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Final Salary/ Defined Benefit

Lifetime Allowance (LTA) Abolishment and What You Need To Know About The Autumn Statement Pension Reform 2023

The Autumn Statement unveiled big changes that will impact your finances. Chancellor Jeremy Hunt announces reforms to the Lifetime Allowance, Lump Sum Death Benefit, and Overseas Transfer Charge. These could really affect your retirement and inheritance plans.

We want to help you understand what it all means. The Lifetime Allowance (LTA) limits how much you can save into pensions without extra tax, also known as the LTA Charge. The reforms mean you can save more into your pension going forward. The Lump Sum Death Benefit rules around how much your pension can pay out when you die. The changes give less flexibility here. And the Overseas Transfer Charge makes moving your pension abroad costlier.

Understanding the Changes

Lifetime Allowance (LTA) Abolition

The Lifetime Allowance sets limits on your pension savings before you incurred extra taxes. Removing this cap gives you more pension flexibility but also means you must take charge of investment and tax planning in your retirement strategy.

Abolishing the Lifetime Allowance eliminates a significant barrier that many pension investors encountered, particularly high earners. While this provides greater freedom in your pension decision-making, it simultaneously transfers more accountability to you for weighing investment choices and potential long-term tax implications when mapping your overall retirement approach. You may need to review your investing risk appetite and tax picture thoroughly.

 


Lump Sum Death Benefit Allowance

The introduction of the Lump Sum Death Benefit Allowance presents a noteworthy change in how we treat death benefits from pensions. This £1,073,100 allowance gives you a clear tax-free benchmark when passing on your pension savings to loved ones after you die.

Any death benefits paid to your beneficiaries up to this amount will not face taxation. This provides helpful clarity for your estate planning needs.

However, for death benefits exceeding this allowance, the tax implications for your beneficiaries become more complicated. They will face income tax charges on any amounts over £1,073,100, potentially leading to substantial tax bills, depending on the final value of your pension and their personal tax circumstances.

This change means you need a more strategic approach when planning how to pass on your pension savings tax efficiently. We encourage you to consider how you distribute any amount over the Lump Sum Death Benefit Allowance within the context of your broader estate and inheritance tax planning aims.

Speaking to a financial adviser can help make sense of the options available to handle the tax treatment of any substantial pension assets in excess of the threshold.

Introduction of Lump Sum Allowance

Alongside the abolition of the LTA, the Autumn Statement introduced a new Lump Sum Allowance of £268,275, which is 25% of the previous LTA. This allowance sets a cap on the Pension Commencement Lump Sum (PCLS) that can be taken tax-free.

While this provides clarity on the tax-free portion of pension withdrawals, it also imposes a new limit that individuals must consider in their retirement planning. This change is particularly relevant for those who have not yet accessed their pension funds and may need to adjust their withdrawal strategies to optimise tax efficiency.

For those with substantial pension savings, careful planning is required to structure withdrawals in a way that maximises the tax-free PCLS available under the new allowance. Exceeding the £268,275 threshold will lead to tax charges that reduce overall retirement income.

Overseas Transfer Charge (OTC)

A notable change for those thinking of transferring UK pensions overseas is the new Overseas Transfer Charge (OTC). This 25% tax charge applies to transfers above the £1,073,100 Overseas Transfer Amount.

This OTA level mirrors the Lump Sum Death Benefit Allowance. For those with a protected higher Lifetime Allowance, that figure would apply instead.

This change introduces a substantial extra tax consideration for assessing whether moving your pension pots abroad aligns with your retirement plans or not. Carefully weighing up the pros and cons is vital to make the right choice, and thus you should always seek the help of a regulated and qualified financial adviser to understand your options.

Specific Implications for QROPS and SIPP

Transfers to QROPS

The timing of transfers to Qualifying Recognised Overseas Pension Schemes (QROPS) takes on greater significance given these rule changes.

If you transfer before 5th April 2024, there would be no Lifetime Allowance tax charge triggered. However, for QROPS transfers after 6th April 2024, although the Lifetime Allowance does not apply, any amount over £1.073 million would face the 25% Overseas Transfer Charge.

Additionally, under current guidelines, moving funds over 10 years ago falls outside the UK tax charge rules. This provides helpful clarity on legacy transfers.

We recommend reviewing transfer plans in advance of April 2024 to map out the most strategic approach aligned with your situation. Getting ahead of the deadline enables us to support you in mitigating any potential tax implications.

Remaining in a Current SIPP

For those opting to stay in their Self-Invested Personal Pension (SIPP), the Lifetime Allowance abolition changes things. Past withdrawals no longer have Lifetime Allowance charges to consider. This covers areas like Pension Commencement Lump Sums, setting up income, death benefits, and age 75 tests.

