DRN-6191799

The complaint Mr I complains that he’s been unable to encash his pension policy with ReAssure UK Services Limited (ReAssure). Mr I says ReAssure’s requests for identification (ID) documents have unnecessarily delayed the encashment of his policy and caused him financial hardship and stress. What happened In summarising what’s led up to Mr I’s complaint and the current position, I haven’t referred to everything, just the key developments. Mr I has a pension policy which was set up in September 2006 with Skandia, now ReAssure. ReAssure lost contact with Mr I and his policy was marked ‘Gone Away’. However, Mr I got in contact in June 2025. He made a Data Subject Access Request (DSAR) and gave a UK address. On 16 June 2025 ReAssure emailed Mr I saying, due to data protection regulations, it needed to make sure that the correct information was issued to the correct person. One measure was to match a signature to what was held on its files. Mr I’s request hadn’t been signed so he’d need to re-submit it with a signature. Mr I supplied a partial copy of the signature page of his passport. On 30 July 2025 ReAssure sent the data to an address in the UK. And, on 15 September 2025, ReAssure sent policy information to Mr I at that UK address. On 16 September 2025 Mr I emailed ReAssure saying he lived overseas and asking if correspondence could be sent there – the previous correspondence had been sent to his parents’ home. That was when ReAssure first became aware that Mr I was living overseas. Mr I emailed ReAssure again on 17 September 2025. He’d received a pension statement but the email was encrypted and he couldn’t reply to it directly. He gave his details and asked if it was possible to cash in his pension and what forms or documents ReAssure required, the expected timeframe and if there were any tax implications or charges. Mr I emailed ReAssure again on 25 September 2025. He said the only response he’d received was a message asking him to call ReAssure. He didn’t want to call but he did want to start the process of getting his money. He asked for instructions and that ReAssure stop sending emails he couldn’t reply to. ReAssure replied the next day saying, before proceeding, it needed to confirm his identity. ReAssure needed certified copies of two ID documents. The copies had to be signed by a UK lawyer, banker, authorised financial intermediary or accountant. Mr I emailed on 27 September 2025, asking that all future email communication was non-encrypted unless legally necessary as it slowed down the process. Mr I became unhappy with how long things were taking and complained to ReAssure. He was also unhappy that, when he’d called ReAssure on 28 October 2025, the call had cut off and he hadn’t been called back. ReAssure issued a final response on 31 October 2025. It didn’t uphold the complaint and said encrypted emails were used for security purposes to protect customers’ data. ReAssure required ID to update Mr I’s address. He’d said ReAssure had previously accepted what he’d

-- 1 of 7 --

provided but he’d given an address in the UK, not overseas. ReAssure required full primary and secondary ID, certified as set out in the email dated 26 September 2025. About the phone call, ReAssure said the call handler had tried to call back twice but was unable to make contact. Mr I emailed ReAssure on 31 December 2025. He said continued administrative obstruction and repeated re-starting of the process had prevented him from accessing money to which he was entitled and was causing ongoing financial and emotional distress. He asked that it be flagged as a hardship/vulnerable case and reviewed urgently. ReAssure issued a further response on 8 January 2026, saying it had reviewed the matter, but the decision was unchanged. To proceed with any payment, ReAssure required fully certified ID – it had only received a partial image of Mr I’s passport. By then Mr I had referred the matter to this service. He said he was in a difficult financial situation as he’d been trying to access his pension fund for some months. He felt ReAssure had made unnecessary demands. Another pension provider had paid out his pension with no delay. He’d been abroad for 17 years and he said ReAssure didn’t expect him to claim. ReAssure had checked his identity in September 2025 when access to his account was given, so he’d already proved who he was. ReAssure’s behaviour constituted systemic delay, bad faith, and a clear breach of the Financial Conduct Authority’s Principle 6 – a firm must pay due regard to the interests of its customers and treat them fairly. ReAssure’s internal policy was a barrier to payment, refusing practical overseas ID verification options. To put things right, Mr I wanted ReAssure to accept non UK certification, encash his fund and pay compensation for distress, inconvenience and expenses incurred. He suggested an interim payment would be appropriate. His financial situation was critical and ReAssure’s repeated delays and administrative obstruction had put him in an increasingly vulnerable position and caused considerable stress. When we asked for ReAssure’s file we told ReAssure what Mr I had said about his extreme financial difficulty and that he needed the funds immediately. We also said he’d asked for an interim payment, although we appreciated that ReAssure couldn’t make a payment until it was satisfied and had completed regulatory checks. But we were passing the message on to ReAssure just in case there was anything that could be done to help Mr I. ReAssure explained that it was able to update Mr I’s address in July 2025 to one in the UK by verifying his signature. But, in September 2025, he’d emailed to say he was living overseas. Updating records to an overseas address has more stringent requirements – enhanced ID verification. His request was originally low risk as he was just asking for information about the policy. But he then wanted to encash it. However, ReAssure said its requirements outlined in the letter sent on 26 September 2025 had contained an error. It said the ID documents had to be certified by a UK lawyer or other professional listed. But, as Mr I lives abroad, ReAssure wouldn’t expect him to obtain certification from a UK professional. Further, the letter didn’t give a full list of acceptable certifiers as per the Customer Identification Guide which didn’t seem to have been enclosed with the letter. ReAssure said its error had caused confusion and delay for which it was deeply sorry. ReAssure offered £500 for distress and inconvenience. ReAssure also said it would undertake a loss assessment once the policy proceeds had been paid out to ensure Mr I hadn’t lost out financially. That was on the proviso that he returned the required enhanced ID documents within the next 28 days. ReAssure said its letter of 26 September 2025 had caused the initial delay and so that would be the starting point of the loss assessment. ReAssure explained the timeframes that would apply.

