Legal and General Assurance Society Limited · DRN-6262327

The complaint Mr H complains that Legal and General Assurance Society Limited (‘L&G’) mis-sold, and has mismanaged, a Fixed Term Retirement Plan (‘FTRP’) he has and that he’s suffered financial loss as a result. What happened Mr H took out a FTRP with L&G in December 2020. It was noted, amongst other things, in the application form Mr H signed for the FTRP that: • Applicants should read the Key Features and Terms and Conditions of the contract before purchasing the FTRP and confirmed they had been provided with these documents. • The applicant agreed to be bound by the Rules of the Scheme and the Terms and Conditions of the FTRP. • Mr H wanted a guaranteed minimum payment period of ten years. • Around £82,000 was to be transferred to L&G. • The financial adviser/intermediary was Firm R and no advice had been given to Mr H about the sale of the product. We’ve been provided with a copy of the Terms and Conditions for the FTRP and these noted, amongst other things, that: “2.2 Income Payments We’ll pay your Income Payments to you in instalments from the Start Date until the earliest of the following: • The date your Plan Term ends. • The date of your death. • The date you leave the Plan... … 2.3 Maturity Amount If you survive to the end of the Plan Term, we’ll pay your Maturity Amount (if any) shown in the Policy Schedule…. … 4.1 Eligibility to cash in, transfer or make withdrawals If you have chosen to have a Guaranteed Minimum Payment Period that is the same as the Plan Term then you have the option to: • Cash in or transfer – cash in or transfer the whole of your Plan and have the value paid direct to you or a Registered Pension Scheme or Qualifying Recognised Overseas Pension Scheme.

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• Withdrawal – you can take a maximum of three withdrawals from your Maturity Amount during the term of the Plan. Your regular Income Payments will remain unaffected. … If you cash in your Plan, we’ll send you a payment representing the cash in value, your Plan will end immediately and no further payments will be made. This payment will be subject to income tax at your marginal rate. … 4.3 Calculation of the cash in, transfer value or withdrawal We will calculate the cash in or transfer value based on the date you request a quote. To calculate the value of your Plan we will add up any remaining Income Payments and Maturity Amount due and give them a value, based on the Underlying Assets and interest rates at the time. (Underlying Assets is defined as “Assets such as gilts and bonds purchased by Legal & General. We use the returns from these assets to help pay the income on our Cash-Out Retirement Plans”) The calculation reduces future Income Payments and Maturity Amount based on the rates currently available on the Underlying Assets. The returns on the Underlying Assets are calculated in the same way that we do for customers who are taking out new Plans. We calculate the reduction in this way to ensure that a fair rate is given to customers who are starting a new Plan, customers who remain within the Plan until the end of their Plan Term and customers who are leaving their Plan early. Your cash in value or transfer value will always be less than the amount you’d get if we continued to pay your Income Payments and Maturity Amount. 4.3.1 Withdrawal Calculation Making a withdrawal is calculated in the same way as cashing in your Plan as described in 4.3 (excluding Income Payments), but only applies to the amount being withdrawn from the Maturity Amount. Your remaining Maturity Amount will always be reduced by more than the withdrawal amount. We will tell you what your remaining Maturity Amount is. Once we have calculated the value, we will then deduct the administration expenses and dealing costs. The administration expenses cover: • Our costs of issuing cash in, transfer and withdrawal quotes The dealing costs cover: • Our costs of processing cash in, transfer and withdrawal claims • The difference between the buying and selling prices of the Underlying Assets. If you request to withdraw the entire or remaining Maturity Amount we will deduct the administration charge and dealing costs from the final maturity value we will pay…” We’ve been provided with a copy of the FTRP Key Features document. This explains, amongst other things, that:

