Hartley Pensions Limited – in Administration

On 2 April 2024, clients were advised of how the joint administrators of Hartley Pensions Limited would implement the transfer out process, by allocating clients into different tranches subject to the assets held. The transfer out process commenced in May 2024, with tranche 2 clients being communicated to first, followed by defined programme in respect of the other tranches. To date 4,539 clients have been contacted, of which 1,286 have been transferred.

It should be noted that the Company’s records were not accurate as some clients contact details were out of date. Equally, the joint administrators have encountered a large number of clients not responding in each tranche contacted so far, and this is delaying the transfer out process. To date, 1,454 clients have not responded.

Please find below an update on the transfer out process for each tranche and the ongoing work required.

Tranche 1 

Tranche 1 relates to clients of ‘white labelled’ SIPPs where Hartley operated SIPPs on behalf of other business partners.

RL360 
The transfer of the RL360 clients was a scheme transfer, rather than individual client transfers. All 905 clients in this scheme have been transferred.

Ardan
There are 157 clients with Ardan SIPPs, of which 127 clients have confirmed their instruction to transfer to Ardan. To date, 75 clients have completed their transfer. Of the clients that have responded, 5 clients have advised they wish to transfer to an alternative operator.

Trireme 
There are 181 clients with Trireme SIPPs, of which 154 have responded. To date, 90 have transferred to Trireme. Of the clients that have responded, 28 have advised they wish to transfer to an alternative operator.

Platform One 
There are a total of 389 clients with Platform One, of which 356 have responded.

298 clients have agreed to transfer to Platform One, with the balance requesting a transfer to other operators.

No transfer has taken place to date as we are still undertaking a fee reconciliation with Platform One to ensure there are no outstanding liabilities. We anticipate this will be resolved by the end of July 2025, following which the transfers will commence.

James Brearley 
30 clients hold SIPPs with James Brearley. The transfer packs are to be issued week commencing 2 June 2025 offering clients a transfer to Platform One or, alternatively, an operator of their choice.

Fundment 
There are 239 clients with Fundment. The transfer pack was issued to clients on 16 May 2025 and, to date, 87 have responded and 77 have confirmed they wish to transfer to Fundment. It is currently envisaged that the transfers will commence by the end of August 2025.

Octopus 
10 clients hold SIPPs with Octopus (now Nova). Octopus has suggested a transfer of these clients to Curtis Banks and discussions in this respect are ongoing. We envisage the transfer pack to be sent to clients in late July 2025.

Simply Ethical 
There are 21 clients with SIPP’s hosted via James Brearley however managed by Simply Ethical. The transfer pack was sent to clients on 25 April 2025 and, to date, there have been 9 responses. No transfer has taken place yet.

Tranche 2 

Tranche 2 relates to clients with assets held of a value of £10,000 or less. There are 335 clients within this tranche, who have been sent their transfer pack.

To date, 112 have returned their forms and 32 have either been paid or transferred out.

Tranche 3 

There are 329 clients who have deceased, that we are aware of. These clients are being dealt with on an individual basis, depending on the assets held and associated documents available.

Tranche 4 

This relates to clients which Morgan Lloyd have advised they are willing to take on. The transfer pack was sent to two groups of clients, the first group were sent the pack on 9 September 2024 and the second group on 10 February 2025.

There are 1,510 clients which have been identified to date, of which:

• 607 have responded, of which 51 have been transferred to Morgan Lloyd; and
• 903 clients have not yet responded.

There are approximately 100 clients which are due to be transferred by the end of June 2025.

Morgan Lloyd are currently reviewing a further 741 clients to establish if they would be able to take them on. We expect Morgan Lloyd will advise us of the clients they wish to take on by the end of August 2025 and the transfer packs to be sent at the end of September 2025.  Any clients who Morgan Lloyd are unable to take on will be contacted separately.

Please note that this will exclude any clients with impaired assets and those with restrictions in place (as detailed below).  

Tranche 5 

Tranche 5 relates to clients who have identified an alternative operator to transfer to. 802 clients sit within this tranche, of which 728 have responded. 53 clients have been transferred to their new operator to date.  

Where a large volume of clients wish to go to one operator we are liaising with that operator to facilitate a bulk transfer.  This will be quicker in the long run for both operators, rather than performing individual requests.

Tranche 6 

There are 7,974 clients who hold impaired assets within their SIPPs.

No document pack is currently available for this tranche. A strategy document has been drafted and there are ongoing discussions with HM Revenue and Customs (“HMRC”) and the Financial Services Compensation Scheme (“FSCS”) with a view to resolving how these assets are dealt with, potentially to include the writing down or writing off of the failed investments. This will involve obtaining consent from the client and HMRC.

There are various categories of impaired assets. One of the major categories, storepods, is being discussed with the FSCS. For those clients holding a storepod, which has been compensated for by the FSCS, the FSCS are proposing that the asset is surrendered.  

