St James's Place Wealth Management Plc · DRN-5927536

The complaint Mrs M has complained that St James’s Place Wealth Management Plc (“SJP”) did not provide annual reviews for her Individual Savings Account (“ISA”) that she has paid for. She is also unhappy that SJP kept taking the annual fees but did not make any changes when the investment was dropping in value. What happened Mrs M met with SJP along with her husband in 2008. They both made some investments following this meeting. Mr M’s complaint is being dealt with in a separate complaint. Around November 2008, Mrs M invested into an ISA with SJP. As part of the process a fact find was completed which confirmed the following information: • Mrs M was aged 42 and married. • She was employed and earned £40,000 per annum. • She had a joint disposable income of £1,500 each month. • She had £4,900 invested in an ISA and £26,000 held jointly on deposit. • She had a medium attitude to risk. • She liked the SJP way of investing. A suitability report dated 5 November 2008 was provided. It confirmed the information in the fact find and recommended Mrs M start a regular premium ISA of £100 per month invested in the UK High Income Trust. Mrs M was then advised to invest a further £3,000 into her ISA in a suitability report dated 5 May 2017 and the advice was to invest 30% into Global Equity, 20% into UK High Income and 40% into Worldwide Opportunities, in line with her medium attitude to risk. Just over a year later a suitability report dated 10 August 2018 recorded that Mrs M was recommended to make a further regular contribution of £100 into her ISA. The suitability report confirmed that she was happy with the UK High Income fund but wanted a more global approach, so the Worldwide Opportunities fund was recommended. A review took place in 2021 and this was confirmed in a suitability report dated 9 March 2021. At this stage a switch of funds was recommended where 10% was to be invested into the Asia Pacific, Emerging Markets, North America, Global Managed, Global Quality, Global Equity, International Equity, UK & International Income, UK & General Progressive and UK Growth funds. A further review was confirmed in a suitability report dated 23 August 2022, where no changes were recommended. Mrs M transferred her ISA away from SJP in November 2022.

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From the relevant date after the implementation of the Retail Distribution review (RDR) on 31 December 2012 (explained in more detail below) Mrs M was paying an Ongoing Adviser Charge (“OAC”) of 0.5% on her ISA. On 22 July 2024, Mrs M complained to SJP but this does not appear to have been received until 18 February 2025. She said that she had not received all of the reviews that she had paid for and SJP continued to take fees and did not act when her investments were falling in value. SJP upheld Mrs M’s complaint in a letter dated 3 April 2025 as it found that it didn’t carry out reviews of her ISA in the years 2019 and 2020. It offered to refund the charges she had paid along with a further £150 for distress and inconvenience. Mrs M didn’t agree with SJP’s answer to her complaint and so brought her complaint to the Financial Ombudsman Service on 4 April 2025. One of our investigators assessed the complaint and was satisfied with the offer SJP had made to Mrs M to refund the charges she had paid for the missed reviews of 2019 and 2020 as he found that the reviews of Mrs M’s ISA had taken place in 2018, 2021 and 2022. Mrs M didn’t agree with the investigator’s assessment as she felt not all of the applicable charges were included in SJP’s offer. So because of this the complaint has been passed to me to decide. 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. I’ve taken into account relevant: law and regulations; regulatory rules; guidance and standards; codes of practice; and (where appropriate) what I consider to have been good industry practice at the relevant time. Where the evidence is incomplete or inconclusive I’ve reached my decision based on the balance of probabilities – in other words, on what I think is more likely than not to have happened given the available evidence and wider circumstances. The focus of this decision is the method of calculating the redress. However, I must first consider which dates of the reviews fall into the scope of this Service. Mrs M’s ISA started in November 2008 and was transferred away from SJP in November 2022. The start date of the investments is important because before 31 December 2012 Mrs M’s investments didn’t attract any ongoing review charges and while an ongoing fee may have been taken, this was effectively deferred commission and there was no obligation for an adviser to provide any ongoing service in order to be able to receive this. However, on 31 December 2012 the rules governing how advisers are paid changed across the industry. This was known as the RDR, as mentioned earlier in this decision. The changes meant that when a review service was to be provided a separate charge known as an OAC should be agreed and deducted from the plan and could be turned off should advice no longer be required. This charge couldn’t be applied retrospectively and would only apply to investments that pre- dated the introduction of the RDR upon a “triggering” event which, in the case of Mrs M, happened in May 2017 when she added to her ISA. So this meant that the annual advice

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reviews should have started on or around twelve months after that point - May 2018. Its important to note that the reviews didn’t necessarily have to take place in May and could have taken place within a reasonable time period. So, Mrs M only started paying OACs from May 2017 and this is the point when SJP’s obligations to Mrs M to annually review her investment began. Merits Having looked at the paperwork provided that came about during Mrs M’s relationship with SJP I have seen letters that show the reviews of the ISA were carried out in 2018, 2021 and 2022. So the only missed reviews were 2019 and 2020. I therefore agree with the offer that SJP has made to Mrs M to refund any charges she paid for those missed reviews as well as the offer for the interest to be added and the payment for the distress and inconvenience caused. Mrs M must be clear that the refund is for the reviews that SJP failed to deliver and that she had paid for because in respect of these SJP failed to meet its obligations. Therefore, it is only right that the charges paid for the service that didn’t take place are refunded. Along with the OACs that Mrs M was paying there were also other charges that were a part of her contract with SJP – such as annual management charges, dealing costs, administrative charges and the charges for fund managers. These are distinct from the OACs and are charges which in my view SJP is entitled to retain because it met its obligations under these charges – it invested the funds as required, bought and sold units, managed the administrative side of the investments such as providing statements and market valuations. And while I know Mrs M feels this wasn’t the case because she thinks she has lost money on her investment there is no correlation between this part of SJP’s obligations and the performance of the investments. I know Mrs M has expressed her dissatisfaction with the level of the compensation however having clarified the calculations with SJP I am satisfied that the offered compensation has been calculated in line with the approach this Service normally uses in complaints such as this one. It is important for Mrs M to note that the OAC for the ISA was 0.5% as clearly set out in the illustrations she was provided for the ISA from the time. Furthermore, as the plans had commenced pre RDR and had become post RDR in 2017 the fees would not be applied to the whole fund value as some tranches would have been pre RDR and no OACs applied to them. So, this too may account for the level of the refund not being as high as she would like. However, as I have said above, I have looked at the charges that were paid for the ongoing advice service that applied to the investments made into the ISA after the RDR came into effect and I am satisfied that the calculations are correct. My final decision My final decision is that I don’t uphold this complaint. But I direct St James’s Place Wealth Management Plc to pay Mrs M the compensation it has already offered in its letter of 3 April 2025 along with the interest payment and the further offer of £150 for the distress and inconvenience caused.

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Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs M to accept or reject my decision before 22 April 2026. Ayshea Khan Ombudsman

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