-- 2 of 7 --

ReAssure couldn’t agree to any interim payment until its enhanced ID requirements for overseas customers had been met. We put the offer to Mr I. He was initially prepared to accept it, but he then expressed concern about possible bank charges, which he’d experienced with a payment from another provider. He also queried why ReAssure needed documents certified by a lawyer or other professional when another provider hadn’t. We asked ReAssure to confirm what documents it required. ReAssure said Mr I needed to provide one item from the enhanced identification List 1 (to verify his name) and one from List 2 (to prove his address). ReAssure explained the certification requirements in more detail. Mr I said he could supply a recent bank statement and his passport. But to get the documents certified he’d need to drive three hours each way to the UK Consulate. If he was expected to do that then he’d reject the offer as he’d want £750 to cover expenses. He said that what ReAssure was asking for wasn’t a legal requirement as the other pension provider hadn’t insisted on it. And ReAssure had verified his ID months ago when he’d been given access to his account and even though ReAssure had said he’d only sent a scan of half a passport page. ReAssure maintained that certified copies were required. As agreement wasn’t reached, the investigator issued her view on 11 February 2026. She said that the crux of the complaint related to ID and what was/wasn’t required. She said it wasn’t for us to say how a business should run its day-to-day operations. ReAssure was allowed to set its own ID requirements. Mr I had told ReAssure he was living abroad and wanted to withdraw all his pension. It was reasonable for ReAssure to ask for ID as Mr I was changing personal details and asking to take all the money. Once funds had been paid out they’d be very difficult to recover. Mr I was trying to access funds that were his but there were scammers who might try to access funds illegally. The investigator couldn’t comment as to how another provider had done things. She empathised with what Mr I had said about it being a six hour round trip to the UK Consulate and she set out the list of acceptable certifiers in case Mr I could find someone closer to home. The investigator noted that ReAssure had admitted that incorrect information was provided on 26 September 2025 and wasn’t corrected until 2 February 2026, a delay of 88 working days. She said, once the pension had been encashed, ReAssure should calculate the total notional payment Mr I would’ve received had it been paid 88 working days sooner, net of his marginal rate of tax, and compare that with the actual net payment he’d receive. She set out further details as to how any loss should be paid. She thought the deadline specified by ReAssure was reasonable, after which the offer would expire. She also said ReAssure’s offer of £500 for distress and inconvenience was fair. Mr I responded to say he’d have to take a day off work and try to find an English-speaking lawyer or notary as the UK Consulate no longer provided that kind of service. He later reported back that he’d been to his bank and to a lawyer, but neither could help. He’d also contacted his local UK Consulate representative who’d said others had encountered the same issue and the only way round was to tell the pension provider that they needed to offer a different ID verification method. The investigator relayed to ReAssure what Mr I had said and asked if there was any other form of ID that ReAssure would be prepared to accept – for example, Mr I’s passport, bank statement and utility bill uncertified. Mr I said he’d sent us everything – a bank statement, his passport and a video he’d made of himself holding the passport, all of which we forwarded to ReAssure. There were some difficulties regarding the video but Mr I had already sent it

