Personal Pension Key Features Document

V0.2 - April 2023

The Financial Conduct Authority is a financial services regulator. It requires us, to give you this important information to help you decide whether the CIRCA5000 Personal Pension is right for you. You should read it carefully so that you understand what you are buying, and the keep it safe to refer to in future. If we make any changes, we will update this document and make it available on www.circa5000.com. Your rights as the investor on the Platform are set out in the Terms, which may be subject to change in the future.

Please read this together with the Pension Key Features Illustration, Pension Terms and Conditions and CIRCA5000’s Terms and Conditions.

Introduction

The CIRCA5000 Personal Pension provides you with a simple, tax-efficient way to invest your savings ready for retirement. You will be able to access your CIRCA5000 Personal Pension how and when suits you, but it will be subject to Government rules and regulations.

We are required to give you important information to help you to decide whether this pension (sometimes we call it the SIPP which stands for self-invested personal pension or PP which stands for personal pension) is right for you. This document will help you understand the key features of our SIPP and provide answers to common questions, so please read it carefully and keep a copy.

This key features document gives a summary of the CIRCA5000 Personal Pension. It does not include all the definitions, exclusions, terms and conditions. The full contractual terms are set out in the Trust Deed & Rules and the Terms and Conditions.

If you would like copies of these, or clarification of any of the information provided in this document, please ask CIRCA5000 by email at hi@circa5000.com or via telephone on: 0151 452 6655.

We have the right to change some of the terms and conditions. In this circumstance, we will write to you to explain the reasons for any such changes.

If you have any questions, please get in touch with us.

Aims of the CIRCA5000 Personal Pension

The pension is designed to let you:

Save for retirement in a tax-efficient and flexible way;
Build up a pension fund to give you a tax-free cash sum and income in retirement;
Take control of your pension fund investments through a wide range of investment choices;
Make decisions by yourself;
Make transfer payments from other pension arrangements;
Specify to whom you would like benefits to go to on your death.

Your commitments

Take time to read this information and any other documentation we provide to you.
Be aware that you and your adviser (if you are using one) are responsible for deciding which investments are right for you, and whether these should be amended during the life of your product.
Make sure we always have up-to-date information about you and tell us if things change - like if you move to a new house, change your bank account or email address.
Remember that you won’t ordinarily be able to take money out of your CIRCA5000 Personal Pension until you are at least 55 (rising to 57 from 6 April 2028). You should be okay with this and see investing as a long-term solution.
When you come to withdraw money from your CIRCA5000 Personal Pension, you will need to make sure you are doing so in ways that are allowed under the pension and tax rules that apply at that time.
Notify us if you are no longer entitled to tax relief on the contribution you make to this or any other pensions.
Read and adhere to the Terms and Conditions of our CIRCA5000 Personal Pension.
Pay our fees for administering the pension on your behalf.

Risk factors

The value will go up and down

The value of your CIRCA5000 Personal Pension depends on the performance of the underlying investments. The value of these investments, and therefore your pension, can go down as well as up. Past performance, projections and illustrations are not a guarantee of what your performance will be. If your investments perform badly, it’s possible you may get back less money than you put in - no retirement benefits are guaranteed.

Your retirement income could be lower than expected.

Your retirement income could be less than you expect if you reduce or stop payments, investment growth is poor or annuity rates at the time you take your benefits are lower than expected.

Fees will affect your pension value

Any fees taken will affect the value of your CIRCA5000 Personal Pension. These charges may vary from time to time, and we will notify you if this is the case. You can find more information about fees and how they are taken in the CIRCA5000 Personal Pension Terms and Conditions. You will also be given a Key Features Illustration, showing the effect of charges.

In the rare cases that we cannot pay fees from your CIRCA5000 Personal Pension due to an insufficient cash balance, we would need to sell other investments to meet these.