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The plan may be suitable for you if: … You do not want the value of your pension pot to go up and down depending on investment performance, and you want to know exactly how much you will receive back and when. … What are the charges for the plan? We take account of our charges when we calculate how much income we’ll pay you and your maturity value. This includes our costs in providing your plan to you. For plans with a shorter term, this means the overall return may be less than you paid in. There are no further charges for you to pay unless you decide to transfer your plan, cash it in or make a withdrawal. … Can I get my money out if my circumstances change? This depends on the options you choose. If you choose a guaranteed minimum payment period that runs to the end of the plan term…then you will have the following options: • Cash in or transfer – cash in or transfer the whole of your plan and have the value paid direct to you or a registered pension scheme. • Withdrawal – take a withdrawal from your maturity value during the term of the plan. Your regular income payments will remain unaffected. Cashing in or transferring the whole of your plan You can ask us for a cash in or transfer value at any time during the term of your plan. We’ll calculate these by giving a value to the future income payments and maturity value due to you and deducting our administration and dealing costs. This value will be affected by the underlying assets and interest rates at the time which will go up and down. This means that the cash in or transfer value will always be less than the total amount due in income payments and the maturity value. The earlier in your plan term you choose to do this, the lower the value is likely to be. If you choose to cash in, we’ll deduct any income tax and pay you the money. If you’re transferring, we’ll pay the money direct to the pension scheme you choose. Withdrawing money from your plan You can choose to make up to three withdrawals at any time during the term of the plan, subject to a minimum withdrawal of £5,000 each time. Choosing to make a withdrawal won’t have any impact on your regular income payments as we will deduct the withdrawal amount, administration and dealing costs from the maturity value only.

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When you ask for a withdrawal, we’ll calculate the impact this has on your maturity value. The value of the underlying assets and interest rates at the time will affect this calculation. We’ll also deduct our administration and dealing costs. This means that your maturity value will always be reduced by more than the withdrawal amount. Taking a withdrawal early in your plan term is likely to reduce your maturity value more than taking a withdrawal later.” The Key Features document also includes the following case study: In respect of a withdrawal request, L&G wrote to Mr H on 28 October 2022 and it was explained, amongst other things, that if a gross withdrawal of £6,200 was taken then the remaining maturity value of the FTRP would be £23,201.79. It was also explained that a maximum of three withdrawals were permitted during the lifetime of the plan. And that a £50 administration fee would be applicable and this would be deducted from Mr H’s remaining maturity value. L&G wrote to Mr H on 2 November 2022 and confirmed it had processed Mr H’s request to make a withdrawal from his FTRP and that it would pay him £4,960. Further, that the remaining maturity balance was £23,201.79.

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In respect of a withdrawal request, L&G wrote to Mr H on 1 August 2023 and it was explained, amongst other things, that if a gross withdrawal of £10,000 was taken then the remaining maturity value of the FTRP would be £8,851.08. It was also explained that a £50 administration fee would be applicable and this would be deducted from Mr H’s remaining maturity value. L&G wrote to Mr H on 14 August 2023, L&G said it had processed Mr H’s request to make a withdrawal from his FTRP and that it would pay him £8,038.80 on 16 August 2023. Further, that the remaining maturity balance was £8,851.08. Mr H emailed L&G on 29 August 2023 and noted, amongst other things, that: • It was clear his investment hadn’t been managed correctly from the outset and this had cost him over £8,000. • His investment had dropped by over 25%, which showed his investment wasn’t being monitored. L&G wrote to Mr H on 25 October 2023 and explained, amongst other things, that: • On 27 June 2023, Mr H had contacted it about a partial withdrawal of £10,000 from his FTRP. L&G tried to call Mr H on 6 July 2023 but couldn’t get an answer and it had then sent Mr H an email about the withdrawal. • On 11 July 2023, Mr H called to chase his request for a withdrawal. • On 25 July 2023, Mr H called chasing documents for the withdrawal and was told this would be treated as a priority to be processed that day. • On 26 July 2023, it had received a risk questionnaire from Mr H. • On 1 August 2023, Mr H called as he had received a quotation with the final figures and he was unhappy that his maturity value would decrease to about £8,000. Mr H wanted a full breakdown of how the withdrawal had affected his plan’s maturity value. • It received Mr H’s acceptance for the withdrawal on 2 August 2023. • Mr H called it on 11 August 2023 as he still hadn’t received his payment. L&G had explained to Mr H the reason for the reduction of the maturity value and had discussed the tax deductions. • On 14 August 2023, the withdrawal payment was issued to Mr H. • There had been a delay in paying Mr H the partial withdrawal amount on his FTRP and it had arranged for £250 to be paid to Mr H. Mr H emailed L&G on 13 November 2023 and said, amongst other things, he would be requesting that L&G investigate the mismanagement of his plan from the outset. L&G emailed Mr H on 25 November 2023 and said, amongst other things, that: • It didn’t agree his plan had been mismanaged. • Mr H bought his FTRP in December 2020. It was set up to run for ten years with Mr H being paid a gross annual income of £3,709.44. • The maturity value at the start of the plan was £32,727.99. This figure was based on Mr H holding the plan for the full term and not taking any withdrawals from it. • In November 2022, Mr H took a withdrawal of £6,000 gross. Before Mr H took the withdrawal it wrote to Mr H to say his maturity value would reduce to £23,201.79 and Mr H agreed to proceed with the withdrawal. • In August 2023, Mr H chose to take a further withdrawal of £10,000 gross. Before Mr H took the withdrawal it wrote to Mr H to say his maturity value would reduce to £8,851.08 and Mr H agreed to proceed with the withdrawal. • On page 9 of the Key Features of the FTRP it’s explained that:

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“When you ask for a withdrawal, we’ll calculate the impact this has on your maturity value. The value of the underlying assets and interest rates at the time will affect this calculation. We’ll also deduct our administration and dealing costs. This means that your maturity value will always be reduced by more than the withdrawal amount. Taking a withdrawal early in your plan term is likely to reduce your maturity value more than taking a withdrawal later.” • There was also an example in the Key Features document that showed how this would work. • As Mr H had taken two withdrawals in the first three years of his plan, this had significantly reduced the maturity value. Mr H emailed L&G on 29 November 2023 and said, amongst other things, that: • L&G couldn’t just say costs had been incurred. • The plan had been mis-sold and mismanaged. • He wanted the balance of his plan to be paid to him. • L&G needed to “prove the figures to [him] as there is no way a investment will go down to nearly nothing despite withdrawals.” Mr H emailed L&G on 1 December 2023 and said, amongst other things, that it had to provide him with investment figures. L&G replied to Mr H and said it was sorry he disagreed with its previous response, but it didn’t agree the plan had been mis-sold. L&G explained that it hadn’t provided any advice, and Mr H had purchased the FTRP through a broker. L&G wrote to Mr H on 4 January 2024 and said it had processed his request to fully withdraw his maturity value. L&G said it would pay him £5,145.22 net in respect of this on 7 January 2024. Mr H emailed L&G on 15 January 2024 and noted, amongst other things, that: • He was disgusted with a surrender valuation he had received from L&G for his FTRP. • He originally invested around £88,300 with L&G on the 21 December 2020. He then took a tax-free cash sum of around £22,075. This left a sum of £66,225.87, which provided a monthly gross income of £309.12. • If he had decided to invest his monies in another way he would have received an income of £551.87 gross monthly. • His FTRP investment would have provided a maturity value of £32,727.99 after ten years, but he was able to make up to three withdrawals during the term and he had withdrawn a total of £22,583.02 across three withdrawals. • This would leave a total pot of £43,643, so he can’t understand why his surrender value is only £22,020. This means there is a shortfall of around £21,000 from the original investment of £66,225. • His investment had been mismanaged and he wanted to know what L&G was going to do about the £21,000. L&G emailed Mr H on 25 January 2024 and noted, amongst other things: • From the monies it had received from Mr H’s previous pension provider, L&G had paid Mr H £22,075.28 tax-free cash. The remaining £66,225.87 was used to purchase a FTRP.

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• In exchange for £66,225.87, it agreed to pay Mr H an income of £3,709.44 gross per year for ten years and a maturity value of £32,727.99. • Mr H’s withdrawals and the impact they had on the maturity value was as follows: • Taking the first withdrawal as an example, although Mr H withdrew £6,200 L&G needed to work out the impact of this on his maturity value. A calculation was made to see what that £6,200 would be worth at the end of his policy term. That calculation worked out the £6,200 would be worth £9,526.20 if it had been left to grow until the policy matured in 2030. This £9,526.20 was then deducted from the original maturity value, leaving a new maturity value of £23,201.79. • The same process was applied to Mr H’s second withdrawal of £10,000, whereas with his final withdrawal Mr H chose to take the remainder of the maturity value in full. • The Key Features document explains: “You can ask us for a cash in or transfer value at any time during the term of your plan. We’ll calculate these by giving a value to the future income payments and maturity value due to you and deducting our administration and dealing costs. This value will be affected by the underlying assets and interest rates at the time which will go up and down. This means that the cash in or transfer value will always be less than the total amount due in income payments and the maturity value. The earlier in your plan term you choose to do this, the lower the value is likely to be.” • As of 18 January 2024, Mr H had a full seven years’ income payments remaining for his plan. The value of his future income payments was £25,966.08, (7 * £3,709.44). • The amount of money that was (then) currently held to pay £309.12 gross monthly over the next seven years was calculated to be £22,020.34 and this amount was the surrender value. • It didn’t agree it had mismanaged Mr H’s policy. • Its calculations are made using an industry-wide recognised formula and based on the underlying assets and interest rates at the time of withdrawal. • It had delayed the payment of Mr H’s remaining maturity value following his withdrawal request by around a month. It had arranged for £300 to be paid to Mr H’s bank account for the inconvenience this had caused. It had also arranged for an interest payment of £54.32 gross to be paid net to Mr H. Mr H emailed L&G on 25 January 2024 and noted, amongst other things, that he didn’t accept its response and he needed a more detailed explanation, including about interest rates and fees charged over the previous three years. L&G emailed Mr H a letter dated 16 February 2024 in which it was noted, amongst other things that:

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• The surrender values are calculated by working out the present value of Mr H’s outstanding future income payments. • The surrender value would always be less than the amount he would get if it continued to pay his income payments and any maturity amount due, as these assets would otherwise remain invested and continue to earn returns to support the future payments. • For the surrender value, the calculation reduces future income payments based on the rates available on the underlying assets at the time the surrender value is calculated. It calculates it in this way to ensure that a fair rate is given to customers. • The main reason Mr H had lost value from his plan was because he had elected to take partial and full withdrawals during a period when interest rates were much higher than when he took out the plan. • When interest rates were positive (greater than zero), then the further into the future the payments are the lower the present value/surrender value would be. • Higher interest rates would further reduce the present value associated with future payments. • In December 2020, when Mr H took out the plan, the annual interest rate for a ten- year gilt was around 0.2%. Since then, interest rates have risen sharply and have varied quite a lot. • The rates on the underlying assets L&G uses for the FTRP have changed in a similar way. • It was setting out the formula it used to work out the maturity value, and also the formula it used to work out how much a withdrawal of the present value would impact the maturity value. L&G emailed Mr H a letter dated 21 February 2024, this repeated much of the information from L&G’s 16 February 2024 letter but it also noted, amongst other things, that: • It was setting out its calculation of deduction from maturity value for each withdrawal Mr H actually made. This included the £50 administration fee each time a withdrawal was made. • It was also setting out how the net surrender value it had quoted in January 2024 was arrived at. As he wasn’t satisfied with L&G’s response, Mr H referred his complaint to this Service. Mr H has noted, amongst other things, that: • L&G is refusing to acknowledge his FTRP was mis-sold and mis-managed from inception. • L&G has sent him various letters but he doesn’t trust what it’s said as being accurate and he requires compensation for the policy being mis-managed. • The monies in his plan weren’t invested correctly and his investment was mismanaged from day one, as a result he’s lost thousands of pounds. His monies should have been invested in a far safer place. • At no time was he told where his monies were invested. L&G has told us, amongst other things, that: • It didn’t provide Mr H with any advice and his application was received from a broker, Firm R.

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One of our investigators reviewed Mr H’s complaint, they concluded there was no evidence to suggest his plan was mismanaged or that L&G had advised him to take out the plan. The investigator noted that L&G had already redressed Mr H for service issues and delays. The investigator didn’t consider L&G had treated Mr H unfairly and they didn’t recommend any redress be paid. Mr H wasn’t in agreement with the investigator’s findings and following that assessment Mr H has noted, amongst other things, that: • The onus was on L&G to ensure it invested his monies in a safe manner. • The plan was opened during the pandemic and the Financial Conduct Authority (‘FCA’) made it clear to financial institutions that they had to make sure investments were safe for customers. • L&G didn’t invest customers’ investments in safe places and interest rates should have been more widely checked. • L&G should have made sure that his investment was safe. • He had withdrawn monies but “if the investments had been put in higher and safer investments [his] withdrawals would not have affected [his] investment”. • At no time did L&G inform him what the costs were to make withdrawals and it’s clear L&G’s costs were more than they should have been. • L&G owe him thousands of pounds for mismanaging the account and not investing his monies in a “safe area where interest was higher”. Following the investigator’s assessment, L&G has noted that: • The FTRP is held within L&G’s wider annuity portfolio supported by a diversified portfolio of corporate bonds, government bonds (gilts), and direct investments. Details about the underlying assets of its annuity portfolio are published on its website as part of the financial tables released with its half-year and full-year results. • Because the FTRP invests in a mixture of corporate bonds and other credit assets rather than relying solely on government bonds, the overall interest rate generated is typically higher than gilt yields alone. • While the index doesn’t represent the specific assets held in the FTRP, the iBoxx £ Corporates 5–10 index is a widely used benchmark for GBP denominated corporate bonds and provides a useful indication of how credit asset yields in the wider market have moved. When Mr H took out the FTRP in December 2020, the annual yield on this index was around 1.3%. Since then, rates rose sharply and fluctuated significantly – reaching around 6.2% in October 2022 and August 2023, before moderating to around 5.0% in December 2023. • The interest rates of 5.33%, 5.00%, and 4.66% used in the respective withdrawal calculations for Mr H in 2022 and 2023 reflect the rate of return it assumed on the underlying assets over the period from each withdrawal date to the plan’s maturity. These rates were (and continue to be) calculated in the same way as interest rates applied to new business in line with the Terms and Conditions of the FTRP. This ensures L&G’s customers are receiving a fair value when redeeming early. As agreement couldn’t be reached the complaint was referred to me for review. Having reviewed the evidence, I previously issued a jurisdiction decision in which I explained why I was satisfied this Service is able to consider all aspects of this complaint.