-- 3 of 7 --

direct to ReAssure anyway. I don’t think ReAssure was able to view it but, in any event, ReAssure didn’t think it would be acceptable. Mr I said he wanted to proceed with a referral to an ombudsman as he was unable to collate the information needed to meet ReAssure’s ID requirements. After the complaint had been passed to me, I asked the investigator to contact Mr I on my behalf. I recognised his position – he needed access to his funds urgently and the ongoing situation was causing financial hardship. I didn’t want to prolong things unnecessarily or cause further distress. But I thought coming to an agreement would be the quickest way to resolve matters. So I wanted to check with Mr I if there was any way he could meet ReAssure’s ID requirements, maybe using an electricity or other utility or internet provider’s bill. As we told Mr I, we’d also contacted ReAssure again to see if it had any further suggestions as to how the ID issue could be resolved and we’d asked for an urgent response. ReAssure said it was already looking to make exceptions to its usual requirements by considering non-certified ID. It was seeking some secondary ID, that is something different to the bank statement to confirm Mr I’s address, such as a utility bill. ReAssure said the Payment Release form had been issued and bank details requested. Mr I told us that he doesn’t get water or gas bills and his internet was paid upfront with no bill due until June next year. But his electricity bill usually arrived around the 25th of the month so as soon as it did, he’d scan and send it to us. He sent us a copy of that bill on 25 March 2026 which we forwarded to ReAssure. We asked ReAssure on 1 April 2026 if there was any update. We were seeking a response as soon as possible or at the latest by 9 April 2026. Mr I copied us in on the email he sent to ReAssure on 4 April 2026. He attached his completed Pension Lump Sum Application Form, a copy of the photo page of his passport and payment instructions. He said he’d been waiting for ReAssure’s reply about the electricity bill but, as ReAssure appeared to be ‘stalling even further’, he’d now decided to send the withdrawal form regardless. He set out why he considered the documents he’d already provided were more than sufficient to meet ReAssure’s requirements with no need to insist on a utility bill. He also said that getting documents certified wasn’t physically possible where he was. He referred to a previous decision we’d issued where we’d said that firms must exercise flexibility for overseas customers where standard UK processes are impossible to meet. When Mr I asked us for an update on 7 April 2026 we explained that we were waiting for a response from ReAssure. Mr I was unhappy about that and said the ongoing delay was causing significant distress. We prompted ReAssure again. We said the matter was a priority due to Mr I’s financial situation. And we asked for a response as soon as possible or by 14 April 2026 at the latest. When we updated Mr I he explained he’d had to borrow money from his mother (who is elderly and unwell in a UK hospital) which had caused an argument. He was unable to fly home to see her as he couldn’t afford it. ReAssure has got back to us but it is having difficulties with the electricity bill and is trying to get it translated. ReAssure has said it might help if Mr I could point out where his name and address is shown on the document.

-- 4 of 7 --

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 do understand Mr I’s difficulties and I recognise the very considerable frustration that this matter has caused him, as well as the serious financial hardship he is suffering due to not being able to access his pension fund. First, I’d like to clarify our role. We’re an informal complaints handling service. We’ll look at what’s happened and what the business has or hasn’t done and come to a conclusion which we consider is fair and reasonable in all the circumstances of the case. We take into account relevant law and regulations (which here would include data protection and anti-money laundering provisions); regulators’ rules, guidance and standards (which includes the regulator’s Principles for Businesses); codes of practice; and, where appropriate, what we consider to have been good industry practice at the relevant time. As the investigator has explained, we can’t tell a business how it should operate on a daily basis. What systems, processes and procedures a business uses is a legitimate exercise of its commercial judgment. That applies to what Mr I has said about ReAssure’s use of encrypted emails which it seems caused him some difficulties. ReAssure has explained that emails are encrypted for security reasons. It’s a widely used security measure, aimed at protecting sensitive data. Unfortunately, encrypted emails can, as Mr I has found, and for a variety of reasons, sometimes end up in the recipient’s spam folder which is inconvenient and annoying. It’s also the case that different businesses will have different procedures and policies. The fact that ReAssure’s systems or procedures aren’t the same as another business’s doesn’t mean that ReAssure is at fault, even if it might feel to Mr I that ReAssure isn’t being as helpful or flexible as his other pension provider. Mr I has now returned signed and completed documentation to ReAssure. And he expects ReAssure to now process his withdrawal urgently. But ReAssure sent the risk questionnaire and other documents so that it would be in a position to deal with the withdrawal request promptly, once the ID issue had been resolved. Unfortunately, while that’s outstanding, ReAssure remains unable to process Mr I’s withdrawal request. I know Mr I feels very strongly that he’s done enough and ReAssure should simply pay him the money without any further delay. However, I don’t think it’s quite that straightforward. I’ve taken into account that Mr I lives overseas and that, as he’s told ReAssure, he’s vulnerable because of financial hardship. The regulator, the Financial Conduct Authority (FCA) has published guidance (FG21/1) which sets out the FCA’s expectations as to how firms should identify and treat vulnerable customers. One of its aims is to help ensure that such customers receive the appropriate degree of protection and experience outcomes in line with those of other customers who may not be vulnerable. But I don’t think the central outcome – that the ID evidence Mr I has been able to produce isn’t sufficient – would’ve been any different if he hadn’t been vulnerable. ReAssure’s requirements would’ve been the same and impacted vulnerable and non-vulnerable customers in the same way. Mr I’s fund value is some £31,000 and ReAssure needs to be satisfied that the money is paid to the correct person. I agree with what ReAssure has said about its requirements being more stringent when it comes to paying out the money, as opposed to simply supplying information about the policy, which is much lower risk.