Different pensions have different benefits

If you transfer another pension plan to us, the pension benefits you receive could be lower than if you stayed in your existing scheme. If you are unsure on the decision to transfer a financial adviser may be able to advise you whether it’s in your best interests and make clear any benefits you may be giving up such as ‘enhanced protection’ or ‘fixed protection’.

You have a right to cancel your pension within the first 30 days. If you cancel a transfer from another provider to us, the other provider may refuse to accept the return of the transfer money

Please also refer to the section entitled ‘Can I transfer other pensions?’

Inflation can reduce the value of your money

Inflation means the cost of goods and services increasing over time. This has the effect of reducing the buying power of the money you have saved. A £10 note will still be worth £10 in five years’ time, but you might not be able to buy as much with it.

Tax charges may apply

The Government sets rules on the amount that you can save into a personal pension each tax year and receive tax relief on. This is known as the Annual Allowance. Your Annual Allowance is also dependent on how much you earn and may be less than the standard allowance.

The Government also has a rule to limit the total amount of tax advantaged cash you can hold in your personal pension overall, which is known at the Lifetime Allowance.

If you exceed the Annual Allowance or the Lifetime Allowance limits, you may need to pay tax. Please note that the tax treatment of your pension is set by HM Revenue and Customs (‘HMRC’) and may change over time.

Retirement Income

Retirement income (sometimes known as drawdown) is the act of taking benefits from your pension when you require. You should be aware that when this time comes:

If you take a large proportion of income in a short period, you may end up paying a higher rate of tax than usual
Whenever you start to take a retirement income, you will trigger annual pension limits, specifically the ‘Money Purchase Annual Allowance’ if it has not already been triggered. This will reduce the maximum contributions you can make into your pensions each year
If you take a higher than planned level of income over a long period of time, it is likely that your CIRCA5000 Personal Pension will not be enough to provide an income for as long as you may have originally wanted
If you receive means tested benefits, taking an income from a pension might mean they are reduced or stopped

Your questions answered

What is the CIRCA5000 Personal Pension?

The CIRCA5000 Personal Pension is a pension plan that allows you to save for retirement in a tax-efficient and flexible way. The benefits you can receive are subject to UK pension legislation. This includes rules about limits on contributions that can qualify for tax relief, the earliest age you can take benefits and limits on what those benefits can be without incurring tax penalties, including the amount that can be taken as tax-free cash payments.

Who can open a CIRCA5000 Personal Pension?

This product is for people who want to:

Invest in a range of assets
Make investment decisions about their pension assets themselves or with their financial adviser or investment manager

The CIRCA5000 Personal Pension is unlikely to be appropriate for people who won’t take advantage of the flexibility it offers in terms of the choice of available investments, or the way benefits are taken. You should consider speaking to a financial adviser or refer to the government’s free service at, moneyhelper.org.uk or on telephone number, 0800 144 89423 about the most suitable pension option for you.

Who will administer my CIRCA5000 Personal Pension?

Seccl Custody Limited will administer your pension in accordance with the Trust Deed and Rules. This includes the day to day running of your pension, ranging from processing contributions, transfers, investments and paying benefits, to ensuring the pension adheres to HMRC rules and regulations.

Is the CIRCA5000 Personal Pension a stakeholder pension?

No. Stakeholder pensions must meet government set standards covering payments, charges and other terms and conditions. Stakeholder pensions are generally available and might meet your needs as well as our CIRCA5000 Personal Pension

What are the Trust Deed and Rules?

The Trust Deed and Rules is the legal document that has established the Seccl Personal Pension, which is the pension scheme underlying the CIRCA5000 Personal Pension. This document also appoints trustees and the scheme operator, who is responsible for registering the scheme with HM Revenue & Customs (HMRC) to ensure the favourable tax treatment mentioned earlier is applied to the pension. The trustees of the Seccl Personal Pension are Digital Pension Trustees Limited and the operator is Seccl Custody Limited who is authorised and regulated by the Financial Conduct Authority (FCA).

Will I have a separate CIRCA5000 Personal Pension bank account?

