As confirmed in our recent communication, we are making a major investment in our systems. This will result in changes to how we operate the bank accounts linked to our products, and we are taking the opportunity to also make some general alterations to our terms and conditions.
The changes we are making take effect from 4 September 2020 and are explained in the letter we sent to you. You may also find the additional questions and answers below helpful.
Please download, read and save a copy of the terms and conditions for your product below. These terms and conditions take effect from 4 September 2020.
Updated terms and conditions
The SIPP Terms and Conditions are applicable to the following products:
- James Hay Modular iSIPP
- James Hay iSIPP
- James Hay Private Client SIPP
- James Hay Partnership SIPP
- IPS SIPP
- IPS (2008) SIPP
- IPS Pension Builder SIPP
- IPS Family SIPP
Additionally, these terms apply to any products which are part of the James Hay Personal Pension Plan.
Applicable to James Hay Wraps which are not held in the name of an individual.
Questions and answers
We are making these changes as part of a major investment in our systems.
All products we administer are affected (with the exception of the James Hay SSAS) but the impacts do vary depending on your product. Your letter sets out all the changes that are relevant to the product(s) you hold.
If we have a financial adviser recorded against your product, they will have been given advance notice of the changes and should therefore be able to help you understand them.
Are Financial Services Compensation Scheme (FSCS) protection limits affected by using pooled accounts rather than individual accounts?
No, you will still have deposits protected up to the current limit of £85,000 for each bank holding your money. We record your individual cash holding within the pooled accounts, so the FSCS would look through to who we are holding money for when paying any claim in the unlikely event of a bank’s failure.
FSCS protection applies per individual and for each bank holding your money. So if you also hold money with a bank in any personal or joint accounts outside of your James Hay product(s) that we are using to hold your money, the FSCS protection limit applies to the combined amount of these accounts.
Please also note that cash held in the Wrap Offshore Bond is not covered by FSCS protection as the product falls under the Isle of Man Compensation of Policyholders scheme. Please refer to the Key Features of the Wrap Offshore Bond for details, which can be found in the Literature section of our website.
When the changes take effect on 4 September, we will confirm all of the banks that we are using to hold our customers’ cash on our website.
How will the pro rating of any shortfall in funding be applied in the unlikely event of one of the banks’ failure?
For cash held in the Wrap (excluding Wrap SIPP), Modular ISA, and Modular GIA:
If a bank is unable to pay us back all the client money we hold with them (so there is a shortfall) we have to share that shortfall across all of our customers for whom we are holding client money. If 10% of our pooled cash were with a particular bank and that bank could only repay half of this amount then each customer would have a potential shortfall of 5% of their cash balance. Please note that in practice, if the shortfall is less than £85,000 per client, the FSCS would cover the shortfall amount.
For cash held in SIPP products, for example the Modular iSIPP, iSIPP and Wrap SIPP:
Pooled cash is spread across customers in the same proportion, except where this would cause the balances held by a customer to exceed £85,000 with a bank not approved by us for that purpose. In these circumstances the amount allocated to that customer for that bank would be capped at £85,000. In the event that a bank is unable to pay us back all the money we hold with them, the shortfall would be shared across all customers in proportion to the cash they hold with that bank. Please note that in practice, if the shortfall is less than £85,000 per client, the FSCS would cover the shortfall amount.
No. Income payroll will continue to be paid in line with the existing timetable. Please refer to the payroll dates page on our website for further information.
Direct Debits for money paid into your James Hay products DO NOT need to be amended as they will be automatically re-routed.
You will however be required to amend all Standing Orders that are currently set up to make payments into your James Hay products. As Standing Orders are set up by the payer, we do not have the ability to re-route them.
Additionally, please ensure you use the new bank details for any single payments made to us from 7 September as confirmed in your letter.
Do I need to use different bank account details to make payments into my commercial property account rather than for personal payments such as contributions?
The account number and sort code will be the same as those to be used for personal payments, however, payments made in respect of a property/land should be made using a separate reference. We will therefore be writing to all impacted investors in the week commencing 24 August 2020, to confirm which reference you should use.
We will also ask self-managed property holders to confirm the bank account details and reference to third parties who pay money directly to us in connection with the property. Property holders who use our property management company, CBRE, will not be required to take any action.
You will no longer be able to pay VAT to HM Revenue & Customs (HMRC) for a property via a Direct Debit. Instead, you will need to provide us with a copy of your VAT Return within 10 working days of the due date and we will process a payment to HMRC.
As confirmed in your letter, we ask that you contact your employer and provide them with your new bank details in order to make contribution payments to your SIPP. If they pay by Direct Debit, they will not need to take any action as the Direct Debit will be re-routed automatically.
Please ensure you use your new bank details from 7 September, otherwise there may be delays in allocating payments or they may be rejected.
Please ensure you use your exiting bank details up until and including 4 September, otherwise payments will be rejected. Please also avoid making any payments to us over the weekend of 5-6 September, whilst we upgrade our systems.
Modular iPlan, iSIPP, Private Client SIPP and Wrap customers can find their account details on James Hay Online or by contacting James Hay. Customers holding other products should contact James Hay for confirmation. You can contact us by phoning 03448 014 103 or by sending us a secure message if you have access to James Hay Online.
We have seen a decline in the number of customers making payments to us by cheque. For this reason, we are withdrawing the option for customers to make payments to us with cheques from 1 January 2021.
Wrap, Modular ISA and Modular GIA only
Once the changes take effect on 4 September 2020, the bank accounts for the Wrap Investment Portfolio, Wrap ISA, Modular GIA and Modular ISA products will be held in the name of James Hay Wrap Managers Limited, which is the provider of these products, rather than in your name. This means we will no longer need to act under Power of Attorney in order to operate these bank accounts and products, nor will we need to ask for Power of Attorney should you open one of these products in future. If we already have a Power of Attorney in place over your product, this will remain on file but we will no longer act upon it. You therefore do not need to take any action regarding this change.
I hold a Wrap Offshore Bond (OFB) in my product but it is mentioned in my letter. Is the OFB impacted?
The money in the Wrap Offshore Bond is already held on a pooled basis as the money is owned by RL360, the provider of the Wrap Offshore Bond, rather than you as the customer. There are also no changes being made to the terms and conditions of the Wrap Offshore Bond.