Restricted SIPPS

There are 1,058 clients that have been contacted separately to notify them of a restriction on their account. We are ascertaining whether clients can partially transfer out, depending on the level of crystallisation of their account. In the interim, the restricted amounts have been ringfenced.

Whilst clients remain with Hartley they can operate their accounts as normal.

Conclusion
We would urge clients to complete and return the document packs they have received, without this no transfer can take place.  If you have not received a document pack and think you should have i.e. you believe you are in Tranches 1 to 5 please contact Hartley at admin@hartleypensions.com or 0117 316 9991.

Please do not contact UHY Hacker Young LLP as the UHY team will not be able to assist with issuing new document packs. 

Dear clients

You may have recently received correspondence from FS Legal offering their assistance (for a fee) for the following:

1. assistance with closing your SIPP; and
2. assistance with making a claim to the FSCS for annual management fees charged.

Clients should be aware that FS Legal cannot speed up the transfer of your SIPP, which requires the assistance of Hartley Pensions Limited and the joint administrators. The current process being undertaken is being funded by the FSCS. 

We are aware that FS Legal are charging a fee of £1,000 to assist with the closure of your SIPP. Please note that there have been no discussions with the joint administrators in relation to this proposal/course of action around this process and therefore an agreement has not been formed. Engagement with the joint administrators on this matter would (normally) be expected.  The correspondence we have seen from FS Legal specifically advises clients not to share the letter with the joint administrators which is highly unusual, given the need for engagement with us . Please be aware that engaging with FS Legal will not result in a quicker outcome/transfer of your SIPP.

In respect of making a claim to the FSCS, please note that the FSCS operates under rules set by the FCA and can only pay compensation where it is satisfied the requirements of these rules have been met. It is not clear why FS Legal consider annual management fees would be something that the FSCS would be able to compensate for under these rules. In any event, we are aware that the FSCS is not currently considering individual claims against Hartley but should the FSCS open to individual claims in future, clients would be able to make the claims themselves and therefore receive the total compensation (if any) that is recoverable.  

Should clients have any queries regarding closing/transferring their SIPP, clients are encouraged to speak to the team at Hartley by calling 0117 316 9991.

Kind regards

For and on behalf of 
Hartley Pensions Limited

For Peter Kubik
Joint administrator 
 

Please click here to access the Joint Administrators’ six month progress report.

Dear clients

Please find below an update on the current position for SIPP holders.

Please note that the above dates are estimates.

Clients are reminded that any responses to their document packs should be directed to the team at Hartley, either by email to admin@hartleypensions.com or phone on 0117 316 9991. Please do not contact UHY Hacker Young’s office as they will not be able to assist.

Whilst the transfers are ongoing transactions within your SIPP can continue as normal, with the exception of new contributions.

Christmas break

Please note that Hartley’s offices will close from 3.30pm on 24 December 2024, reopening at 9am on 2 January 2025.

Kind regards 

Further to the recent update, the work to improve the IT infrastructure is still ongoing and clients should be aware there will be significant down time during the week commencing 2 December 2024. The team at Hartley will continue to have access to phone calls and emails however there may be delays in responses due to limited access to client records during this time.

We apologise for any inconvenience caused.

Kind regards

Peter Kubik
Joint administrator
 

Dear clients

The Joint Administrators have continued with the transfer out strategy and Document Packs have been issued to the following tranches:

* Please note that tranche 1 also includes other client groups such as Platform One, James Brearley and Fundment, for who communications have not yet been sent but we anticipate sending over the next 4 weeks.

If you believe you fall into one of these tranches and have not received your Document Pack, please contact the team at Hartley either by phone on 0117 316 9991 or by email to admin@hartleypensions.com. Please do not call UHY Hacker Young’s office as we will not be able to assist with requests for Document Packs.

Please note that we are currently undertaking some work to improve the IT infrastructure which will commence from 4pm on Friday 15 November 2024 which we expect will continue until Thursday 21 November 2024. The Hartley team will continue answering calls and responding to emails during this period, however the Bristol office will be closed during this time and the team will not have full access to the servers. We appreciate client’s patience while this work is undertaken to update the system.

Kind regards

Skevi Iacovou
Director

Dear clients

Please be advised that communications have been sent to the following tranches regarding your transfer out:

If you are in the above tranches and have not received any communications, please contact Hartley Pensions Limited directly at admin@hartleypensions.com or 0117 316 9991 for a new Document Pack to be issued to you. Please do not call UHY Hacker Young’s office as we will not be able to assist with these requests.

* Please note that tranche 1 also includes other client groups such as Ardan, Trireme, Platform One, James Brearley or Fundment, communications have not yet been sent.

Kind regards

Peter Kubik
Joint administrator 

We are writing to you as we have identified that your Self Invested Personal Pension ("SIPP") may contain an asset which we believe to be impaired and/or toxic, as such your SIPP falls within Tranche 6 (as explained in our previous communications issued on 12 June 2024).

