Financial Ombudsman Service decision

Ascot Lloyd Limited · DRN-5907383

Investment AdviceComplaint not 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 Ms S complains about Ascot Lloyd Limited’s service fees following it acquiring her as a new client. What happened Ms S was previously a customer of Investment Solutions Wealth Management Limited (“ISWML”). In April 2024, ISWML was acquired by Ascot Lloyd Limited (“AL”) and so Ms S became a client of its. Ms S complained to AL in March 2025 as she was unhappy that she would be required to pay an initial 3% fee to receive new advice from it. She said she’d already paid an initial 3% fee to ISWML and so didn’t think it was fair and reasonable for her to have pay this again. AL considered Ms S’ complaint but didn’t uphold it. In summary, it said: • There is no initial 3% fee for clients who have been acquired through the acquisition of ISWML. • An advice fee would apply if it provided a client with new advice, regarding new products or investing new funds into an existing investment. • Additionally, if there are significant changes to an existing investment, a potential advice fee could also be incurred for that specific advice. • Servicing related activity and annual reviews are covered by the on-going advice charge which is 0.75% per year. Ms S remained unhappy with AL’s response and so she referred her complaint to this service for an independent review. One of our investigators considered the complaint and explained that AL had acted fairly. In summary, they said: • AL hasn’t charged Ms S any upfront fees as she’s not taken any advice to move her investments. • They didn’t think it was unusual for a new advisor to want to better its understanding of a client’s needs and to make new recommendations, and it’s not unreasonable for a charge to be levied for this service. • They felt AL had made its charging structure clear through its brochure. Ms S didn’t accept the investigator’s findings. In summary, she said: • She paid an upfront fee to ISWML to actively manage her investments, which included reviewing her risk profile annually and at times made recommendations to exit certain funds and reinvest the proceeds in other funds. • It’s unfair that she must now pay an initial 3% fee for this service purely because AL has since acquired ISWML. As Ms S remains unhappy, the complaint has been passed to me to decide.

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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. When AL acquired ISWML, Ms S moved over to it as a client. I understand AL sent Ms S a welcome brochure at the time explaining its charging structure. AL has provided a copy of this and it explains: “There will be an initial fee for our advice, suitability checks and implementation. This is typically 3% for funds under management. Your fees will be calculated at the report stage and disclosed to you in your meeting with your adviser. All details will be clearly laid out in your suitability report before any arrangements are made, so there are no surprises. There is also an ongoing fee to keep your arrangements administered and under periodic review. This is typically 0.75% pa of the funds we manage. Our ongoing services are optional, and you can cancel them at any time.” As such, I’m satisfied AL provided Ms S with clear information about its charges when onboarding Ms S as a new client. I understand that Ms S feels she shouldn’t have to pay AL an initial fee when she had already paid one to ISWML. AL has explained that Ms S doesn’t have to pay an initial fee if she remains invested within her existing investments and has confirmed that it isn’t charging an ongoing administration fee. As such, I’m satisfied that there has currently been any financial loss caused to Ms S for me to consider. I appreciate Ms S says she was receiving a more tailored service from ISWML and that it would, at times, make recommendations to exit certain funds and reinvest the proceeds in other funds outside of the annual reviews she had. AL has explained that Ms S’s existing investments are still managed by the investment provider and that it does not manage any individual fund in terms of having input into the make-up, buying or selling within a fund. Rather, it makes recommendations of which overall fund is most suitable to a client’s needs and requirements looking at various factors, including the fund management by a provider. I’ve not seen any evidence to support that ISWML was managing the funds Ms S is invested in and AL has provided our service with a copy of ISWML’s Service Agreement which suggests ISWML was providing a similar financial advice service to that provided by AL. This document suggests that ISWML charged Ms S an initial fee of 3% and it would charge 0.75% per annum for its ongoing advice. Regardless, I don’t think it would be fair or reasonable to expect AL to provide the same level of service, purely because it has acquired ISWML. As I’ve mentioned above, I’m satisfied AL clearly explained the service it would provide in its welcome brochure. An issue that appears to be at play in this complaint is that AL doesn’t recommend that Ms S remain invested in the funds she currently holds. Therefore, if she chooses to have a review, it would automatically look to make a recommendation to move to her into more appropriate funds. And it is that recommendation that would trigger a fee as it is new advice. I appreciate Ms S doesn’t want to have to pay the fee, however, I’m satisfied it would be fair for AL to charge this as per its charging structure.

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My final decision My final decision is that I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Ms S to accept or reject my decision before 28 April 2026. Ben Waites Ombudsman

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