Financial Ombudsman Service decision

St. James's Place Wealth Management Plc · DRN-6237005

ISAComplaint upheld
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The verbatim text of this Financial Ombudsman Service decision. Sourced directly from the FOS published decisions register. Consumer names are reduced to initials by FOS at point of publication. Not an AI summary, not a paraphrase — every word below is the original decision.

Full decision

The complaint Mr L complains about the service he has received from St. James's Place Wealth Management Plc (‘SJPWM’) in respect of his ISA. In short, he says that the investments weren’t in line with his attitude to risk, the business hasn’t rebalanced the ISA correctly taking into account his changing circumstances and he hasn’t received annual reviews and ongoing service which he believes should have been provided. What happened Mr L opened an ISA on SJPWM’s advice in February 2006. He initially invested £1,500. Three additional lump sum deposits of £1,000 were made by cheque in April and September 2006 (two in September). And from June 2006, Mr L began making regular deposits of £500 per month into the ISA. The ISA provider was St James’s Place Unit Trust Group Limited - part of the same wider group as SJPWM but a separate entity. In December 2006, Mr L opened a separate unit trust account, again on the advice of SJPWM, and invested £2,000. Again, the provider of this account was St James’s Place Unit Trust Group Limited. In May 2008 the regular contributions to Mr L’s ISA were increased from £500 to £600 per month. The contributions continued until 2025. I understand the unit trust account was closed around 2014. In January 2019, SJPWM emailed Mr L about arranging a meeting to discuss his ISA and investments. Mr L responded saying he couldn’t meet with the adviser at that time. SJPWM contacted Mr L again in January 2020 to arrange a meeting. And I understand a conversation took place on 23 January 2020. SJPWM followed this up with an email several days later confirming what had been discussed - that Mr L was happy with his existing investments. Mr L made a lump sum contribution of £10,000 into his ISA in February 2022. SJPWM had further discussions and meetings with Mr L on 16 February 2022 and in November 2023 and May 2024. During the discussion in 2022, SJPWM recorded that Mr L wanted to maximise his ISA contributions in the next couple of years and was happy with the ISA performance. SJPWM commented that topping up his ISA made sense. The 2023 and 2024 meetings concluded that no changes to the ISA and Mr L’s investments were necessary. Mr L complained to SJPWM in February 2025. He was concerned with the advice he’d received, in particular the high level of equity content of his ISA investments, and that there had been no rebalancing of the portfolio for a significant amount of time despite him now nearing retirement and his needs having changed. He said SJPWM had failed to provide ongoing advice and services in relation to his ISA, since it was taken out. Mr L also indicated he was unhappy with the level of fees he’d incurred, which he didn’t think were made clear

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and he believed these should be refunded. In April 2025, Mr L transferred his ISA to a different provider and closed the account that SJPWM had previously recommended. SJPWM didn’t agree that the advice or investments recommended were unsuitable for Mr L, saying it believed these were appropriate based on his circumstances and attitude to risk at the time of the recommendation to take out the ISA. And, while performance had been disappointing at times, it said the investment, net of charges, had grown over 50% since it was taken out. SJPWM said that the charges and costs had been set out to Mr L before he agreed to the advice. And it said it hadn’t been required or obliged to provide ongoing advice / services or regular reviews until 2022, when Mr L had made a lump sum top up to his ISA, which it had recommended. It said it believed reviews had been conducted in 2022, 2023 and 2024. But it acknowledged one had not been carried out in 2025, before Mr L transferred his ISA to a different provider, even though it should have been. So, SJPWM said it would refund the ongoing adviser fees which related to the missed review in 2025 plus interest at 8%. And it also agreed to pay Mr L £150 for the trouble and upset caused. Mr L did not accept the offer made and asked our service to consider the complaint. One of our Investigator’s looked into the matter. Our Investigator didn’t think the initial advice was unsuitable and they agreed, based on the available evidence, that SJPWM didn’t have an obligation to provide ongoing reviews until February 2022. They acknowledged that SJPWM had held discussions with Mr L in 2022, 2023 and 2024. But they didn’t think that the evidence supported an adequate service (review of the ongoing suitability of his investments) had been provided. And the Investigator also thought, if an adequate review of Mr L’s circumstances and attitude to risk has taken place in 2022, SJPWM would likely have recommended fund switches to bring his investments more in line with his medium attitude to risk at the time (the investments he held being higher medium risk). So, the Investigator recommended that SJPWM run a calculation of what returns Mr L would have received between the meeting in 2022 and him surrendering the ISA had his funds been invested on a medium risk basis (using a fair comparator index). And if he would have been better off compared to what did happen (the returns received from the existing investments over that time), they said SJPWM should compensate Mr L. They also said that this calculation should account for Mr L having not received the correct level of ongoing service in 2022, 2023 and 2024, in addition to 2025, which SJPWM had already acknowledged. They also thought the offer of £150 for distress caused was appropriate and should be honoured. SJPWM said it accepted the Investigator’s opinion and would pay the redress as suggested. Mr L did not accept the Investigator’s opinion. He has made a significant number of additional submissions which I’ve considered. I won’t recap them all here but in short, he didn’t agree that the recommendations were suitable, including mentioning that SJPWM hadn’t done sufficient due diligence on some of the investment managers. He disagreed with additional lump sum payments into the ISA in 2006 being considered as ‘execution-only’. Mr L also didn’t agree that SJPWM was not required to provide ongoing services before 2022. And he thought the recommended redress didn’t address the investment loss incurred shortly prior to him moving ISA provider, which he felt was caused because of SJPWM’s delays in responding to the complaint.