However, the Pension Commencement Lump Sum still has a £268,275 cap. Any excess over this amount would face income tax charges. Lump sum death benefits also have a £1.073 million threshold before beneficiaries pay income tax on any excess at their marginal rate.

There is an exception on death before age 75 – beneficiaries can take any excess as income without an immediate tax charge. Even so, remaining in a UK pension means potential future legislation changes could still alter access rules and tax treatments, especially if governments change. 

The Role of a Financial Advisor

Financial advisers have an important role in making sense of this pension complexity for clients.

We can offer tailored guidance on how transferring overseas or staying put could align with your objectives. Our analysis will factor in the new rules and your unique financial and retirement planning aims.

Informed choices matter given the substantial tax implications in play. We will discuss pros and cons in detail before you commit one way or another.

Our support also extends to strategic planning around contributions, inheritance, and calculating tax efficient income drawdown. We keep you updated on regulatory developments and what they mean for your situation.

The financial landscape continually evolves, so having first-hand advice ensures you can adapt plans accordingly. We provide ongoing assessments to keep your arrangements on track through personal or policy changes ahead.

Our aim is equipping you with the knowledge to pursue the pension approach that works best for your circumstances.

To Sum Up

The Autumn Reform 2023 introduces noteworthy changes to the UK financial environment. Areas impacted include the Lifetime Allowance, Lump Sum Death Benefits and the Overseas Transfer Charge.

These reforms provide openings along with complexities. This increases the need for professional financial advice to steer through the changes smoothly.

With our pension expertise and individual guidance, you can effectively navigate the new rules. We will collaborate on robust arrangements tax-efficiently aligned with your long term aims.

As the financial landscape inevitably continues shifting, first-hand advice is crucial to stay informed. We will explain the meaning of policy and regulatory updates on your position as they emerge.

Our support empowers you to adapt as the environment evolves. By working together, we will ensure your financial plans remain on track to deliver your retirement goals.

Book a free initial consultation with one of our Independent Financial Advisers to discuss your pension planning further.

Categories
Final Salary/ Defined Benefit

Understanding Withdrawal Protocols for Your Brite Advisors Pension or General Investment Account: A Guide

There’s important news for Brite Advisors’ clients regarding their pension or Investment Account. At Cameron James, we want to make sure you’re up-to-date with these changes. For more context, be sure to read our previous blog.

Understanding the New Withdrawal Process

Following the appointment of McGrathNicol as Corporate Receivers, Brite Advisors has established specific protocols for processing withdrawal requests. These include:

  • Submitting requests through Corporate Trustees, where such arrangements exist.
  • Direct investors without Corporate Trustees must send their requests via email to a designated address.
  • Only those who had submitted requests prior to November 9th i.e., those who were actively already drawing from their pension, are able to access their funds at this point in time, and requests made after this date will not be considered
  • Withdrawals are limited to maintaining at least 70% of the total investment value as of 9th of November 2023. I.e., you can withdraw a maximum of 30% of the value you had on the 9th of November.
  • Complete withdrawal or surrender of investments is not currently permitted under these new guidelines.

Request Submission and Processing

For those with pension schemes, continue to liaise with your usual scheme administrators for withdrawal requests. Direct investors with Brite Advisors should adhere to the new email process. The Receivers are diligently working to gain access to necessary systems and anticipate beginning the processing of qualifying requests in the upcoming weeks.

Whilst the Receivers’ official announcements don’t explicitly state this, we have seen correspondence from pension trustees indicating that it may actually be possible to submit a request after the 9th of November cut off, and get the withdrawal approved, but there will need to a bulletproof reason for doing so, such as financial hardship without it.

The statement received from the Trustee was that “requests made after 9th November will require special consideration by the Receivers and must be accompanied by an explanatory memorandum, perhaps describing the purpose of the withdrawal and the hardship that may ensue if the request is not acceded to, which must be duly signed by the requesting member.”

Please note, this option should only be considered under genuine circumstances. Be aware that any requests for full withdrawal or similar actions are likely to be rejected.

The Broader Impact on Investors

These recent changes have significant implications for a wide range of investors, affecting both short-term liquidity and long-term financial planning. It’s crucial for investors to reassess their strategies and possibly adjust their financial plans in light of these new withdrawal protocols.

Our Opinion

These updates from Brite Advisors are significant, and after many weeks of confusion and speculation around when members would be able to start drawing again from their pensions, it finally appears like there is movement.

Whilst this may feel like an opportunity to secure some of your funds and get them off the Brite Platform, making withdrawal requests is unlikely to be a sound strategy unless you have a genuine reason to need the funds. Any funds withdrawn at this time will invariably be taken into account when they work out what is owed to each Brite member via whatever mechanism they apply if there are insufficient funds to make the members whole.

