Independent Expert support for a Part VII transfer

Phoenix Life and abrdn Life and Pensions sought to streamline their strategic partnership and enhance their market-leading capabilities.

This involved a Part VII transfer to move £3 billion of unit-linked business from Phoenix Life to abrdn Life and Pensions.

The challenge 

A historical relationship and strategic partnership between the two groups meant they had a complex operating relationship. The Part VII transfer aimed to simplify and streamline operational aspects for both parties.

As an Independent Expert, we needed to work closely with both firms, and the PRA and the FCA, and to establish if the scheme would result in any material adverse impact to policyholders, including expected servicing standards.

Key criteria included: the impact on benefit expectations, benefit security, administration and servicing, and management and governance standards.

While an Independent Expert’s overriding duty is to the court, choosing the right one – with the right knowledge, experience and capacity to deliver to tight timescales – can be crucial to a successful transfer.

How we helped 

Working closely with both firms and drawing on our team of specialists, we assessed the regulatory and prudential implications of the transfer. This included broader themes such as operational readiness and resilience, capital and liquidity requirements, Treating Customers Fairly, and the Consumer Duty, among others.

We reviewed:

• impacts on fund range, structure and charges
• arrangements for property funds which both transferring and non-transferring policies were invested in
• trading implications during and after the transfer
• amendments to reinsurance arrangements and floating charges between the two insurers and external providers
• communications approach to policyholders and the ultimate beneficiaries of policies
• issues arising from non-profit business written in with-profit funds.

We presented findings in summary reports to policyholders, and produced main and supplementary reports for court use.

The results 

The transfer was sanctioned in March 2025 by the High Court, with the judge noting that the Independent Expert report was clear, detailed and comprehensible.

Close and efficient working with both firms and regulators was key to achieving a seamless experience throughout. We addressed last-minute queries from the regulators, as well as queries on new issues arising during the Part VII process. In addition, our experienced team members were available at the right time, including short notice, and operating under tight deadlines.