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As an agreement could not 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. It is worth noting that we are not a regulator – that is the role of the Financial Conduct Authority (‘FCA’). It is not our role to fine, sanction or punish a financial business. Rather our role is to decide what is fair and reasonable in the individual circumstances of a complaint. When considering the matter, I’ve taken into account relevant law and regulations, regulator’s rules, guidance and standards and codes of practice - many of these are found in the FCA’s handbook under the Principles for Businesses (‘PRIN’) and the Conduct of Business Sourcebook (‘COBS’). I’ve also thought about what I consider to have been good industry practice at the time. It is also true that the relevant regulatory rules and standards have changed overtime. So, when considering SJPWM’s actions, it is the rules in place at the relevant times that I’ve considered. This is because it would be unfair to apply updated and strengthened rules and regulations retrospectively to actions that occurred before those rules came into effect. Where the evidence is incomplete, inconclusive or contradictory, I reach my conclusions on the balance of probabilities – that is, what I think is more likely than not to have happened based on the available evidence and the wider surrounding circumstances. I want to be clear that this complaint and my decision is looking at the actions of SJPWM, the party which originally recommended the ISA to Mr L. Again, while part of the same group, this is a separate entity to the ISA provider St James’s Place Unit Trust Group Limited. I’d also like to reassure the parties that I’ve carefully considered all of the arguments made and the evidence provided. I’ve been provided a significant amount of information relating to the events complained about, as well as detailed opinions, particularly from Mr L, about what has happened. I understand Mr L feels strongly about the matter and has set out an extensive list of points he would like answered. I acknowledged I haven’t repeated the information to the same level of detail that he has and I’ve only summarised the events that took place. But if I don’t comment on or refer to everything that has been said this isn’t meant as a discourtesy or because I haven’t thought about it. I know this approach may come as a disappointment to Mr L, given his strength of feeling and the number of questions he believes need to be answered. But my decision addresses what I think are the key points in deciding the complaint, bearing in mind our role as an informal dispute resolution service and my remit of deciding what a fair and reasonable outcome is. Our Investigator found that SJPWM hadn’t provided ongoing services, in the depth and manner it should have done, from February 2022 onwards. And that, had this been done, it is likely Mr L’s ISA would have been invested differently between 16 February 2022 (when it undertook a review) and when it was transferred elsewhere (in April 2025). SJPWM accepted the Investigator’s opinion on these points. I think the Investigator’s opinion on this appears fair and the proposed manner for resolving this is, in my view, reasonable. So, I don’t need to comment on or discuss these points further beyond addressing that Mr L has said that the delay in SJPWM responding to his complaint meant that he incurred losses, when the value of his investments fell shortly prior to the transfer of his ISA, which he thinks have not been addressed by this redress. Mr L has said that his investments fell in value while he was waiting for an answer to his complaint and before he transferred his ISA elsewhere. And has referred to being trapped in