Toxic and/or impaired assets includes assets which: (1) the FSCS have previously paid out compensation; and/or (2) is a failed investment (such as shares in a company which has failed); and/or (3) has little or no value; and/or (4) has some other complexity which is limiting the Joint Administrators ability to transfer your asset.

This list is non-exhaustive and outlines the sorts of characteristics that would make an asset impaired and/or toxic.

FSCS compensated assets

Although clients may believe that receiving compensation from the FSCS brings the matter to a close, put simply, when the FSCS pays compensation, it does not remove the asset from your SIPP.

The Joint Administrators are working with the FSCS, and their legal advisers, to establish the best course of action regarding these assets. Until an agreement has been reached, your SIPP will remain open and you will continue to receive communications from Hartley or the Joint Administrators regarding the process, subject to a revised plan.

If your SIPP contains any other asset, as well as the impaired/toxic asset, you will continue to be charged an annual administration fee.

In the meantime clients are able to operate their SIPP as normal, subject to a minimum cash/asset balance remaining in your SIPP account to cover the annual administration fees.

The Joint Administrators are in discussion with the FSCS regarding a mechanism to address any partial balance of your annual administration fee that has already been charged to your SIPP, following the transfer of your assets.

Summary and next steps

As explained above, we are liaising with the FCA and FSCS regarding the impaired and/or toxic assets. Whilst we do not currently have a timeline for when these discussions are expected to conclude, we anticipate issuing client asset statement to Tranche 6 clients who the JAs believe holds toxic/impaired assets within their SIPP in the coming months.

We will contact you regarding your SIPP and next steps in the coming months, and thank you for your continued patience.

Yours faithfully

For and on behalf of Hartley Pensions Limited

Peter Kubik

Please click here to access the Joint Administrators’ six month progress report. 

Dear clients

Hartley Pensions Limited – In Administration (the "Company")

We refer to recent emails sent by FS Legal to clients who have registered to their portal.

In the latest communication from FS Legal, they have requested that clients pay them £1,000 to assist with closing their SIPP. FS Legal have stated that there will be many people with empty/toxic SIPPs that will need transferring out and the fees will be more expensive in the long run.

The comments from FS Legal are incorrect and have been made without any discussion with the Joint Administrators. We are therefore writing to explain the next steps and to reassure clients that it is not necessary to instruct FS Legal or any other representative in order to prevent SIPPs with impaired or toxic assets from being transferred.

We understand that some clients may have some questions following FS Legal’s emails, please see FAQ's at the bottom of this message.

The Strategy

To summarise the order in which SIPPs will be dealt with:

Tranche 4 represents the batch of SIPPs that do not hold any impaired or toxic holdings. Morgan Lloyd have indicated that they will be willing to take on these SIPPs;

Tranche 5 are those SIPPs where clients have indicated that they wish to transfer to an operator other than Morgan Lloyd; and

Tranche 6 represents those SIPP that hold impaired or toxic assets.

Impaired or toxic assets

We are investigating whether we can disinvest impaired or toxic assets from SIPPs, with the agreement of the client and HMRC, to avoid these being transferred wherever possible. The position is complicated and lengthy, but this is the outcome we are seeking to achieve.

For SIPPs containing only impaired or toxic assets, this would mean that the SIPP could be closed.

For SIPPs containing both liquid or standard assets and impaired or toxic assets the approach depends on whether or not the SIPP is in drawdown.  For those SIPPs that hold both a toxic asset and liquid/standard asset it is not possible to partially transfer a SIPP that is in drawdown and therefore the toxic asset needs to be dealt with first.

For those SIPPS that are not in drawdown, Morgan Lloyd have not stated whether they will or will not take on toxic assets, but it is their preference that the toxic asset is dealt with first, before the transfer.  This will be the same position for everyone not willing to transfer to Morgan Lloyd.

We are therefore working on removing impaired or toxic assets from SIPPs prior to any transfer or closure.

FSCS recoveries

There are a number of SIPP books which were acquired by Hartley prior to Administration where FSCS has paid a client’s claim for compensation against the former SIPP Operator. Where clients have received compensation from the FSCS, as a condition of paying that compensation, their rights against the firm in default and any third parties are assigned to the FSCS, and any sums that would be payable in respect of the claim will instead be paid to the FSCS. The FSCS is a statutory body and is subject to a duty to pursue recoveries using the assigned rights where it is reasonably possible and cost-effective to do so.  The Joint Administrators have been in discussion with FSCS regarding the impact of the assignments on the Strategy.

The FSCS have provided the Joint Administrators with a shortlist of impaired or toxic assets which the FSCS is using assigned rights to pursue recoveries. In these cases, the FSCS expects to be able to make a recovery. The FSCS’s rules state that where clients have uncompensated losses and the FSCS makes a recovery using their assigned rights, dependant on circumstances the FSCS may make a further payment to the client.

