SCENARIO B
Using Moneyhub’s pensions dashboard from your existing app
Under this scenario of providing a pensions dashboard, your organisation relies on Moneyhub’s PDS permissions, i.e. Moneyhub is making available its regulated PDS to your organisation as a third party. What do you need to do?
Collaborative delivery
Moneyhub will do the lion’s share of the work, but this will still need to be a collaborative project with your firm. The simplified table below summarises what you and Moneyhub will need to do, individually and jointly.
When should we start?
When you start will depend on how quickly you want to launch your dashboard to your customers (or members).
Remember that your competitors will be launching dashboards as soon as testing is complete (which could be in late 2024 or early 2025). The later you leave it, the less you will benefit from offering a dashboard: for example, you will begin losing customer primacy, and leaking assets under management, as soon as your competitors launch their dashboards.
TALK TO OUR GUIDES-
Decision to proceed
Make decisions 1, 2 & 3 (decision tree above), i.e. decide to:
Offer your customers a pensions dashboard
Partner with Moneyhub, securing necessary budget
Rely on Moneyhub’s PDS permissions (rather than applying to become a regulated PDS firm yourselves).
Moneyhub can support you with making your internal business case for the above.
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Definition of contractual arrangements between your firm and Moneyhub
including FCA required controls that you will not make any changes to the way our PDS is displayed to your customers
(because Moneyhub is the regulated PDS firm and retains all regulatory responsibilities in respect of the PDS provision).
Definition of user journeys
Jointly-specify the customer user journeys via which your customers will be passed:
From your app or website to Moneyhub’s dashboard
From Moneyhub’s dashboard back to your app or website.
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Apply to FCA to become a regulated PDS firm, including:
compliance with all PDP and DWP standards, pre-connection and annual independent compliance audits.
Regulatory business plan. Data export screenshots: including evidence of how we have considered customers’ understanding of giving their consent for the data export. Evidence of how the Consumer Duty (CD) outcomes have been considered. Moneyhub’s plans for making available our PDS to third party client firms. Moneyhub firm details:
Financial resources, Systems, Compliance and Thresholds.
Policies: Vulnerable customers, Complaints, Compliance monitoring, Risk management and Business continuity
Financials: Y1, 2 & 3 financial projections post-authorisation, Last annual accounts, Management accounts, Loans and Other external funding. Misc: Staff, IT controls, ICO status.
Payment of VoP application and ongoing supervision fees.