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those investments while awaiting SJPWM’s response. But, notwithstanding that Mr L was free to transfer at any time and had evidently identified concerns a couple of months earlier, I’m satisfied the methodology of redress suggested by the Investigator already appropriately addresses any fluctuation in investment value prior to the transfer (and while the complaint was ongoing) as the calculation covers the period in question. As, in my view, what happened from February 2022 onwards has been fairly addressed by the Investigator, my decision will largely focus on the other points of complaint that remain in dispute. Again, these are essentially the suitability of the original recommendation from SJPWM (including how to invest the ISA funds and whether the fees and costs were made clear) and if SJPWM was required to provide ongoing services prior to February 2022 (and if it was, the subsequent impact of it not doing so). The suitability of the original advice SJPWM has provided a copy of a fact-find completed with Mr L shortly prior to the recommendation to take out the ISA. This recorded that Mr L was 42, had no significant debts, his income exceeded his expenditure each month and he had several thousand pounds in an emergency fund. It was recorded that Mr L had invested previously and was now looking to invest an initial lump sum (£1,500), followed by additional contributions at a later date, in a tax efficient manner to achieve growth over the medium to long term. The fact-find said that the intention for the monies invested was to potentially help fund a career change in the future. Mr L has referred to his objectives for these funds having changed at a later point to providing income in his retirement. But I’m satisfied these were the objectives discussed at the time of the advice. The fact-find said that Mr L had a ‘medium to high’ attitude to risk (‘ATR’). Based on his recorded circumstances, I don’t think there was anything that ought to have suggested to SJPWM this was inaccurate or that he didn’t have the capacity to accept risk at this level. And I’m satisfied that this assessment of Mr L’s ATR was based on the discussions at the time and that SJPWM was entitled to rely upon this. The recommendation letter SJPWM sent to Mr L repeated that his objectives were to invest for growth over the medium to long term and that he didn’t expect to need to access the funds for several years. And that his ATR was medium to high. And there is nothing that indicates Mr L disagreed with this at the time of the advice. Based on the information recorded about Mr L’s circumstances and objectives, I think the recommendation that he take out an ISA was suitable. It was a tax efficient way of saving and investing and gave him the opportunity to achieve growth. The key features document for the ISA, published by the provider, set out that there were 11 different investment fund options available. The recommendation noted that Mr L had indicated he wanted to invest all of the initial £1,500 lump sum into one fund and that this particular fund was considered to be lower risk than Mr L’s ATR. But it was also noted that if Mr L did later make further contributions to his ISA, he would select funds with a higher risk profile. So again, based on the information available at that time, I’m satisfied that the fund was suitable for Mr L. As I’ve noted there were three further lump sum payments into the ISA in 2006. Letters sent to Mr L by his adviser at SJPWM, acknowledging receipt of his cheque and confirming this had been sent on to the provider, all state “I can confirm that no advice was sought or given in relation to this application”. Mr L disputes that these were execution only transactions and says that these were based on the initial advice.

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As I said, the initial recommendation referred to Mr L likely making further contributions to the ISA at a later date and that when he did so, the risk profile of these subsequent investments he selected would be higher. And the effect would be that the overall risk profile of the ISA would be closer to his ‘medium to high’ ATR. And I think these deposits are likely what that advice referred to – so the adviser understood that these were going to be made. At the same time though, the advice referred to Mr L selecting how this money would be invested, when he came to make those deposits. Which supports that, when the transactions were made, they likely were carried out on an execution only basis. Ultimately though, I don’t think this makes a difference to the suitability of the advice SJPWM provided to take out the ISA. The later deposits were likely discussed at the initial meeting and may indeed have been informed by the initial advice when Mr L came to make them. But, based on what I’ve seen, after they were made the spread of investments was still consistent with Mr L’s recorded ATR at the time. So, even if the additional deposits and investment decisions were based on discussions Mr L had with the adviser, I can’t see that the adviser recommended investments that were unsuitable. Taking all of this into account, I’m satisfied that the initial advice was suitable. The recommendation referred to key facts about SJPWM’s services and a term of business, as well as an ISA key features booklet and product illustration, having been provided to Mr L. I’m satisfied on balance that these documents likely were given to him and the declaration in the ISA application form Mr L signed confirmed he’d received and read the ISA key features. The ISA key features document, in the further information section, explains that the initial charge on all investments is 5% and the annual management charge (‘AMC’) 1.5%. It also explains that the “difference between the Bid and Offer priced (including the initial charge) is currently 5%”. So, this confirms that there is an initial charge levied by the provider for investing and that this is included in the difference between bid and offer prices. The ISA illustration also contained a section about how charges would affect the investment. This included the explanation “When you buy units for your ISA, the maximum price that you pay is based on the notional cost of acquiring the capital assets of the Trust, divided by the number of units in issue to which the Manager adds an initial charge”. So, this again set out that there would be an initial charge from the provider for investing. It then explained that “The Offer price is the price per unit at which you could acquire those capital assets and the Bid price is the price per unit at which the underlying assets could be realised”. It then went on to reiterate “The difference between the Bid price and Offer price, known as the spread, is normally 5%... and incorporates the initial charge”. So, this also explained that the initial charge is incorporated in the ‘spread’, and that this was being charged at 5%. The section about charges also explained that there was an AMC of 1.5%, as well as fund specific charges. There was no separate charge noted as being payable by Mr L to SJPWM. I’m satisfied therefore, in addition to the advice being suitable, that Mr L was provided with information about the charging structure for the recommended product. Mr L has argued that this was ‘opaque’ and unclear and that an adviser at SJPWM had agreed with him about this. But I think the information was sufficiently clear, setting out the initial charge and AMC in percentage terms, for him to be able to make an informed decision about whether to agree to proceed with the advice. Mr L has referred to later FCA investigations, which concluded in 2019, into a fund manager that had a business association with the ISA provider, St James’s Place Unit Trust Group Limited, and who had some involvement with some of the funds his money was invested in. And he has suggested that he believes this means the initial advice from SJPWM was

