St. James's Place Wealth Management Plc · DRN-6172794

The complaint Mr C and Mrs H and the estate of Mr C1, their late father, complain about advice provided by St. James's Place Wealth Management Plc (“SJP”) regarding several investment bonds. Mr C and Mrs H say, among other things, that that the initial recommendations weren’t explained, they were misadvised after Mr C1’s death to start replacement bonds, the performance was poor and SJP delayed responding to the complaint. What happened Mr C and Mrs H, together with their late mother and father, have been advised by SJP in their respective capacities for many years, across a variety of products and services. The history of the bonds relating specifically to this complaint is broadly as follows. In 2010 Mr C1 and his wife Mrs C were advised to start two SJP investments bonds, each in their sole names, both committing £10,200 and written with each of their children, Mr C and Mrs H as respective second lives assured. A series of further recommendations was made to Mr C1 adding to his bond across 2010 and into 2011, with a final addition made to it in 2018. Sadly, Mrs C passed away in 2015, and I understand her bond was encashed in that same year. In 2011, another recommendation was made to surrender two existing bonds held in two discretionary loan trusts previously set up by Mr C1 and his wife in 2007, for which Mr C and Mrs H were trustees. As such, the advice was provided to them in that capacity and not to Mr C1. The combined surrender proceeds were invested into a single new SJP investment bond that was then held in Mr C1’s discretionary loan trust. Then, in 2017, following the sale of Mr C1’s property, further advice was provided to him to invest the sale proceeds into a unit trust feeder account and ISA, with the remainder split between two further SJP investment bonds, again both written with Mr C and Mrs H as second lives. These bonds were placed into two new variable discretionary trusts, again with Mr C and Mrs H as trustees for both. Sadly, Mr C1 passed away in August 2020 after which all four bonds were assigned to Mr C and Mrs H in March 2021. They were then all fully surrendered in October 2024, after Mr C had further reassigned his share of each bond to his wife for tax purposes. Mr C and Mrs H initially complained to SJP in November 2023 about the bonds. They voiced concerns with the apparent failure of the adviser to provide suitability reports for any of the advice and also the tax burden they now faced if they were to surrender the bonds. Subsequent delays in SJP’s handling of the complaint meant that no final response was issued to Mr C and Mrs H until February 2025, by which time, as noted, the bonds had all been surrendered and the matter had been referred to this service. SJP’s final response dealt with the above concerns and two additional issues that had been raised in the meantime – that the reassignment of Mr C’s shares of the bonds to his wife had

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taken too long and a failure by SJP to inform them why the investments had been transferred to a new SJP Partner. SJP didn’t uphold any part of the complaint, saying, in brief – • Suitable advice had been always provided to Mr C1 and his wife, which had considered their investment objectives and attitudes to risk. (Copies of all suitability letters were provided along with the final response). • Writing all the bonds with a second life assured was suitable as it facilitated continuity of the investments. • The assignments in May 2021 were completed for continuity and required no independent suitability assessments. • All relevant clients were written to and informed of the change of SJP partner in 2025, which was instigated to ensure that a continuing good service would be provided. One of our investigators also considered Mr C and Mrs H’s concerns, but he too didn’t think it should be upheld. He said, in brief – • SJP had provided suitability letters in relation to the advice given. While he appreciated that Mr C and Mrs H had questioned the authenticity of the documents, he wasn’t persuaded SJP had provided misleading documentation. • The letters showed the investments recommended to Mr C1 aligned with his objectives, his attitude to risk, and were affordable. As the bonds were generally arranged specifically for him, Mr C and Mrs H’s circumstances weren’t considered. • Our service usually dismissed complaints regarding solely performance, and there was no evidence of negligence. Investment performance was variable and good performance couldn’t be guaranteed. • There didn’t appear to have been any new investments started after Mr C1’s passing. It seemed there may have been some confusion between the assignments in 2021 and a surrender or replacement of the bonds. Mr C and Mrs H didn’t accept the investigator’s view. They voiced several continuing issues including – • Evidential concerns with the suitability letters provided by SJP. • The advice provided to them following Mr C1’s passing regarding encashment or replacement of the bonds. • Inconsistencies regarding the status of the trusts. • A failure to assess whether the advice had met Mr C1’s objectives. • Replacement bonds incurring higher charges, surrender penalties and additional tax complexity. • The complaint not being about performance. The investigator wasn’t persuaded to change his view, so as no agreement could be reached, the matter was referred to me to review. 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. The purpose of this decision is to set out my findings on what’s fair and reasonable, and explain my reasons for reaching those findings, not to offer a point-by-point response to

