Quilter Financial Services Limited · DRN-6069656

The complaint Mr N with the help of a professional representative has complained that Quilter Financial Services Limited (“Quilter”) did not review his investment portfolio correctly or in time despite him paying regular ongoing adviser charges (“OACs”) for this service. What happened In May 2015 Mr N received financial advice from Quilter regarding his investments. Quilter produced a suitability letter dated 22 May 2015 which set out its recommendations. The suitability letter also set out details about the ongoing review service Mr N had requested, the cost of which (0.5% annually) would be met by way of a deduction from Mr N’s investment funds under management by Quilter. The suitability letter also detailed that the review would typically comprise of the following services: • An assessment and review of investment performance and markets relative to your specific investments as well as a wider economic review. • A review and appraisal of prevailing interest rates and annuity rate movements as may be applicable to your circumstances at your time. • A summary of the impact of any legislative or statutory changes that might impact on your retirement strategy, for example, changes in taxation law or State pension benefits. • An update and appraisal of your financial and personal situation, needs, circumstances and objectives. • A review of your attitude to risk and volatility linked specifically to the performance of your pension funds, to ensure continued appropriateness. This will help to ensure that your risk tolerance continues to match the investment fund(s) being used. The suitability letter set out that the frequency of meetings would be at least annually. And it explained how Mr N could cancel the service if he no longer required it. Mr N, through his representative, complained to Quilter about the lack of annual reviews in a letter dated 16 September 2024. Quilter didn’t provide its final response letter within the correct timescales and so the complaint was referred to this Service on 25 March 2025. Mr N’s representative added to the complaint concerns about Quilter’s complaint handling, specifically that Quilter had failed to answer the complaint within the required eight weeks. Quilter issued its final response letter on 30 April 2025. It said that part of the complaint had been made too late under the Dispute Resolution Rules (“DISP”), as set out in the Financial Conduct Authority’s (“FCA”) Handbook, under which this Service operates. It felt that the complaint about the ongoing service prior to 2018 had been made too late. And in respect of the ongoing service from 2018 onwards it didn’t uphold the complaint and provided information confirming that the reviews had been carried out each year to date. Mr N was unhappy with this response and so it was assessed by one of our investigators. He felt that the issue of the time bar objection fell away because he was satisfied that the

-- 1 of 3 --

annual reviews had been carried out from inception of Mr N’s investment in 2015. He was also satisfied that these reviews continued each year up to the point Mr N raised his complaint in September 2024. Mr N’s representative didn’t agree with the investigator’s findings. It felt that on the basis the OACs were paid in advance leading up to completion on the month of each annual review, any delay in the review being provided meant that Mr N had paid extra for the reviews. The representative accepted that some reviews were provided earlier as well as later and that it would be unbalanced to only consider late reviews. So, it proposed that the most fair and reasonable approach would be to take an overall view that after commencing with the ongoing reviews service in May 2015 Quilter had most recently reviewed the ninth review in the ninth year in September 2024, four months later than the start in May 2015. It therefore contended that Mr N be refunded for the overall four-month delay in reaching this point with the reviews so he had not paid extra for those reviews. The investigator wasn’t persuaded to change his initial outcome. So, as no agreement could be reached the complaint has been passed to me to decide. 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’ve taken into account relevant: law and regulations; regulatory rules; guidance and standards; codes of practice; and (where appropriate) what I consider to have been good industry practice at the relevant time. Where the evidence is incomplete or inconclusive, I’ve reached my decision based on the balance of probabilities – in other words, on what I think is more likely than not to have happened given the available evidence and wider circumstances. Firstly, in relation to the time bar objection raised by Quilter. I agree with the investigator that this point falls away because I am satisfied that the annual reviews were carried out correctly and as required from the inception of Mr N’s investments. Turning now to the issue of the reviews, from the information that has been provided to me I am satisfied that Mr N received the annual reviews each year starting from 2016, which was twelve months after he started his investments with Quilter (as expected). I have seen the letters that were produced following the review meetings, and provided to Mr N, and these clearly indicate a review meeting had taken place and that detailed discussions were had with Mr N on each occasion concerning his personal and financial circumstances along with his needs, objectives and attitude to risk. These letters are dated: • 25 April 2016 • 20 January 2017 • 15 January 2018 • 1 February 2019 • 22 April 2020 • 19 May 2021 • 27 May 2022 • 4 August 2023 • 23 September 2024

-- 2 of 3 --

I therefore don’t think there can be any doubt that the annual reviews did take place each year as required and Mr N was a part of these discussions. I am also satisfied that each year Mr N’s circumstances and objectives were updated. Mr N’s circumstances were changing most years due to illness, unfortunately, and these details along with his changing needs and objectives were recorded in detail. So, I am satisfied that reviews were also carried out correctly in terms of its content and what they covered and that full detailed reviews took place. I know that Mr N’s representative has argued that the reviews were not carried out at exactly the correct time each year and that because Mr N was paying in advance for them he has effectively paid extra charges. However, I don’t agree. It is quite normal for annual reviews to not take place at the exact same time each year. In my view, if they are broadly taking place once a year this is sufficient and I view this as Quilter fulfilling its contractual obligations to Mr N. Overall, I am satisfied that Mr N received all the annual reviews from the outset of his investments that he was paying for and had agreed to under his contract with Quilter. And I am satisfied that the review meetings covered the correct and relevant details. I therefore don’t think Quilter did anything wrong in its dealings with Mr N. In terms of the additional complaint points the representative has raised about Quilter’s complaint handling, it is disappointing to see that Quilter wasn’t able to issue its final answer to Mr N within the correct timescales. However, it was made clear to Mr N and his representative that he could refer the complaint to this Service when that eight-week period was up even if Quilter hadn’t provided its answer, which is what he did. So, I don’t agree that this matter has caused Mr N any distress or inconvenience. My final decision For the reasons set out above my final decision is that I don’t uphold this complaint and I make no award. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr N to accept or reject my decision before 16 April 2026. Ayshea Khan Ombudsman

-- 3 of 3 --