To assist with the Strategy, but allow the FSCS to continue to pursue recoveries, the Joint Administrators and the FSCS are investigating whether legal title to these assets can be transferred to the FSCS. This would mean transferring legal title to a new SIPP pension trustee would not be necessary. This will therefore reduce costs. We are currently in an ongoing consultation with the FSCS to determine if and how we can transfer the impaired or toxic assets on its recoveries list.

Once a SIPP has had the toxic asset dealt with by either ownership transfer or deregistration this will allow us to close these SIPPs.

Next steps

We will be dealing with the majority, if not all, toxic assets at no cost to the client. We therefore do not see how any involvement of FS Legal would be in client’s interests.

We hope to have resolved a large number of toxic holdings by the time we send out statements to Tranche 6 in September 2024.

The order in which the tranches are being dealt with is to ensure an organised and efficient execution of the exit and administration strategy.  Please be assured that work on Tranche 6, and in particular the treatment of impaired or toxic assets, continues alongside the work on Tranches 1-5.

Should you have any queries, please contact the Hartley team by telephone on +44 (0)117 316 9991 or by email at admin@hartleypensions.com.

Yours faithfully

Peter Kubik

Joint administrator

The affairs, business and property of the Company are being managed by the Joint Administrators, who act as agents of the Company and without personal liability. 

FAQS

The communication from FS Legal raise the following questions:

1. Do I need to instruct FS Legal to close my SIPP which contains solely toxic/impaired assets?.
   • There is no requirement or benefit in instructing FS Legal, or any other company, as this will not speed up the closure of your SIPP. The Joint Administrators have already commenced this process and are in ongoing discussions with the FSCS and HMRC as described above.
   • As previously advised, the Joint Administrators are funded by the FSCS to transfer and/or close clients SIPPs at no cost to the client. Therefore we want to make clear that clients do not need to spend any monies with FS Legal in this process as this will not hasten the process already in place.
2. Will I be charged an annual administration fee if I have a mixture of liquid/valuable and toxic/impaired assets within my SIPP?
   • A SIPP containing a mixture of holdings continues to be managed as before, investment decisions can continue to be made and pension draw down can continue. For this reason, annual fees will continue to be charged.
3. Do I need to instruct FS Legal to pursue losses relating to Hartley pre-administration?
   • The FSCS is the compensation scheme for customers of UK authorised financial services firms such as Hartley, and protects consumers when those firms are not able to meet protected claims against them.   Once it its open to claims against Hartley, clients can make claims directly to the FSCS who will process these free of charge, and without making the charges that a claims management company will levy.  
   • FSCS is not yet open to claims, whether direct from clients or representatives. This remains the case pending FSCS’s investigations into whether there may be any further protected claims against Hartley that would allow them to pay compensation under their rules.
   • The FSCS will publish updates on its website:
     https://www.fscs.org.uk/making-a-claim/failed-firms/hartley-pensions/
      

Please click here for a further update on the transfer out process.

Please click here for an update on the progress of the administration.

Please click here for an update on the progress of the administration. 

Please click here to access the Joint Administrators’ six month progress report.

Please click here for an update on the progress of the administration. 

Please click here to see further communication from Spencer West, acting for the new representative respondents. 

Please click here to see the order issued following the hearing on 22 January 2024. You will note the hearing has been adjourned to the week commencing 5 February 2024. An update will be issued once the date has been confirmed. 

Please click here for an update on the progress of the administration as well as communication from Spencer West LLP on behalf of the alternative representative respondents. 

Please click here for a further update on the progress of the administration.

We refer to our recent update advising that FS Legal has been instructed by the proposed representative respondents (“RR’s”) regarding the court application to consider the exit and administration charge. 
 
We understand that from certain correspondence from clients there may be some confusion in this regard. The joint administrators have approached clients to become RR’s and six clients have agreed to take on this role. An application to court is required to formally appointed the RR’s and they therefore require legal representation. FS Legal have confirmed that they are willing to act on the RR’s behalf but for both the RR’s formal appointment and the application to consider the charge.  
 
FS Legal have asked us to advise clients that there is a letter on their portal for clients to consider. In order to access the letter, you will need to register on the portal at www.hartleypensionsgroup.ning.com. Whilst we have had sight of the letter, we have not had any input in its contents and clients should note that there is no obligation to provide the requested funding. All queries regarding this funding should be directed to FS Legal at hartley@fsl.legal as we are unable to comment on it. 

We also understand that FS Legal have added on their portal that there was a possibility of Hartley being placed into liquidation. Please be advised that the joint administrators have secured funding to continue trading whilst the application to court is made. Liquidation was only a possibility as the RR’s believed liquidation may have resulted in a return to clients from FSCS compensation, however the FSCS have advised that compensation on the proposed exit and administration charge is not currently available.  
 