No. Uninvested cash is held in a client money bank account, this is a pooled account so that in the event of a bank’s failure your claim will be a share of the cash held in all such accounts held at the bank.

Is this the right option for me?

This could be right for you if you:

Are willing to invest your capital over the medium to long term, understanding that you may not be able to take money out until you are at least 55 (57 from 6 April 2028)
Want to benefit from tax relief on your contributions – subject to government limits
Want access to a wide range of investments and understand and accept the associated risks
Want a way to consolidate your other pension savings

The scheme administrator, Seccl does not offer or provide any financial advice. It is strictly your decision whether to use any Seccl service or whether to invest in, and how much to invest in, our/the CIRCA5000 Personal Pension.

How do I start saving in the CIRCA5000 Personal Pension?

You can open an account online at www.circa5000.com.

Paying into the CIRCA5000 Personal Pension - What are my options?

You can choose from:

One-off payments
Regular payments
Transfer of pension benefits from other suitable pension schemes

These are payable by:

You (via bank transfer or direct debit)
Your employer (via standing order)

You can stop paying at any time or take payment holidays and restart payments later. Remember though that stopping payments, even temporarily, will reduce the possible value of your fund at retirement.

How much can I save in my CIRCA5000 Personal Pension?

There is a minimum limit of £50 for our product and there is or maximum limit on how much you can put in. There are government limits on the amount of contributions that are eligible for tax relief and you may have to pay tax if you exceed the Annual Allowance. This is explained later on this page.

All relevant UK individuals can pay, and get tax relief on, contributions up to £3,600 gross each year. Where your earnings are in excess of £3,600 you may make gross contributions of up to 100% of your earnings known as UK relevant earnings subject to a maximum amount known as the annual allowance, which is set each year by the Government. The annual allowance applies as a total limit across all of your registered pension schemes in a tax year. It covers:

Your payments;
Employer payments made on your behalf; and
Any increase in the value of retirement benefits you may earn from a defined benefit pension scheme.

If you were a member of a registered pension scheme but did not fully use your available annual allowance from the previous three years, you may be able to ‘carry forward’ that unused allowance.

The annual allowance does not include transfers from other pension arrangements and does not apply in the year of death or severe ill-health.

Any payments over the Annual Allowance will be subject to an Annual Allowance charge at a rate set by HMRC. The amount of tax charged will be your highest marginal rate of tax determined by your individual circumstances based on your income and the amount by which you have exceeded the annual allowance.

In some cases, you may be able to make larger contributions in a particular tax year. If you think you may be close to, or exceed, the Annual Allowance you should talk to a financial adviser as this is a complex area.

Employer contributions are not taxable as a benefit in kind for you and the employer will normally get tax relief on employer contributions as a business expense. Therefore, you will not normally get tax relief on employer contributions.

What are the different Annual Allowances?

Annual Allowance

Currently, the Annual Allowance is £60,000. This applies to everyone unless they are subject to the Tapered Annual Allowance.

Tapered Annual Allowance

The Tapered Annual Allowance is between £60,000 and £10,000. This applies to those earning ‘adjusted income’ in excess of £260,000 and ‘threshold income’ in excess of £200,000. The Annual Allowance is reduced by £1 for every £2 of earnings over £260,000 up to earnings of £360,000.

Money Purchase Annual Allowance

This is currently £10,000 and applies where you have started taking a retirement income flexibly.

Can I make contributions if I have ‘Enhanced’ or “Fixed’ Protection?

Protection and lifetime allowance rules are changing from 6th April 2024 this means that whether you can make contributions without losing protection will depend on when you applied for and were granted either Enhanced or Fixed protection.

Applied for either Enhanced or Fixed protection before 15th March 2023 you can make contributions without losing this protection.
Applied for either Enhanced or Fixed protection after 15th March 2023 these will be lost if a contribution is paid to the CIRCA5000 Personal Pension. This will have serious tax consequences for you as it could mean that you need to pay a Lifetime Allowance charge when you take benefits (see ‘Is my pension size limited’).

