Who is responsible for reporting the transfers?

However, some of the reporting requirements to both HMRC and The Pensions Regulator were introduced and did not subsequently change. So this raises the question: If you, as an IFA, are providing transfer advice to say owner directors of SMEs, who should be doing the HMRC Registered Pension Scheme Event Report (APSS 300) and the subsequent Pensions Regulator form (PR12)? Officially, it is the trustees to the scheme, but the onus, directions and forms are as clear as the proverbial mud! So who carries the can when your client picks up a fine for your transfer advice? Time will tell as to w...