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COMP 4A.3 Trusts, pension schemes and collective investment schemes

17/03/2026R

If any group of persons has a claim as:

  1. (1) trustees; or
  2. (2) operators of, or as persons carrying on the regulated activity of winding up a stakeholder pension scheme (which is not an occupational pension scheme) or personal pension scheme (or any combination thereof),

the FSCS must treat them as a single and continuing person distinct from the persons who may from time to time be performing those roles.

17/03/2026R

Where the same person has a claim as:

  1. (1) a trustee for different trusts or for different stakeholder pension schemes (which are not occupational pension schemes) or personal pension schemes; or
  2. (2) the operator of, or the person carrying on the regulated activity of winding up different stakeholder pension schemes (which are not occupational pension schemes) or personal pension schemes,

the FSCS must treat the claim in respect of each trust, scheme or fund as being the claim of a separate person, unless the claim relates to a single pooled investment failure impacting multiple trusts, schemes or funds.

17/03/2026R

Where the claimant is a trustee and some of the beneficiaries of the trust are persons who would not be eligible claimants if they had a claim themselves, the FSCS must adjust the amount of the overall claim to eliminate the part of the claim which, in the FSCS’s view, relates to any beneficiary who would not be an eligible claimant.

17/03/2026G

The look through in relation to pension schemes in COMP 4A.2.3R(1) means that:

  1. (1) where a member’s benefits are money-purchase benefits, the FSCS will treat any claim as though it was made by the member whether the claim is made by the individual member or the trustee of the pension scheme; and
  2. (2) where a member’s benefits are not money-purchase benefits, no look through will apply and the FSCS will consider any claim owed to either the trustee of the pension scheme or an individual member on its own merits.