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every submission made by the parties to the complaint. And so, while I’ve considered all the submissions by both parties, I’ve focussed here on the points I believe to be key to my decision on what’s fair and reasonable in the circumstances. Turning first to the advice provided to Mr C1, and also to Mr C and Mrs H in their capacities as trustees, I’ve seen nothing that persuades me that the adviser acted incorrectly or provided advice that was unsuitable. At each point of providing advice (of which, as noted, there were many) he appears to have appropriately considered relevant circumstances, objectives, attitudes to risk and affordability and to have involved the parties receiving the advice in discussions about the recommendations. Further, all the advice was fully documented in suitability letters issued at the time. I note what’s been said about the possibility that the documents SJP has now provided not being contemporaneous – that they may have been created only after the event, in response to the complaint. This assertion appears to be based in part at least on the ‘metadata’ associated with the files produced by SJP, where the creation dates appear to have been in 2025. However, this isn’t unusual, as this data will often refer to the date on which the new copy of a document was created, rather than when the original document was created. I’m satisfied that the suitability letters provided by SJP are contemporaneous and are the versions of the letters that I think, on balance, were more likely than not provided at the time of the advice. As I’ve said, some advice was provided specifically to Mr C and Mrs H in their capacities as trustees of the discretionary loan trusts that Mr C1 and his wife set up in 2007, to hold the bonds that were surrendered and reinvested in 2011. Again, the letters sent to them, care of their parents’ address, appear to set out suitable recommendations made after detailed discussion of objectives. On that occasion they invested solely in SJP’s Gilt fund, despite a warning about a lack of diversification, because of concerns about market volatility. I think this type of documented interaction supports there having been a robust consideration of matters by the adviser. Regarding the trust situation, I note that Mr C and Mrs H have also disputed to some degree both the evidence for and appropriateness of the trust arrangements. But, again, I’m satisfied the documentation supports both. The suitability letter of November 2011 set out the details relating to the two trusts set up earlier in 2007, and I’ve seen copies of the deeds relating to the trusts started in 2017, signed by Mr C and Mrs H, which held the bonds recommended after Mr C1 sold his property. Another key point Mr C and Mrs H have raised relates to the apparent setting up of new products following Mr C1’s passing in 2020 and the costs and complexities created by this. But I’ve seen no evidence of that happening. As I noted in setting out the background to the complaint, the four bonds that had been recommended in 2010, 2011, and 2017 weren’t changed or replaced after Mrs C1’s passing (other than some fund switches within them in May 2021). Rather, they were assigned to Mr C and Mrs H who became the new owners. The bonds continued as they were after Mr C1’s passing because Mr C and Mrs H had been added as lives assured. This is common practice, done to avoid early repayment penalties and enforced surrenders, to enable ongoing management of the investments, as was the case here. Mr C and Mrs H were able to maintain the investments and control when and how they were surrendered, as demonstrated by Mr C choosing to reassign his shares of the bonds to his wife to manage the tax situation. (I note concerns have been raised regarding the administration of that process, but I haven’t considered them here as they would need to first be raised with the relevant part of SJP).

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The later bonds, as opposed to those started in 2010 and 2011, were subject to ongoing advice charges, but as Mrs H has confirmed that they met regularly with the adviser and annual reviews took place, I see no basis on which the complaint should be upheld in this respect. In closing, while I recognise Mr C and Mrs H will be disappointed that I’ve reached the same conclusions as the investigator, having carefully considered all the evidence, I find no basis on which to uphold the complaint My final decision For the reasons given, my final decision is that I don’t uphold the complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr C and Mrs H and the estate of Mr C1 to accept or reject my decision before 28 April 2026. James Harris Ombudsman

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