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What I’ve decided – and why I remain satisfied this complaint is one we can consider for the reasons I’ve previously explained at length to the parties in the decision I issued on 2 December 2025, and I’ve not set out my findings on our jurisdiction to consider the complaint in full again here. I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. When considering what’s fair and reasonable in the circumstances, I need to take account of relevant law and regulations, regulator’s rules, guidance and standards, codes of practice and, where appropriate, what I consider to have been good industry practice at the relevant time. The parties to this complaint have provided detailed submissions to support their position and I’m grateful to them for doing so. I’ve considered these submissions in their entirety. However, I trust that they won’t take the fact that my final decision focuses on what I consider to be the central issues as a discourtesy. To be clear, the purpose of this decision isn’t to comment on every individual point or question the parties have made, rather it’s to set out my findings and reasons for reaching them. Where the evidence is incomplete, inconclusive, or contradictory, I reach my decision on the balance of probabilities – in other words, what I consider is more likely than not to have happened in light of the available evidence and the wider circumstances. FTRP being mis-sold Regarding the sale of the plan, in the application form for the FTRP the details given for the financial adviser/intermediary are those of Firm R. It’s also recorded Firm R, while acting as the financial adviser/intermediary, didn’t advise Mr H on the sale of the product. L&G isn’t responsible for anything Firm R did or didn’t advise on, or for Firm R arranging the FTRP for Mr H. If Mr H is unhappy about anything Firm R did or didn’t do then Mr H would need to raise any concerns he has with Firm R in the first instance. However, I’m satisfied from the contemporaneous documentation that L&G didn’t advise Mr H on the policy before he took it out and I’m not in agreement with Mr H that L&G mis-sold him the policy. L&G was responsible for the clarity of information it provided about the FTRP, for example in the Terms and Conditions and Key Features documents for the FTRP. But I think the information in those documents was clear, fair and not misleading – and I’m not persuaded the FTRP was mis-sold on this basis either. FTRP being mismanaged In January 2024, Mr H said to L&G that his FTRP investment would have provided a maturity value of £32,727.99 after ten years, but he was able to make up to three withdrawals during the term and he had withdrawn a total of £22,583.02 across three withdrawals. Mr H says this would leave a total pot of £43,643 (from the original sum of £66,225.87), so he can’t understand why a quoted surrender value was only for £22,020 and that this means there is a shortfall of around £21,000 from the original investment. Mr H has also noted in submissions to this Service that he expects “£20,000 or more” due to L&G having mismanaged his funds. It looks like Mr H might not have allowed for the regular annual £3,709.44 gross payments he had received prior to January 2024 in his January 2024 calculation. Although I recognise, even allowing for those sums, there is still a