Important update regarding Hartley Pensions Limited – In Administration and your self-invested personal pension scheme (''SIPP'')

We write to provide you with an update on the administration of Hartley Pensions Limited - in administration (''Hartley'') and, in particular, to inform you of the progress of the Court application and informal committee (the ''Committee'') that we referred to in our last update of 31 July 2023. 

Representative respondents

On 15 June 2023, we released communications to all clients explaining the role of the representative respondents (''RR'') and requested that any client who wished to become a RR should contact us. 

Following this communication, a number of clients came forward and the Joint Administrators (''JA’s'') have now agreed to appoint six RRs. The JAs consider these clients to be appropriate for the role of RR as they represent a wide variety of the SIPP schemes, asset holdings and value of assets held. 

The RR's have expressed a willingness to be formally appointed by the Court as soon as possible; we will update all clients with the RRs details in due course when this has been done but please note that the RR's can only be formally appointed once the Court application has been issued to ratify the Exit and Administration charge. 

Court application 

As you may be aware from our last update we advised you that we have recommenced work on the court application and expect to issue this in November 2023.

We continue to engage with the Financial Conduct Authority (“FCA”), Financial Services Compensation Scheme (“FSCS”) and RRs on this work.

Cost models

On 31 July 2023 we advised you that we had a meeting with the Committee to discuss the cost models which form the basis of the Exit and Administration Charge. As a reminder for clients, the Exit and Administration charge is a one off charge to cover the extra costs needed to administer an orderly transfer of your SIPP to a new operator given the failure of Hartley. Once this charge has been approved by the court, it will replace the contractual management fee. 

Since this meeting the JA's have also had a meeting to discuss the cost models with the RRs. Following these meetings, based upon the comments raised by the RRs and the Committee, the JA’s are now only considering the fixed fee per client model and the hybrid charge based on asset type model. A recap of these models is as follows:

1. The hybrid charge model is based upon the asset type within the client SIPP. Each client will be subject to a fixed fee charge depending on the type and number of assets they hold within their SIPP.
2. The fixed fee per client model is a flat charge for all clients, regardless of the type of assets that they hold within their SIPP. 

A further meeting is arranged with the RRs for 12 October 2023 where it is anticipated that a final cost model will be agreed between the RR’s and the JA’s. You will be updated once a final cost model has been agreed but you are able to find further information relating to this on the portal.

Client portal set up for SIPP holders

The six proposed RR’s (who are SIPP Holders) have nominated FS Legal Solicitors LLP (“FSL”) to advise them in relation to the proposed costing models court application.  FSL sat on the GPC SIPP Limited and the Harlequin Property creditor committees.  The firm specialises in financial services law and practice and is well versed in the issues that this matter raises. 

In order to be able to canvass opinion and to explain the process, FSL have set up a secure client portal for the approx. 17,000 SIPP holders.  It is vital that SIPP holders review the information contained within this secure portal and provide feedback.  

Access 

The secure portal can be access by going to www.hartleypensionsgroup.ning.com. When you get to the site sign up for a new account.  There is a “Click here to join” button, which will allow you to join.  You will be asked some basic question to allow you to be verified.  If you have any queries, please email hartley@fsl.legal.  The portal will go live in the week commencing the 16 October 2023.  It will include information about the proposed charges and how this could affect you.  Please take time to join the client portal.  It is there to assist SIPP account holders and to canvass view to better inform the RR’s, who will shortly need to formally respond to the application being made by the JA’s for the Exit and Administration charge.

Update on nominated operators 

All potential nominated operators have provided us with their offers and we are currently in the process of reviewing all proposals. All clients will be updated when one or more nominated operator(s) have been chosen.

If you have any questions in the interim, a list of responses to FAQs along with our previous communications can be found online at https://www.uhy-uk.com/hartley-pensions-limited-administration.

IMPORTANT - avoiding scams 

It should be noted that correspondence in relation to client schemes will only be issued by Hartley Pensions Limited or UHY Hacker Young LLP. Clients are reminded to remain alert and should correspondence be received by a third party, they should notify the Hartley Pensions team by any of the following methods:

Phone: 0800 063 9113 (Freephone for UK callers)
            +4420 3282 8151 (international callers)
Bristol office: +44 117 316 9991
Email: hartleypensions@uhy-uk.com or admin@hartleypensions.com

For more on how to protect yourself from the most common types of scams, ScamSmart pages on the FCA website provide advice on how to avoid investment and pension scams. 
 

Please click here to access the Joint Administrators’ six month progress report. 

The joint administrators are aware that a client of Hartley Pensions Limited (“Hartley”) has set up an action group website. We want to emphasise that this website contains several inaccuracies concerning both the administration of Hartley and its parent company, Wilton UK (Group) Limited. 