Can I transfer over other pensions?

Yes, you can. If you instruct a transfer, your existing pension provider may need to sell down your investments and transfer the cash into your CIRCA5000 Personal Pension, which would then be invested in line with the investment style you picked. Alternatively, if your existing pension provider allows, and the investments are available on our platform, you can instruct that these are re-registered to your CIRCA5000 Personal Pension without the need to sell down.

We will not accept transfers from pensions with Safeguarded Rights, (as defined in Section 48(8) of the Pensions Schemes Act 2015).

What can I invest in?

You, (or your advisers if you have them), can choose from a wide range of investments, provided that the investments chosen are allowed by HMRC. The investments acceptable to your CIRCA5000 Personal Pension are:

Investments meeting the FCA’s definition of standard and capable of being held by Seccl Custody Limited
FCA authorised or recognised collective investment schemes or a listed securities capable of being valued on a regular basis and sold within 30 days

This is a complex area and if you have any questions you should contact either (provider name) or us.

If there is anything else you would like to invest in, please contact us to see if this will be allowed.

Is my pension size limited?

Yes. The maximum you can take from all your pension arrangements is called the Lifetime Allowance, as set each year by the Government without incurring an additional tax charge. If you exceed the Lifetime Allowance, you will be subject to the Lifetime Allowance charge.

If the excess is taken as pension income, then the charge is 25%. If it is taken as a lump sum, it will be 55% of the amount above the available lifetime allowance which will be deducted from your fund and paid to HMRC when paying your benefits.

Every time you take benefits from your pension, some of these pension limits are used up. Checks against the pension limits are carried out at various points, including:

In the event of your death
Whenever you use part of the fund for tax-free cash and start income withdrawal and/or pension purchase
At age 75 (if funds are still invested in the pension)
When funds from which you have previously been drawing an income are used to purchase a pension, usually in the form of a lifetime annuity

At each of the above stages, an allowance is made for any tests that have already been carried out. Tax charges apply to any further benefits once all the pension limits are used. The tax charges are set by HMRC.

If you transfer the whole pension, it will come to an end. Any protection you have applied to HMRC for could be lost if you transfer. You should speak to your financial adviser before making a transfer.

What are the charges?

You will pay an annual CIRCA5000 Personal Pension fee, which includes all costs associated with holding the account including payments, withdrawals, trading and custody. On top of this, there are investment costs which include fund charges (taken directly by the fund provider) and market spread (the difference between the price we buy and sell investments).

To see the latest rates that will apply, please read the CIRCA5000 Personal Pension Terms and Conditions.

Charges are deducted directly from your CIRCA5000 Personal Pension. You can find a more detailed description of our chargesin our client Terms and Conditions, and on your Key Features Illustration.

What might I get back?

At the application stage, we will provide an illustration that shows what you might get back when you decide to take your benefits. These are based on assumptions that include:

Amount invested
Performance of your investments
Effect of charges
Amount of any cash lump sum you take
Amount of drawdown income you take
Annuity rate that applies at the time
Effect of tax
Your chosen retirement date.

It is important to remember that the material effect of these assumptions will only be known at the date you decide to take your benefits together with other factors such as inflation.

How will I know how my CIRCA5000 Personal Pension is doing?

You can see the value of your investments at any time by signing into your account on your CIRCA5000 mobile app.

We also provide you with a regular annual statement showing the value of your CIRCA5000 Personal Pension and what it is likely to be worth in the future. The first statement is provided within around three months after you open your account and will be put into the secure online document store.

Your statement will also show any income you have taken (if you are receiving a retirement income).

Can I transfer out my CIRCA5000 Personal Pension?

You can transfer out all or part of your pension to another registered UK pension scheme at any time. Any accounts already in drawdown will have to be transferred in full in line with pension regulations.

How can I take my benefits?

When you approach your selected retirement age, we will let you know what your options are at that time. Pension Wise, a free government service, can give you impartial information around the choices you have.