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difference between the £66,225.87 figure and the combined value of the total withdrawals Mr H had received up to January 2024 plus the quoted surrender value. The main issue with Mr H’s calculation is that L&G never undertook to pay Mr H £66,225.87 (or more) if he received monies (other than the regular £3,709.44 gross payments) back from his plan before the end of the ten-year term. That’s not the way the FTRP works, and I think this was clear from the Key Features and/or Terms and Conditions documents. Rather, in consideration for the £66,225.87 purchase price, L&G agreed to pay Mr H an income of £3,709.44 gross per year for ten years and a maturity value of £32,727.99. However, the maturity value of £32,727.99 after ten years was only guaranteed if Mr H didn’t take any ad-hoc withdrawals before the end of the ten-year term. In other words, if L&G had the use of all of the monies until the end of the term for investment it would guarantee Mr H a maturity value of £32,727.99 (in addition to the regular £3,709.44 gross payments). But if Mr H took any ad-hoc withdrawals (and up to three were permitted on the plan) then the maturity value would be recalculated and it would always be reduced by more than the sum actually being withdrawn. This is because where ad-hoc withdrawals were taken then L&G no longer had the use of the monies being withdrawn. And the monies being withdrawn were monies that would otherwise have remained invested and continued to earn returns for L&G so as to support the future payments L&G had guaranteed to make if no withdrawals were made. Accordingly, where an ad-hoc withdrawal was taken then that withdrawal would be given a calculated value based on the underlying assets and interest rates at the time. This calculated value was, in effect, the future value of the sum actually being withdrawn as at the end of the ten-year FTRP term (based on the annualised interest rate available on the underlying assets held at the time of the calculation). And the calculated sum, plus any dealing costs and administration fees (the £50 administration fee), would then be deducted from the existing pre-withdrawal maturity value to arrive at a new maturity value. L&G has explained that the FTRP sits within its wider annuity portfolio, and details about the kind of assets that are held in its annuity portfolio are published on its website. I think the wording in the FTRP Terms and Conditions is broad in respect of the assets L&G could invest in. And, overall, having carefully considered all of the evidence we’ve been provided, I’m not satisfied L&G has invested the FTRP monies into assets that it wasn’t entitled to under the terms of the product. Regarding the regular income payments and the maturity value; it was explained in the Key Features document (which Mr H acknowledged having received by way of signing the FTRP application form) that, “We take account of our charges when we calculate how much income we’ll pay you and your maturity value. This includes our costs in providing your plan to you… There are no further charges for you to pay unless you decide to transfer your plan, cash it in or make a withdrawal.” So, the maturity value of £32,727.99 (assuming no withdrawals during the plan) plus income of £3,709.44 gross per year for ten years, which L&G and Mr H agreed to at outset, were already inclusive of charges. Further charges would only apply if Mr H decided to transfer or cash in his FTRP or if he made an ad-hoc withdrawal. And I think the explanation about all of this in the Key Features Document the case was clear, fair and not misleading. It was also explained in the Key Features document that:

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“When you ask for a withdrawal, we’ll calculate the impact this has on your maturity value. The value of the underlying assets and interest rates at the time will affect this calculation. We’ll also deduct our administration and dealing costs. This means that your maturity value will always be reduced by more than the withdrawal amount. Taking a withdrawal early in your plan term is likely to reduce your maturity value more than taking a withdrawal later.” Again, I think the explanation that this was the case was clear, fair and not misleading. So, I don’t think it should have come as a surprise when Mr H’s maturity value was reduced by more than the sum being withdrawn on each occasion an ad-hoc withdrawal was taken. It’s my understanding that, in addition to what was explained about “administration and dealing costs” in the Key Features document, the L&G withdrawal forms explained a £50 administration fee was applicable for ad-hoc withdrawals and would be deducted from the remaining Maturity Value. But, even if I’m wrong about this it was, in any eventuality, explained in the correspondence L&G sent Mr H on 28 October 2022 that if a gross withdrawal of £6,200 was taken then the remaining maturity value of the FTRP would be £23,201.79 – and that a £50 administration fee would be deducted from Mr H’s remaining maturity value. Further, it was also explained in the correspondence L&G sent Mr H on 1 August 2023 that if a gross withdrawal of £10,000 was taken then the remaining maturity value of the FTRP would be £8,851.08 – and that a £50 administration fee would be applicable and would be deducted from Mr H’s remaining maturity value. We’ve not been provided with a contemporaneous illustration for the withdrawal of £6,383.02 that was paid to Mr H on 8 January 2024. But I have seen that L&G emailed Mr H on 6 December 2023 explaining it was attaching paperwork for the withdrawal and that Mr H then replied to L&G on the same date explaining he was returning a risk questionnaire and was awaiting the next set of documents. Further, that Mr H then emailed L&G again on 12 December 2023, referencing L&G’s comments about its system being down and explaining that he was attaching the risk questionnaire he had previously sent it on 6 December 2023. Mr H also said he required the rest of the paperwork or L&G would receive “paperwork for a CCJ” including in respect of the “£8851.0”. Mr H also later emailed L&G on 3 January 2024 attaching an acceptance form and stating that “I require to know how much longer I will have to wait for this sum of £6383.02 less tax at 20%”. As such I’m satisfied, on the balance of probabilities, that Mr H was made aware (and prior to him completing all necessary paperwork for the January 2024 withdrawal) that the remaining maturity value of £8,851.08, if taken as a withdrawal at that time, would result in a gross payment of £6,383.02. I also think it’s more likely than not, much as was the case in the October 2022 and 1 August 2023 paperwork, that it would have been explained in the paperwork for the January 2024 withdrawal that there would be a £50 administration fee. So, overall, I’m satisfied that L&G explained clearly to Mr H, at the relevant times, what the impact on his maturity value would be (including charges) if he took each withdrawal, that Mr H was aware (or ought reasonably to have been aware) of what L&G had told him about this, and that Mr H then opted to proceed with the withdrawals. I also think the information L&G provided to Mr H about this was clear, fair and not misleading. Regarding the calculation of any residual maturity value where ad-hoc withdrawals were taken, it was explained in the Terms and Conditions that: “4.3 Calculation of the cash in, transfer value or withdrawal …