One significant inaccuracy is the claim that Mr Flanagan has leverage of UHY Hacker Young and therefore has control over the Hartley administration. This claim is entirely untrue. Mr Flanagan holds no authority over UHY Hacker Young, the joint administrators or Hartley itself. Upon the administration of Hartley, Mr Flanagan's directorial powers ceased and he no longer maintains any managerial position within the company. 

The website is soliciting funding via a GoFund website, though it fails to specify how the funds will be used. The joint administrators advise exercising caution if considering making a donation. 

Please be assured that the joint administrators are diligently addressing the situation and working to ensure that accurate information is accessible to all clients. 
 

Please click here to access the proof of debt form. Completed forms should be sent to Dhruv Maru at d.maru@uhy-uk.com, together with any supporting documentation, to formally submit a claim in the administration of Hartley Pensions Limited. 

Please click here for an update to SSAS clients. 

Please click here to view a further update to clients.

Please click here to view a further update to clients. 

Please click here to view a further update to clients and frequently asked questions.

Please click here to access the Joint Administrators’ six month progress report. Please note that clients are being provided access for information purposes only. 

The Joint Administrators are aware that a number of clients have been receiving communications from the following email addresses: ''admin@hartleypensionsuk.com'' and “info@hartley-pensions.com” as well as receiving calls from 020 7971 1496, 0117 251 0439 and 0117 251 0319. These messages and calls appear to represent that they are on behalf of Hartley, and the Joint Administrators are aware they have been requesting client’s bank details to process a refund. 

The Joint Administrators are also aware of communications being sent to clients by the following:

• Central Reservations UK, using the email "accounts@centralreservations-uk.com", advising clients to contact Hartley’s offices on 020 7088 8341 please note this is not a Hartley phone number;
• Chartered Trading Standards Institute advising clients to contact them on 08000 541 432; and
• Debt Collectors UK Limited requesting payment by client.

Please be aware that any correspondence received from these email addresses or phone numbers are NOT authorised by Hartley or the Joint Administrators and may be a scam. If clients receive communications from these email addresses or phone numbers, the Joint Administrators advise clients to disregard these and report it. Please do NOT provide any personal information, bank details or arrange payments to them.  

The Joint Administrators are also aware that some clients have received communications from Bowerstone Capital Limited claiming to have been instructed by The Insolvency Service to assist clients with recovering their assets. Whilst the correspondence from Bowerstone Capital Limited does not appear to mention Hartley Pensions Limited, the Joint Administrators have notified The Insolvency Service and they have confirmed they have not instructed Bowerstone Capital Limited. The Insolvency Service has referred us to the following link, which provides further information which they have published: Investors warned about approaches to recover lost funds - GOV.UK (www.gov.uk) 

It should be noted that correspondence in relation to client schemes will only be issued by Hartley Pensions Limited. Clients are reminded to remain alert and should correspondence be received by a third party, they should notify the Hartley Pensions team by any of the following methods:

Phone: 0800 063 9113 (Freephone for UK callers)
            +4420 3282 8151 (international callers)
Bristol office: +44 117 316 9991
Email: hartleypensions@uhy-uk.com or admin@hartleypensions.com
 

Please click here to view a further update to clients and frequently asked questions. 

Please click here to view an update to SSAS clients. 

Important update regarding Hartley Pensions Limited – In Administration - and your self-invested personal pension scheme (''SIPP'')

We write to provide you with an update on the current administration of Hartley Pensions Limited- in administration (''Hartley'') and in particular to inform you of the progress made in respect of the key tasks being conducted by Peter Kubik and Brian Johnson of UHY Hacker Young LLP (the "Joint Administrators") since their appointment as Joint Administrators of Hartley on 29 July 2022. 

Background Information 

As you may be aware Hartley entered into administration on 29 July 2022. This decision was made as a result of serious operational and regulatory issues. Due to this the Financial Conduct Authority (''FCA'') imposed a number of requirements on Hartley and upon seeking professional advice the director concluded that Hartley was or was likely to become cash flow insolvent in the future. As a result of this the director appointed the Joint Administrators to manage the affairs of Hartley. 

Updates on the Administration of Hartley 

The Joint Administrators are aware of the recent communications circulated by Mr Flanagan on 23 November 2022, as a director of Hartley Pensions Trustees Limited and Hartley SAS Limited. The Joint Administrators would like to make it clear that these communications were sent without the agreement of either the FCA or the Joint Administrators and are inaccurate and misleading.  

All information in regards to the administration of the SIPPs and all client concerns have been addressed in our FAQ page set up by the Joint Administrators. A further updated copy of FAQs is attached to this letter and a further link to the FAQ page is included below for ease of reference: https://www.uhy-uk.com/hartley-pensions-limited-administration

If after visiting the above webpage, you have any outstanding queries not covered by the FAQs you can contact the Joint Administrators on 0800 063 9113 or at hartleypensions@uhy-uk.com. Please ensure any email sent to this email address includes your SIPP/SSAS reference and we will respond to you as soon as possible. Please ensure that all queries are directed to either the customer service number or email address above rather than the individual contact details listed in Mr Flanagan's communications on the 23 November 2022.