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unsuitable. But I don’t agree. For the reasons I’ve explained, I think SJPWM’s recommendations were suitable at the time of the advice. The issues that have since come to light were not, in my view, something that SJPWM could reasonably have known about at the time. And so, I can’t fairly say that this retrospective knowledge makes the recommendations unsuitable. Ongoing services and when SJPWM was required to provide these The initial advice took place prior to the Retail Distribution Review (‘RDR’) in 2012. Prior to the RDR, it was common for the advising or arranging agent that helped establish investments, to be paid “trail commission”. This tended to be payable for the lifetime of the investment. Trail commission was paid by the product provider, in this case St James’s Place Unit Trust Group Limited, rather than the consumer. It was normally funded by the annual management fees the provider charged. The ISA illustration confirms that the adviser would receive renumeration, and set out estimates of what this would be, including that the ongoing payments each year would be 0.25% of the ‘Bid price’. And the ISA key features document repeated this and that this would be paid by the provider, St James’s Place Unit Trust Group Limited. Both documents also confirmed though that this remuneration would be funded from the deductions listed in the illustration. Again, this consisted of the AMC, initial charges and product charges with no separate and distinct payment being made by Mr L to SJPWM on an ongoing basis – he was not paying a specific, separate charge of 0.25%. So, I’m satisfied that, at the point of the initial agreement, SJPWM was being paid trail commission by St James’s Place Unit Trust Group Limited and that this was funded from the charges the provider applied, not a separate fee paid by Mr L. Trail commission was usually payable simply for having sold or arranged the investment and receiving it didn’t require the advising business to provide ongoing advice or services. Unless that is the advising firm had contractually agreed, separately, to provide specific ongoing services. The illustration and ISA key features, which came from the product provider rather than SJPWM, indicate the provider would pay the commission “for arranging this plan and providing ongoing servicing”. But there was no further description of what ‘ongoing servicing’ would look like. And there is nothing in the information from SJPWM itself that says it agreed to provide ongoing services or what these would look like. The recommendation letter makes no reference to ongoing services having been agreed or that SJPWM would provide these – indeed it left it with Mr L to contact the adviser in the future if he wanted other advice, with no commitment for SJPWM to contact Mr L regularly. Nor did SJPWM’s key facts or terms of business documents commit it to provide ongoing services. So, I can’t fairly say, based on the available information, that SJPWM contractually agreed to provide an ongoing service at the time of the initial advice in 2006. One of the things RDR aimed to achieve was to increase the transparency and fairness of adviser fees and the services provided in return for those fees. That’s because, it wasn’t always clear what service was being provided for the fees being charged. As here, terms like ‘ongoing servicing’ (albeit it wasn’t SJPWM that said this) often weren’t clearly defined. But the RDR marked a change for future contracts and didn’t require businesses to go back to existing policies and clarify the terms. So, it wouldn’t be fair to now define the term ‘ongoing servicing’ (which is quite broad) and hold SJPWM to account for it. I’m also satisfied that SJPWM didn’t agree, and wasn’t contractually obligated, to provide ongoing advice on the ISA following the separate advice later in 2006 to take out a unit trust

