Financial Ombudsman Service decision
Interactive Investor Service Limited · DRN-6175933
The verbatim text of this Financial Ombudsman Service decision. Sourced directly from the FOS published decisions register. Consumer names are reduced to initials by FOS at point of publication. Not an AI summary, not a paraphrase — every word below is the original decision.
Full decision
The complaint Mrs G complains that Interactive Investor Service Limited trading as Interactive Investor (IISL) caused delays in the transfer of her pension that resulted in her suffering a financial loss. What happened Mrs G held a Self Invested Personal Plan (SIPP) account with IISL, which in August 2025, she decided to transfer to a third party pension provider, who I will refer to as Provider A. The transfer application was completed via the Origo system, and the request received by IISL on 12 August 2025. This was rejected due to the information on the request not matching IISL’s system. IISL corrected their systems on 28 August 2025. Provider A submitted a new transfer request on 26 August 2025 which was accepted, the trades for the sale of Mrs G’s investments were placed on 8 September 2025 and the funds were transferred to Provider A on 12 September 2025. Mrs G was unhappy with the delays in transferring her pension, and on 24 September 2025 she complained to IISL. Her complaint was predominantly about the length of time taken to transfer and the fact the initial transfer request was rejected. On 14 November 2025, IISL provided their final response to Mrs G’s complaint. The complaint was comprised of three elements – the delay in the transfer, the amount of time taken to deal with her complaint, and the fact that the original transfer request was rejected. In relation to the amount of time taken for the transfer, IISL confirmed that the request was received and accepted from Provider A on 26 August 2025 and logged on 29 August 2025. They confirmed that the amount of time taken to log the transfer request was slightly outside of their standard timescales, and offered £50 compensation in respect of this. However, IISL concluded that the total transfer was within the timescales for transferring a pension, and did not uphold this element of the complaint. In respect of the time taken to deal with the complaint, IISL confirmed that they had responded in line with Financial Ombudsman and FCA standards. In respect of the complaint point relating to the fact that the initial transfer request was rejected, IISL upheld the complaint. They found that Mrs G’s address had not been fully updated within their internal systems and offered a further £130 compensation for the delay and frustration caused. Mrs G was not satisfied with this, and on 26 November she forwarded her complaint to this service. On 20 February 2026, our investigator provided her view. Having carried out an investigation she concluded that IISL’s errors caused a delay in the transfer of Mrs G’s pension to Provider A, and that if there had not been delays, the trades would have been placed on 20 August 2025, rather than 22 August 2025 as IISL had calculated. She stated that IISL should carry out a calculation of the transfer value if the trades had been placed on 20 August 2025, and compare this with the value that was actually transferred on 26 August 2025. If the amount transferred was less than the notional value, IISL should pay this amount to Mrs G.
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Mrs G accepted the investigator’s view. IISL did not agree with the investigator’s assessment of when the transfer could reasonably have completed, and stated that the correct date to be used for calculating whether Mrs G incurred a loss is 22 August 2025 rather than 20 August 2025 as indicated by the investigator. Because IISL did not agree with the investigator’s view, the complaint has been passed to me for a final decision to be made. 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. Having done so, I am in in agreement with the investigator, and for broadly the same reasons and uphold Mrs G’s complaint. In order for an Origo request to be processed, all the details within it must match what the transferring provider holds on their systems. In Mrs G’s case, the transfer request was initially rejected by IISL because the address details held on their systems did not match the request. IISL have confirmed that the reason for this was that the address on their systems was out of date. IISL corrected their systems on 28 August 2025. Provider A submitted a new transfer request on 26 August 2025 which was accepted, the trades for the sale of Mrs G’s investments were placed on 8 September 2025 and the funds were transferred to Provider A on 12 September 2025. It is not in any doubt that IISL’s errors in not updating Mrs G’s address resulted in a delay to the transfer of her pension. IISL have acknowledged this, apologised for their error and paid Mrs G £180 compensation for the trouble and upset caused. I have therefore not focused further on the cause of the delay, rather, I have considered the crux of the complaint, that is, the dates to be used for the calculation to put Mrs G back in the position she would have been in had it not been for IISL’s error. Following the correction of Mrs G’s address within their systems in order to allow the transfer request to proceed, it took IISL six working days to process the transfer (from 29 August 2025 when the second transfer application was received), and send the funds to Provider A (on 12 September 2025). This timescale is reasonable considering the funds needed to be liquidated, and in line with standard timescales for a transfer such as this. Therefore, I think it is reasonable to conclude that had the Origo transfer application been accepted when it was first sent to IISL, that it would have been likely to have taken the same amount of days to process the transfer. Therefore, based on the initial receipt date of 12 August 2025, it is fair to conclude that the trades required in advance of Mrs G’s monies being sent to Provider A should have been placed on 20 August 2025, six working days after the receipt of the transfer request. IISL have already completed a calculation based on the trades having taken place on 22 August 2025, which showed that Mrs G had not lost out financially due to the delays, and the amount actually transferred to Provider A was around £703 higher than it would have been had the delay not occurred. However, as outlined above, I believe that using a date of 20 August 2025 for the trades is fair and reasonable and in the circumstances, more appropriate.
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Putting things right In order to put Mrs G back in the position she would have been in had the error not occurred, IISL should carry out a calculation of what the transfer value would have been had the trades been placed on 20 August 2025 and compare this to the amount transferred to Provider A. If the notional value that would have been transferred is higher than the amount actually transferred, this is a loss, and the difference should be paid to Mrs G. Given that the value based on a trade date of 22 August 2025 showed a gain of over £700, I think it is unlikely that the calculation using 20 August 2025 will show that Mrs G incurred a loss due to the delays in transfer, however if the above calculation does show a loss, the compensation amount should be paid into Mrs G’s pension plan if possible. The payment should allow for the effect of charges and any available tax relief. The compensation shouldn’t be paid into the pension plan if it would conflict with any existing protection or allowance. If a payment into the plan isn’t possible or has protection or allowance implications, it should be paid directly to Mrs G as a lump sum after making a notional reduction to allow for future income tax that would otherwise have been paid. This isn’t a payment of tax to HMRC but an adjustment to make sure Mrs G isn’t overcompensated. If Mrs G has remaining tax free cash entitlement, 25% of the loss would be tax free and 75% would have been taxed according to her likely income tax rate in retirement, presumed to be 20%. So making a notional reduction of 15% overall from the loss is appropriate. IISL have already paid Mrs G a total of £180 to recognise the distress and inconvenience caused by their errors. I have considered the impact of IISL’s error on Mrs G, and also taken into account the levels of compensation which this service would typically award for errors such as this. I am satisfied that the amount paid (£180) is in line with what this service would typically award for delays such at those experienced by Mrs G. I understand that IISL have already paid this amount therefore there is nothing further to pay in respect of this. My final decision I uphold Mrs G’s complaint against Interactive Investor Service Limited trading as Interactive Investor. They should carry out a calculation as outlined above and pay any loss to Mrs G. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs G to accept or reject my decision before 26 May 2026. Joanne Molloy Ombudsman
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