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To calculate the value of your Plan we will add up any remaining Income Payments and Maturity Amount due and give them a value, based on the Underlying Assets and interest rates at the time. The calculation reduces future Income Payments and Maturity Amount based on the rates currently available on the Underlying Assets. The returns on the Underlying Assets are calculated in the same way that we do for customers who are taking out new Plans. We calculate the reduction in this way to ensure that a fair rate is given to customers who are starting a new Plan, customers who remain within the Plan until the end of their Plan Term and customers who are leaving their Plan early. Your cash in value or transfer value will always be less than the amount you’d get if we continued to pay your Income Payments and Maturity Amount. 4.3.1 Withdrawal Calculation Making a withdrawal is calculated in the same way as cashing in your Plan as described in 4.3 (excluding Income Payments), but only applies to the amount being withdrawn from the Maturity Amount. Your remaining Maturity Amount will always be reduced by more than the withdrawal amount. We will tell you what your remaining Maturity Amount is.” And in the Key Features document it was explained that: “When you ask for a withdrawal, we’ll calculate the impact this has on your maturity value. The value of the underlying assets and interest rates at the time will affect this calculation. We’ll also deduct our administration and dealing costs. This value will be affected by the underlying assets and interest rates at the time which will go up and down.” L&G has provided detailed explanations, for example in the email it sent Mr H on 21 February 2024, about the respective calculations it performed both for the withdrawals Mr H took and also for a surrender valuation quotation it provided to Mr H. L&G has explained, amongst other things, the formulas used and what the annualised interest rate available on the underlying assets at the time of its calculation were. I’ve reviewed the contents of the calculations L&G set out in its 21 February 2024 email. I’m not persuaded that the calculations are incorrect. And I don’t think the methodology L&G applied for calculating the future value (at the end of the ten-year term) for the ad-hoc withdrawals, so as to make the appropriate deduction to the remaining maturity value, was unfair or unreasonable. I also don’t think the calculation methodology was inconsistent with how L&G had explained it would go about calculating the impact of withdrawals on the maturity value in the FTRP Terms and Conditions and Key Features documents. Regarding the annualised interest rate available on the underlying assets at the time of the calculation for each withdrawal; mindful of, amongst other things, the prevailing Bank of England base interest rate at the time of the withdrawals, gilt yields at the time of the withdrawals and the type of assets L&G was actually investing in – L&G’s calculated annualised interest rate for the underlying assets at the time of each withdrawal calculation also doesn’t given me cause for concern. So, L&G’s figures don’t appear obviously incorrect or unreasonable to me. And I think the same is also true of the methodology and figures used for the surrender valuation quotation L&G provided to Mr H.