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because again the documents didn’t include a commitment to do so. Mr L has said that SJPWM ought to have assessed the ongoing suitability of his ISA in May 2008, and regularly after that, when he increased his regular contributions from £500 per month to £600 per month. But I don’t agree that there was a requirement for SJPWM to do more or provide ongoing suitability reviews at that time. Notwithstanding that the acknowledgment the product provider sent in 2008 confirmed that this increase had been instructed online (and so there isn’t any indication that SJPWM had input into that decision), the regulations by that point had not changed. So, even if SJPWM had advised Mr L at that stage, which for the avoidance of doubt I don’t think it did, there were no requirements to provide a specific ongoing service. And there doesn’t appear to have been any new contractual documents completed at that point, committing SJPWM to do something more. After the RDR, trail commission was not allowed on new products sold. But it could continue to be paid under existing agreements where it was already payable, without creating an automatic obligation on the adviser to take any further action. So, the RDR being enacted didn’t impose a requirement on SJPWM to provide Mr L with a specific ongoing service, as the agreement pre-dated RDR. There were also no changes to Mr L’s ISA between the implementation of RDR and him making a lump sum deposit in 2022, which was discussed with SJPWM, that, in my view, gave rise to a requirement for SJPWM to provide an ongoing service (and again no such service had been defined). Mr L has referred to changes to COBS in 2018, arising from Markets in Financial Instruments Directive II (‘MiFID II’) which said that investment firms providing a periodic suitability assessment shall review, in order to enhance the service, the suitability of the recommendations given at least annually. But this change related to setting expectations around the frequency of regular reviews, where that service was already being provided or was taken out after that point. SJPWM wasn’t though providing a periodic suitability assessment because, as I’ve explained, it hadn’t agreed and wasn’t required to do so at that point. So, I don’t agree that these changes to regulation created an obligation on SJPWM in respect of this agreement. In 2022, when Mr L made a new lump sum contribution to his ISA, SJPWM began charging a separate fee for ongoing advice – a change to the arrangement to that point in which only trail commission had been paid. I’m satisfied that from that point, it was required to provide regular reviews of the ongoing suitability of Mr L’s ISA. But prior to that, for the reasons explained, I don’t think SJPWM was obliged to provide an ongoing service or regular reviews. And indeed, until that point, Mr L had not directly paid SJPWM for an ongoing service. He paid AMC’s and other charges to the ISA provider (St James’s Place Unit Trust Group Limited). And the provider has in turn paid trail commission to SJPWM, funded from those charges. But he wasn’t paying SJPWM for a contractually agreed ongoing service until that point. And it’s worth noting that I’ve seen nothing to indicate that the AMC and other charges for the ISA would not still have been payable at the same level, even had the provider not been paying trail commission, meaning Mr L would always have paid the same amount. In summary therefore, I’m satisfied that SJPWM was not required to provide ongoing services or undertake ongoing assessments of the suitability of Mr L’s ISA and how it was invested prior to February 2022. With this in mind, I’m aware Mr L has raised several points about the suitability and performance of his investments after the ISA was opened, up until the point SJPWM began