Please click here to access SIPP client FAQs. 

Please click here to access an update to SSAS clients.  

We are aware that clients have been sent a letter from the director of Hartley Pensions Trustees Limited regarding your pension scheme. This letter has not been approved by the Administrators and is factually incomplete and inaccurate.

Communications will be sent to all clients from the Administrators shortly. Despite extensive efforts, the Administrators have not been able to secure a sale of the Hartley Pensions Limited SIPP business. As such, the Administrators are in the process of structuring a Court approved plan to transfer out clients’ SIPPs on an individual or bulk basis. The communications will explain the timescales involved but it is not expected that this process will conclude prior to the first quarter of 2023. With regards to the SSAS book, a sale is likely to be agreed shortly and it is expected that a sale of the SSAS business will complete by the first quarter of 2023 with SSAS clients transferred to a new operator.  

We remain committed to administering your pension scheme and appreciate that clients will be concerned from the communications circulated by Mr Flanagan. However, please note that these communications have been issued without any input from the Administrators and therefore are incomplete, inaccurate and should not be relied upon. 

Clients are not required to do anything at this stage but we will notify all clients once the more detailed communications are issued.
 

On 12 September 2022 the FCA lifted the restriction preventing clients from transferring their schemes to an alternative provider. 

Whilst the Joint Administrators acknowledge the lifting of this restriction, they are however unable to comply with any requests to transfer until such time as a full reconciliation of each client’s holdings has taken place. This reconciliation is underway and it is hoped that it will be completed by January 2023.

This does not affect the ability of clients to carry out normal transactions although there is still a restriction in place preventing voluntary contributions being made.

If you have any further queries, please email hartleypensions@uhy-uk.com

We anticipate that there will be a further update posted on the website on the progress in the administration in December 2022.

Please click here to access the joint administrators’ proposals. Please note that clients are being provided access for information purposes only and are not therefore able to vote on the proposed decisions. 

Hartley is the manager and operator of your Self-Invested Personal Pension ("SIPP") and/or Small Self-Administered Scheme ("SSAS"). Hartley is a separate legal entity to the corporate trustees which hold the money and assets within your SIPP/SASS on trust.

As a result of serious operational and regulatory issues, the Financial Conduct Authority ('FCA') imposed a number of requirements over Hartley.  As a result, Hartley’s director sought professional advice and concluded that Hartley will or is likely to become cash flow insolvent in the future.  Subsequently, the director has appointed Peter Kubik and Brian Johnson of UHY Hacker Young LLP as joint administrators (the “Administrators”) of Hartley on 29 July 2022. 

Hartley remains subject to a number of FCA requirements agreed with by, or imposed upon, it.  The requirements were agreed or imposed in an attempt for Hartley to correct a number of operational, financial and regulatory issues within the business and to protect Hartley's clients.  

PLEASE REVERT BACK TO THIS PAGE FOR FURTHER UPDATES.

The Joint Administrators had previously advised that an informal client committee had been formed in order to consider the various models available to fund the ongoing costs of the administration, to determine the fairest option for all members. Sharesoc, a not for profit organisation run by individual investors, is part of the committee. Any clients who wish to contact the committee can do so via Sharesoc’s website at https://www.sharesoc.org/contact-us/. 

Administration is an insolvency process by which Hartley has been placed under the control of insolvency practitioners, who will manage the affairs of Hartley, instead of the director. 

The Administrators have a statutory objective of achieving a better outcome for creditors than in a winding up of the firm (without first entering administration) and intend to continue to operate Hartley while a transfer of its SIPP book is arranged in order to meet this objective.

Peter Kubik and Brian Johnson, both of UHY Hacker Young LLP, were appointed as Administrators by the director of Hartley.  

The Administrators are both qualified insolvency practitioners, regulated by the Insolvency Practitioners Association.

Yes, Hartley remains authorised and regulated by the FCA (in relation to SIPPs) and the Pensions Regulator (“TPR”) (in relation to SSASs). The Administrators are in contact with the FCA, which consented to the appointment of the Administrators, and are having initial discussions with TPR. They will also speak to other relevant agencies such as HM Revenue and Customs, the Financial Ombudsman Service ('FOS'), and the Financial Services Compensation Scheme ('FSCS'). You will be provided with all relevant information in due course. 

Hartley is the manager and operator of your SIPP/SSAS. The money and assets held in the SIPP/SSAS are held on trust by a corporate trustee which is a separate legal entity to Hartley. 

The Administrators are now engaged in an accelerated sale process to secure an alternative manager and operator of your SIPP/SSAS. It is the intention of the Administrators to trade Hartley whilst in administration, subject to funding, to allow the Administrators time to arrange an orderly hand over of the management of the SIPP/SSAS to an alternative provider. 
 