Currently the options include:

Converting your investments into retirement income by buying an annuity from an annuity provider (we do not offer or plan on offering this option)
Taking retirement income directly from investments in your account, this is known as drawdown pension
Taking a tax-free pension commencement lump sum and using the remainder of your account to either buy an annuity or take drawdown pension
Taking the whole value of your investments as cash lump sums, 25% as a pension commencement lump sum and 75% as income and taxed as such.

Note: In order to take any retirement benefits you will need to transfer out of this scheme as we do not currently have the facility to take either drawdown income or cash lump sums.

When can I take benefits?

You can usually start taking an income from your pension from age 55, rising to age 57 from 6 April 2028. You may also be able to take a cash lump sum or income earlier if you are seriously ill or suffer an illness or accident which means you cannot continue in your current occupation.

When you reach age 50, you can use Pension Wise from MoneyHelper, a free impartial government service, to help you understand what your pension income choices are and how they work. This service can be accessed at: https://www.moneyhelper.org.uk/en/pensions-and-retirement/pension-wise.

You should speak to CIRCA5000 or seek guidance from Pension Wise when you are thinking of accessing your pension income.

What happens if I die?

In the event of your death, any regular contributions being collected will stop.

The investments will remain unchanged and therefore subject to market movement until we receive any required documentation from your personal representatives that allows us to distribute any proceeds.

We will take into account any beneficiaries you nominate when we decide who to pay the benefits to and how much each person will receive.

Your beneficiaries can choose to receive the benefits as one of the following options:

As a cash lump sum
They can receive a guaranteed yearly income by transferring the benefits to buy an annuity from an annuity provider
They can receive a flexible income that they can increase or decrease by taking the benefits as retirement income by transferring to a provider that offers beneficiary drawdown.

We will write to your beneficiaries setting out the options available to them. These benefits may be taxed but this will depend on your circumstances at the time of your death. If you die before age 75, death benefits will normally be paid free of tax.

However, if you die on or after your 75th birthday benefits will be subject to tax.

In some circumstances there may be a delay in passing the benefits on to your beneficiaries due to the nature of your investments. For example, an investment may be suspended from trading.

Can I cancel my CIRCA5000 Personal Pension?

Yes, you can. We will send you a confirmation email each time you start a new contribution or make a transfer in which will include details of your right to cancel. You will have 30 days from when we issue this confirmation to cancel. The cancellation request should be sent to us by email at: hi@circa5000.com

If you start to take retirement income (also known as drawdown pension) from your CIRCA5000 Personal Pension, you will also have 30 days to change your mind. Cancellation rights only apply to the first time you utilise drawdown pension on your CIRCA5000 Personal Pension.

The amount we pay back will depend on what action has been taken in respect of your account prior to the time you cancel. If you exercise your right to cancel within 30 days from when we issue your confirmation, we will refund any cash payment in full that we have already received as part of regular direct payments you have set up.

In all cancellation cases, any deductions we make when an account is cancelled will be restricted to the following:

our own charges
charges incurred in relation to your investment choices
charges incurred for any transactions you make.

The amount we pay back will also reflect any market movement in the investments between the date the money was first applied to your account and the cancellation date. This may be less than your original investment.

If you start trading within the cancellation period you may be liable for any charges due to us and any charges levied by others.

How can I make a Complaint?

If you have a complaint, please send us an email to complaints@circa5000.com or via telephone on: 0151 452 6655. You can also make a complaint to the SIPP administrator, Seccl, by emailing SIPP@seccl.tech, contact Seccl online at www.seccl.tech or by telephone on: 01225 43520. Our lines are open Monday to Friday 09:00 to 17:00.

Your complaint will be handled by a person of appropriate competence and experience. That person will not have been directly involved in the matter which is the subject of the complaint.

We will endeavour to resolve any complaint as soon as possible.

If a final response has not been issued within four weeks of receipt of your complaint, we will write to you providing a holding response that will indicate when we will make further contact. This further contact will be within eight weeks of receipt of the complaint.