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providing ongoing services. This included similar arguments to those I’ve already mentioned about one of the fund managers. But, notwithstanding that SJPWM is not the product provider so has no say in investment decisions and fund performance is not something we generally uphold a complaint about, as SJPWM wasn’t required to assess the ongoing suitability of his investments prior to February 2022, I can’t fairly hold it responsible for any of those issues, prior to that point. Although it wasn’t required to provide Mr L with ongoing services or reviews, prior to 2022, I can see that SJPWM did contact him in 2019 to attempt to arrange a meeting. And a conversation appears to have taken place a year later, in early 2020. The reason for this appears to have been because the previous adviser was no longer working for SJPWM and a new adviser was attempting to make contact. Again though, SJPWM wasn’t required at that point to conduct periodic suitability reviews or provide any other ongoing services. So, I can’t say that SJPWM did anything wrong by accepting what Mr L told it at that time – that he was satisfied with his investments. Summary For the reasons I’ve explained, I’m satisfied that the advice SJPWM gave Mr L in February 2006 to take out an ISA was suitable. And, although it appears to have received trail commission from that point, SJPWM was not required to provide Mr L with ongoing services or advice about the ongoing suitability of his products or investments prior to February 2022. SJPWM has agreed with our Investigator’s opinion about what happened from February 2022 until Mr L transferred his investments to a new provider – the reviews that did take place didn’t go far enough and SJPWM should have recommended changes to how Mr L’s ISA was invested at the point they met on 16 February 2022, which likely would have been accepted. And I think this opinion is fair and reasonable and that SJPWM should pay Mr L redress to address this. And I think the methodology already suggested by the Investigator, which again SJPWM has accepted, is a fair and reasonable way to do this. So, I uphold this complaint in part and will set out below how SJPWM should address this. Putting things right To summarise, I consider that my aim should be to put Mr L as close to the position he would probably now be in if SJPWM had advised him as it ought to have on 16 February 2022 and if he hadn’t been charged for ongoing services that were not provided as they ought to have been between February 2022 and the ISA being closed in April 2025. I take the view that Mr L would have invested differently. It is not possible to say precisely what he would have done differently. But I am satisfied that what I have set out below, which is in line with what our Investigator recommended, is fair and reasonable given Mr L's circumstances and objectives. The compensation set out should, if possible, be paid into Mr L’s ISA. But I understand this is held with a different business and making a lump sum payment of redress into it could conflict with Mr L’s annual ISA allowance. So, if this is not possible, the redress amount should be paid to Mr L as a lump sum. What must SJPWM do? To compensate Mr L fairly, SJPWM must: • Compare the performance of Mr L's investment with that of the benchmark shown

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below and pay the difference between the fair value and the actual value of the investments. If the actual value is greater than the fair value, no compensation is payable. • SJPWM should also add any interest set out below to the compensation payable. • SJPWM must repay the adviser’s fees charged for ongoing services due between February 2022 and April 2025. Had these fees not been deducted from Mr L’s ISA, the funds (fees) would have benefitted from growth. So, when refunded, these amounts should be adjusted for growth had the fees remained in the ISA (invested in the same way to the rest of the balance), from the date the fees were deducted to the point the ISA was transferred. Interest at a rate of 8% should then be paid on the total adjusted amount from the date the ISA was transferred to the date of settlement. • If the above performance comparison shows a gain so that no compensation is payable, the difference between the actual value and the fair value can be offset against the refund of fees with interest. Income tax may be payable on any interest awarded. Portfolio name Status Benchmark From ("start date") To ("end date") Additional interest SJP ISA No longer in force FTSE UK Private Investors Income Total Return Index 16 February 2022 – date of review Date ISA with SJP was transferred and ceased to be held – April 2025 Pay 8% simple interest per year on any loss from the end date to the date of settlement. Actual value This means the actual amount paid from the investment at the end date. Fair value This is what the investment would have been worth at the end date had it produced a return using the benchmark. Any additional sum paid into the investment should be added to the fair value calculation from the point in time when it was actually paid in. Any withdrawal from the ISA should be deducted from the fair value calculation at the point it was actually paid so it ceases to accrue any return in the calculation from that point on. If there is a large number of regular payments, to keep calculations simpler, I’ll accept if SJPWM totals all those payments and deducts that figure at the end to determine the fair value instead of deducting periodically. Why is this remedy suitable? I have decided on this method of compensation because:

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• Mr L wanted Capital growth and was willing to accept some investment risk. • The FTSE UK Private Investors Income Total Return index (prior to 1 March 2017, the FTSE WMA Stock Market Income total return index) is a mix of diversified indices representing different asset classes, mainly UK equities and government bonds. It would be a fair measure for someone who was prepared to take some risk to get a higher return. • Although it is called income index, the mix and diversification provided within the index is close enough to allow me to use it as a reasonable measure of comparison given Mr L's circumstances and risk attitude. SJPWM should provide details of the calculation to Mr L in a clear simple format. SJPWM must pay the compensation within 28 calendar days of the date on which we tell it Mr L my final decision. If SJPWM fails to pay the compensation by this date, it should pay 8% simple interest per year on the loss, for the period following the deadline to the date of settlement. SJPWM should also separately pay Mr L the £150 it previously offered for any distress caused. My final decision For the reasons I’ve explained, I uphold this complaint in part. To put things right St. James's Place Wealth Management Plc should compensate Mr L in line with the putting things right section of my decision. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr L to accept or reject my decision before 27 April 2026. Ben Stoker Ombudsman

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