment Savings Committee, has been discussing and corresponding with HMRC to try and clarify several of the ISA changes which have been causing concern to the industry. These include: allowing partial transfers of current year ISA funds between ISA managers from 6 April 24. There is a clear conflict between the amended regulations and the ISA guidance issued by HMRC; Expanding the Innovative Finance ISA to include Long-Term Asset Funds (LTAFs) and open-ended property funds with extended notice from April 2024. The amended regulations do not meet HMRC’s stated objective of permitting LTAFs to be held in innovative finance ISAs. Changes to the flexible ISA regulations and guidance are extremely confusing and causing genuine concern in the industry
• The Cash & Investment Savings Committee will be providing input into a TISA paper to reflect the above concerns, submitted to HMRC after the general election
• The Cash & Investment Savings Committee has provided valuable input to TISA’s response to the British ISA consultation which has now been submitted to HM Treasury. We wait to see whether the new Government pursue the introduction of this new ISA
• Members of the committee have continued to provide helpful feedback and expertise on the issue of fractional shares, a topic on which TISA has continued to liaise with HMRC/HMT on. HMRC has confirmed that draft regulations were close to issue prior to the announcement of the general election and it is hoped that the new Government will pursue the introduction of fractional shares within stocks & shares ISAs
• TISA has been liaising with UK Finance, the Building Societies Association (BSA) on the back of the FCA’s recent Cash Savings Market Review where the FCA wish to see the percentage of cash ISA transfers throughout the industry within 7 days raised from 85% to 90%
• TISA has been working with the Ministry of Justice (MoJ) to help inform members of a new Toolkit designed to help staff within the financial services sector direct customers successfully with mental health/incapacity issues
• TISA has been working with HMRC and the committee to organise some HMRC/HMT site visits to authorised ISA managers to help HMRC/HMT more clearly understand the processes of ISA managers
• In the lead up to the Autumn Statement, TISA submitted its Budget Representation Letter and liaised with HMT and HMRC to discuss our recommendations for simplifying and improving the ISA regime. Many of our recommendations were included in the 2023 Autumn Statement, with Government announcing the following: allowing multiple subscriptions to ISAs of the same type every tax year starting from April 2024 (TISA ask), allowing partial transfers of current year ISA funds between ISA managers starting from April 2024 (TISA ask), removing the requirement to reapply for an existing dormant ISA from April 2024 (usually referred to as the ‘gap year’ rule), expanding Innovative Finance ISAs to include Long-Term Asset Funds and open-ended property funds with extended notice from April (TISA had been calling for LTAFs to be included in ISAs), permitting certain fractional share contracts as eligible ISA investments (TISA ask), digitising the ISA reporting system to enable the development of digital tools to support investors, Harmonising the account opening age for any adult ISAs to 18 from April 2024 resulting in the minimum age for Cash ISAs increasing from 16 to 18, freezing the ISA (£20,000), JISA (£9,000), LISA (£4,000) and CTF (£9,000) limits at their current levels for 2024-25, reforming the Help to Save scheme (and will publish proposals in a response to the consultation on Help to Save Reform) as well as consulting on delivery of the new scheme. Following the Autumn Statement, engagement with HMT/HMRC will continue (particularly on the implementation of fractions). Since the Autumn Statement, TISA has provided feedback to HMRC/HMT on some of the key ISA regulation changes which came into force 6 April 2024.
• Detailed feedback has been provided to the HMRC policy team with regard to company liquidations. Current HMRC guidance is, arguably, having a negative impact on ISA customers who hold shares in liquidated companies in their stocks & shares ISAs. We await further feedback on this issue.
• TISA has finalised some joint work with UK Finance, the Building Society Association (BSA) on the back of the FCA’s 2023 Cash Savings Market Review.
• TISA has been liaising with the HMRC Compliance team to discuss concerns that the industry currently has regarding the HMRC ISA audit programme.
• TISA has been liaising with HMRC to discuss some potential problems relating to the reporting of Lifetime ISAs.

abrdn
Aegon UK PLC
Alder Investment Management
Allfunds Bank S.A.U
Bank of Ireland
Barclays Wealth
Cazenove Capital
CMC Markets Investments Limited
Coutts & Co
Cynergy Bank
Danske Bank
Digital Moneybox Ltd
Evelyn Partners
Fidelity International
Financial Software
Forester Life
Freetrade Limited
GoHenry Family Finance Limited
Hargreaves Lansdown
HSBC
Interactive Brokers (U.K.) Limited
Interactive Investor
JP Morgan Asset Management

L & G plc
LGT Wealth Management
Lloyds Banking Group
M&G Investments
NatWest PLC
Nude Finance Limited
OneFamily
Pershing
Phoenix Group
Quilter (formerly Old Mutual Wealth)
Raymond James Investment Services Limited
Rathbone Bros Plc
RBC Brewin Dolphin
Redmayne Bentley
Royal Bank of Scotland
Santander UK Plc
SS&C
Third Platform Services Limited
Unbiased Limited
Vanguard Asset Management
Virgin Money PLC
Walker Crips Investment Management
Yealand Fund Services Limited

David Beaston, Technical Manager/Trainer
leads on this work at TISA

Chair: Rob Jameson, M&G

Publications

News