By the end of the eight weeks, we must send you either a final response or a response which explains that we are still investigating the complaint, giving reasons for the delay and likely timescales. We will also, where appropriate, provide you with details of the Financial Ombudsman Service, along with a copy of their leaflet ‘Your Complaint and the Ombudsman’ and a statement confirming that an approach can be made by you to the Financial Ombudsman Service if you are dissatisfied with the outcome and the length of time the matter has taken.

Financial Ombudsman Service

Exchange Tower

Harbour Exchange Square

London

E14 9SR

Telephone: 0800 023 4567 (call charges will vary)

Email: complaint.info@financial-ombudsman.org.uk

Website: www.financial-ombudsman.org.uk

The Pensions Ombudsman

10 South Colonnade Canary Wharf

London

E14 4PU

Telephone: 0800 917 4487 (call charges will vary)

Email: helpline@pensions-ombudman.org.uk

Website: www.pensions-ombudsman.org.uk

Is my CIRCA5000 Personal Pension safe?

Yes, your money is safe when using Seccl, as we work with global finance service providers who are regulated by the Financial Conduct Authority. As custodians, we hold your cash securely and separately from our own, which means that if we went into administration, our creditors wouldn’t have a claim to your investments.

Digital Custody Nominees Limited is the Nominee which is wholly owned and controlled subsidiary of Seccl Custody Limited, which holds the funds for our ISA, General Investment Accounts and SIPP Accounts. Up to the first £85,000 of your money invested with us can be protected by the Financial Services Compensation Scheme (FSCS) in the event of the insolvency of Seccl Custody Limited, or Digital Pension Trustees Limited. However, it’s important to understand that the FSCS doesn't cover you in the event that your investments do not perform as expected and you get back less than you originally invested. For more information visit https://www.fscs.org.uk/

What is the Financial Services Compensation Scheme (FSCS)?

The FSCS is the UK’s compensation fund of last resort for customers of authorised financial services firms. See further information at https://www.fscs.org.uk/what-we-cover/pensions/.

Seccl is authorised by the FCA so you will have access to the FSCS. In the event you suffer financial loss because of Seccl’s failure or an investment failure, the actual level of compensation you receive will depend on the basis of your claim and where the money you have with us is invested. The FSCS only pays compensation for financial loss. Compensation limits are per person per firm, and per claim category.

The FSCS may be able to pay you compensation if Seccl or any banks with whom Seccl place your money are no longer able to meet their financial obligations. If certain investments fail, you may also be eligible for compensation.

Our current banking partner is Lloyds Bank PLC, and we will inform you if this changes. For more information about how the FSCS might apply to you, please contact us or visit the FSCS website at fscs.org.uk. The FSCS’s address is 10th Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU.

How to contact CIRCA5000 or Seccl

We recommend that you contact us by emailing us at hi@circa5000.com or via telephone on: 0151 452 6655.

Please do not include any account details when you contact us by email.

CIRCA5000 Ltd is registered in England and Wales, No 11200977, which is authorised and regulated by the Financial Conduct Authority, registration number 846067. CIRCA5000 Ltd Registered Office is 3rd Floor, 86-90 Paul Street, London, EC2A 4NE.

Your administrator Seccl can be contacted by emailing SIPP@seccl.tech or via telephone number on: 01225 435200. Our lines are open Monday to Friday 09:00 to 17:00.

Please do not include any account details when you contact Seccl by email.

Seccl Technology Limited is registered in England and Wales No 10237930. Registered office 20 Manvers Street, Bath, BA1 1JW Digital Custody is a service provided by Seccl Custody Limited who are registered in England and Wales No 10430958. Registered Office 20 Manvers Street, Bath, BA1 1JW.

Seccl Custody Limited, a firm authorised and regulated by the Financial Conduct Authority, registration Number 793200, is a wholly owned subsidiary of Seccl Technology Limited. The contact address for the FCA is included in the definitions section below.