-- 5 of 7 --

In considering Mr I’s request for payment, ReAssure has taken into account his situation and has made some efforts to assist him by adjusting its requirements. Given Mr I’s difficulties in getting documents certified, ReAssure is prepared to accept uncertified copy documents. ReAssure has seen Mr I’s passport (which hasn’t been certified) and the bank account details (which I think have been certified by a bank official at least). But ReAssure has requested another document (which I understand won’t need to be certified) to confirm Mr I’s address. All in all I don’t think that’s unreasonable. So, to that extent, that’s an end to the matter – I’m not upholding Mr I’s complaint on the basis that I don’t think ReAssure’s requirements are unreasonable. Further, I think the compensation ReAssure has offered for its admitted error in not notifying its correct requirements is fair and reasonable. As the investigator has explained, we don’t fine or punish businesses. Instead, we look at the impact a business’s mistake has had on the consumer. Here Mr I suffered distress, inconvenience and frustration. I think £500 is fair and reasonable and in line with the sort of award we’d make in a situation such as this – where a business’s mistake has caused considerable distress, upset and worry. I’d emphasise that the compensation is only in respect of ReAssure’s admitted error about not notifying the correct ID requirements. It doesn’t reflect any wrongdoing on ReAssure’s part in not paying out the fund to Mr I. I’ve said above that I don’t think ReAssure’s ID requirements – which it has adjusted to try to accommodate Mr I’s situation – are unreasonable. So I’m not upholding the main aspect of Mr I’s complaint and I’m unable to say that ReAssure should now pay the fund out to him immediately. ReAssure also offered to undertake a loss assessment. That was offered on a time limited basis, but things have moved on and I think ReAssure should undertake a loss assessment anyway and in line with what the investigator said in her view. Whenever Mr I’s benefits are paid, there will always have been that delay (some 88 working days) which ReAssure admits it caused by providing incorrect information about its requirements so it’s fair and reasonable that ReAssure should check that Mr I’s fund value isn’t less than it would’ve been, but for that delay. ReAssure has also tried to set things up to enable payment to be made promptly to Mr I by supplying documents, such as the risk questionnaire, which ReAssure wouldn’t normally do until the ID requirements had been met. And Mr I has completed and returned the Pension Lump Sum Application Form and provided his bank details. But the ID requirements remain outstanding so, as I’ve said, ReAssure is unable to make payment (which includes any interim payment) to Mr I. I’ve considered the decision Mr I has cited. The facts aren’t identical although there are some similarities in that the case did concern a customer who’d moved abroad and was trying to access her pension with ReAssure as a lump sum. But the complaint didn’t centre on what ID/address verification requirements might be reasonable when a customer lived overseas. So I don’t think it assists here. I anticipate that Mr I will be disappointed with my decision. I know he feels very strongly that ReAssure is unreasonably denying him access to money which is his. But for the reasons I’ve explained, I don’t agree. I’m very conscious that saying ReAssure hasn’t acted unreasonably won’t bring about a result for Mr I – he still won’t have satisfied ReAssure’s ID requirements and so he’s no closer to accessing his funds. That’s the reason why we’ve made efforts to try to assist in practical terms by exploring how it might be possible for Mr I to meet ReAssure’s ID requirements. Mr I may consider that delayed things and he wanted my decision to have been issued earlier. But I think that would’ve been in the anticipation that I’d be upholding

-- 6 of 7 --

the complaint and directing ReAssure to release his fund to Mr I immediately. But, unfortunately for Mr I, that isn’t the decision I’ve reached. As to the electricity bill, I’d draw Mr I’s attention to what ReAssure has said – that it might assist if he can confirm where his name and address is shown, although it seems ReAssure is arranging to have it translated anyway. I’d ask ReAssure to liaise with Mr I direct about any outstanding requirements. I’m however issuing my decision as Mr I has made it very clear that’s what he wants. I don’t consider that ReAssure has acted unreasonably or treated Mr I unfairly. So, on that basis, I’m unable to uphold the main aspect of his complaint. But ReAssure has accepted that it did make an error and has offered to put things right in a way which I think is fair. My final decision ReAssure UK Services Limited has made an offer. I think this offer is fair in all the circumstances. So my decision is that ReAssure UK Services Limited should pay £500 to Mr I and, when the policy proceeds are settled, carry out a loss assessment. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr I to accept or reject my decision before 11 May 2026. Lesley Stead Ombudsman

-- 7 of 7 --