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So, regarding Mr H’s complaint that the FTRP has been mismanaged; I’ve carefully considered what L&G has done, along with the Terms and Conditions and Key Features for the FTRP – which Mr H acknowledged having received by way of signing the FTRP application form in December 2020. And I’m not in agreement with Mr H that the FTRP has been mismanaged. I think it’s been managed in a manner that accords with the Terms and Conditions and Key Features for the FTRP. I also think that where withdrawals have been made from the FTRP, that the updated maturity values have been calculated in a manner that isn’t outwith what’s described in the Terms and Conditions. Tax I can see our investigator mentioned to the parties in his assessment that Mr H had previously corresponded with L&G about income tax deductions. The investigator explained that the tax applied to each income payment is determined by codes HM Revenue & Customs provide. The investigator also explained that if Mr H is concerned too much tax has been paid on his withdrawals, then Mr H would need to contact HMRC to discuss this. I’m in agreement with what the investigator said on this issue and I’m not satisfied L&G has done anything wrong in respect of this. Delay in the withdrawal payment that was paid to Mr H in August 2023 On 27 June 2023, Mr H contacted L&G about making a partial withdrawal from his FTRP. L&G then tried to call Mr H on 6 July 2023 but couldn’t get an answer, so it sent him an email. Then, on 11 July 2023, Mr H called L&G and chased it regarding his request for a withdrawal. As I understand it, documents Mr H needed for the withdrawal still hadn’t been sent to him and, on 25 July 2023, Mr H called L&G and chased it again. It appears that during that call L&G told Mr H that his request would be treated as a priority. And it appears Mr H did then receive some documents later that day and he had a further telephone conversation with L&G on 25 July 2023. Following this, on 26 July 2023, Mr H returned a risk questionnaire L&G had sent him. It appears Mr H then had a phone call with L&G on 31 July 2023 and further information, including a valuation, was then sent to him by L&G. Following this, a withdrawal request form was needed to proceed with the withdrawal. Mr H had a further conversation with L&G on 1 August 2023 and I can see L&G then received the withdrawal request form from Mr H on 2 August 2023. Mr H then chased L&G for the withdrawal payment on 11 August 2023 and the withdrawal payment was subsequently made to Mr H on 14 August 2023. I do think there were some periods of unnecessary delay in this process which were caused by L&G, most prominently the delay between the phone call on 11 July 2023 and documentation not being sent to Mr H until 25 July 2023 (and only then after Mr H had called L&G to chase it for a second time). I also think it took longer than I would have expected for the payment to be made to Mr H on 14 August 2023 after he had returned the withdrawal request form on 2 August 2023. Mr H has noted that he will not accept compensation of less than £2,000 in respect of this delay. I’ve thought carefully about this and I accept the delay did have an impact on Mr H and that it caused him some inconvenience. However, having regard to this and also to the extent of the delay/the sum concerned, I don’t think an award of more than £250 in total is appropriate for the loss of the use of the monies during the delay and the distress and

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inconvenience the delay caused. I can see L&G has said it previously paid Mr H £250 compensation for its failings in respect of the August 2023 withdrawal. I think a total of £250 compensation is fair compensation for this issue. Accordingly, the amount L&G has already paid Mr H for this delay is in line with the type of award I would otherwise have made and I’m not making any further award in respect of this issue. Delay in the withdrawal payment that was paid to Mr H in January 2024 As I understand it, Mr H emailed L&G’s complaints team on 25 November 2023 asking to make a withdrawal, and this request was then forwarded on by L&G to its payments team on 29 November 2023. L&G then attempted to process the withdrawal on 6 December 2023 but encountered a technical issue with its system. L&G has said that issue wasn’t resolved until 28 December 2023 and a withdrawal letter was then issued to Mr H. Following this, Mr H was paid £6,383.02 on 8 January 2024. L&G apologised for the delay and said it had arranged for £300 to be paid to Mr H’s bank account for the inconvenience caused. L&G also arranged for an interest payment of £54.32 gross to be paid net to Mr H. I do think there were some periods of unnecessary delay in this process which were caused by L&G, most prominently the delay between it receiving Mr H’s email on 25 November 2023 and it issuing the withdrawal letter on 28 December 2023. I accept the bulk of the delay was due to technical issues L&G was facing, but I do still think Mr H was entitled to compensation for the loss of the use of the monies during the delay and the fact he was impacted and inconvenienced by the delay. I accept this second delay also had an impact on Mr H and caused him additional inconvenience. However, having regard to this and also to the extent of the delay/the sum concerned, I don’t think an award of more than around £300 in total for this second delay is appropriate for the loss of the use of the monies during the delay and the distress and inconvenience the delay caused. I can see L&G has said it previously paid Mr H a little over £300 compensation for its failings in respect of the January 2024 withdrawal. I think the sum L&G paid Mr H is fair compensation for this issue. Accordingly, the amount L&G has already paid Mr H for this delay is in line with the type of award I would otherwise have made and I’m not making any further award in respect of this issue. Conclusion I think L&G did cause some unnecessary delays in respect of the withdrawal payments it made to Mr H in August 2023 and January 2024. But I’m satisfied it’s already paid Mr H fair compensation in respect of those delays and I make no additional award. I don’t think L&G mis-sold or mismanaged the FTRP, so I make no award in respect of Mr H’s complaint about these issues. My final decision For the reasons I’ve detailed above, my final decision is that I don’t uphold Mr H’s complaint about Legal and General Assurance Society Limited and I make no award. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr H to accept or

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reject my decision before 27 April 2026. Alex Mann Ombudsman

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