Existing pension assets are held by trustee firms, which are not regulated by the FCA, and have not entered into administration. If this changes the Administrators will contact any clients affected.

The Administrators are seeking to agree an orderly handover of the management of the SIPP/SSAS to an alternative provider as soon as possible. Please see the report at the top of the page for more information.

PLEASE REVERT BACK TO THIS PAGE FOR FURTHER UPDATES.

On 12 September 2022 the FCA lifted the restriction preventing clients from transferring their schemes to an alternative provider. 

Whilst the Joint Administrators acknowledge the lifting of this restriction, they are however unable to comply with any requests to transfer until such time as a full reconciliation of each client’s holdings has taken place. This reconciliation is underway and it is hoped that it will be completed by January 2023.

This does not affect the ability of clients to carry out normal transactions although there is still a restriction in place preventing voluntary contributions being made.

If you have any further queries, please email hartleypensions@uhy-uk.com

We anticipate that there will be a further update posted on the website on the progress in the administration in December 2022.

The restrictions do not prevent you from accessing your pension in the normal course. For example, you are able to drawdown money in the usual manner, trade investments and request your pension commencement lump sum. The only restrictions are that no further contributions can be made to your SIPP and no transfers out can be made currently.

Members are not currently able to make any new contributions to their pensions. This is intended to ensure that no new member assets are received in a period in which customers cannot transfer out and/or Hartley is subject to the administration process.  

Yes. It is intended that you will be transferred to a new provider, following which you may move to a provider of your choice. Any transfer to a new provider will require FCA approval. 

No action needs to be taken at this stage whilst the Administrators identify an alternative service provider. Please bear with us. We will provide you with regular updates to let you know what is happening.

If you owe Hartley money you will likely be asked to pay that money.  You will be contacted with details of where the money should be paid.

The Administrators are doing everything they can to facilitate a smooth transfer to a third party provider. They ask that you bear with them whilst they do this but if you want to make a complaint, you can submit this to the following address:

E: Complaints@hartleypensions.com
T: 0800 063 9113 (Freephone for UK callers)
    +4420 3282 8151 (international callers)

The FSCS is the compensation scheme for customers of UK authorised financial services firms and protects consumers when those firms are not able to meet protected claims against them. 

The FSCS will not be opening its online claims service against Hartley yet. Following Hartley's insolvency, the FSCS will investigate whether there are any claims protected under its rules that would allow the FSCS to declare a default and pay compensation.

If Hartley is not able to meet claims against it, and the FSCS identify any claims eligible under their rules, customers will be entitled to apply for compensation up to the limit of £85,000. The FSCS will work closely with the Administrators and investigate whether there are any claims that meet the qualifying conditions for compensation.

You can obtain further information about the FSCS on its website:
https://www.fscs.org.uk/making-a-claim/failed-firms/hartley-pensions/

Claims management companies may approach customers of Hartley, offering to help them bring claims against it. Be cautious if you are approached by one of these companies.  For the vast majority of Hartley customers there is no benefit in involving a third party in making a claim.  

The FSCS is free to use. However, it is not yet open to claims, pending its investigations into whether there may be any protected claims against Hartley that would allow them to pay compensation under their rules. The FSCS will publish updates on its website:

https://www.fscs.org.uk/making-a-claim/failed-firms/hartley-pensions/
 

As a result of the appointment of the Administrators, Hartley is protected by a statutory moratorium which prevents any legal processes being initiated against Hartley. Consequently, you cannot make a complaint to the FOS. However, if you want to make a complaint in the meantime, please submit this to the following address:

    FAO: The Administrators
    Hartley Pensions Limited (in administration)
    c/o UHY Hacker Young LLP
    Quadrant House
    4 Thomas More Square
    London
    E1W 1YW

The Administrators will work with the FSCS to determine whether Hartley is able to meet eligible claims against it. The FSCS will not be opening its online claims services against Hartley yet.
 

If you already have a claim with the FOS, you don’t need to take any action at the moment. The FOS will be working closely with the FCA and the Administrators to agree an appropriate course of action. The FOS will contact you in due course regarding the next steps. 

Hartley's staff remain employed and the Administrators will continue to liaise with the staff throughout this process.

You can contact Hartley in the usual way as follows:

Post: Hartley Pensions Limited, 5th Floor, 25 Marsh Street, Bristol, BS1 4AQ

Phone: +44 (0)117 316 9991

Email: admin@hartleypensions.com 

Updates will be posted on the UHY website at:
https://www.uhy-uk.com/hartley-pensions-limited-administration

If you wish to advise the Administrators on any matters, please email them at hartleypensions@uhy-uk.com

You can also write to them:

FAO The Administrators
Hartley Pensions Limited (in administration) 
c/o UHY Hacker Young LLP
Quadrant House
4 Thomas More Square
London
E1W 1YW
 

Please end the call and contact the Administrators on 0800 063 9113.  Please remain alert to the possibility of fraud.