So taking funds now, which will likely be taxable, especially if not from any sort of lump sum allowance, is likely to be poor financial planning, so you should not rush and make any impulsive decisions, but rather seek the advice of a qualified and regulated financial adviser.

Also, if you are in a strong financial position, and do not need any access to funds at this time, then all your request is doing is clogging up the admin capacity of the Receivers for those who genuinely do have a strong need for the funds, so you will be impacting your fellow Brite members negatively.

If you already had a withdrawal request put in, or were in receipt of a regular income stream, prior to the 9th November then please carry on liaising with the Receivers, whether directly in the case of investment accounts, or through your Trustee in the case of pension accounts, and hopefully the payments will be forthcoming.

For those of you who have made, or are looking to make, withdrawal requests post 9th November, please make sure you only do so if you are in desperate need for the funds, as your request will unlikely be successful. And, if you do need the funds, make sure you put together a thorough reasoning for why you need the funds when submitting the request, as otherwise they will also likely reject your request, so take the time to be thorough.

Navigating Changes with Confidence

As the situation evolves, staying informed and adaptable is essential. Cameron James is dedicated to providing guidance and support during these times. For personalised advice and assistance, we encourage you to contact us or other qualified and regulated financial advisers.

Whilst there is still potentially a long way to go before the entire situation is resolved, and the ability to transfer out is possible, that does not mean you have to sit idly by waiting for that time. Getting out ahead of the process, and finding a professional, honest and regulated adviser to work with now, to prepare for that moment, will all but certainly be valuable down the road, whilst also helping you obtain some peace of mind, no matter how insignificant, that you are doing what you can to help get yourself into a better position.

Categories
Final Salary/ Defined Benefit

What’s the Latest with Your Investment at Brite Advisors?

For those invested with Brite Advisors, there have been some key changes recently. We at Cameron James want to ensure you understand these changes and how they might affect your investments.

If you’ve been affected by the situation at Brite Advisors, keep reading – this update is specifically for you. For more background on this case, you can read our previous blog post here.

Appointment of Corporate Receivers

Linda Smith and Rob Kirman from McGrathNicol were appointed as Corporate Receivers and Managers at Brite Advisors by the Federal Court of Australia on December 13, 2023. Their role involves securing Brite Advisors’ property, including client assets, and conducting thorough investigations. This move aims to stabilise the company’s operations and ensure proper management of assets.

Current Asset Status

The Receivers have successfully secured substantial assets, with investments valued at over AU $976 million (c.US $652 million). Their efforts are focused on stabilising the company’s operations and providing clarity on the status of client assets under management.

Now, this appears to be, on the face of it, some positive news. As per the last updates, it appeared that c.US $69m was potentially unaccounted for in Brite’s accounting system, which was much of the reason for the expedited appointment of the Receivers.

However, it appears that some of that may now be accounted for, so worries about missing/stolen funds are perhaps not quite as large as first suspected, in our opinion, as the last update from the Receivers would indicate. Given that they have not made further reference to missing funds and that they have stated their goal is now to move on to the loans to ascertain who has the rights to all the funds, is a further indication that they have moved in a positive direction towards accounting for the missing funds.

This doesn’t mean they are out of the woods, and a lot of funds still may be missing, but it is certainly appearing to be trending in the right direction, with the next report hopefully providing even more clarity on this point. The Receivers, of course, might be in a position where they don’t want to cause more panic, and are withholding such statements until the court report, once they have had even more time to investigate and can make a more declarative statement of the security of all the client assets under management.

Future Reports and Implications

A report is expected by 24 January 2024, which will shed more light on the future of client assets. This development is significant for investors and requires careful attention.

By this date, they will have hopefully obtained all the various loan agreements and contracts, and have a better, if not complete, understanding of the rights of ownerships of the funds, along with once and for all being able to confirm that they have control to all the client assets, and that there is nothing unaccounted for.

From there they can then work out what is client owned, and then it will likely be up to the courts to decide how clients will be repatriated with their assets, and what amounts they will be able to transfer to a new platform/provider etc. However, there is no way to know for sure what information they have obtained, and how far along we are until this report is completed and published. They will also 100% need to make sure that all the accounts reconcile, and that they have indeed got access to all the accounts and all the money.

Exclusion from Broader ‘Brite Group’

It’s important to note that the Receivers’ appointment does not extend to other entities within the ‘Brite Group’. This delineation is critical for understanding the scope of their investigation and actions.

However, whilst ASICS might only be looking at Brite’s Australian Entity, that is where the money is held, so should not be too much cause for concern, especially for those of you in the US, where legal action is underway from the SEC.

Restrictions on Withdrawals

We now have more clarity on the withdrawal process, after months of speculation and slightly ambiguous wording in court/receiver documents. If you set up a withdrawal instruction before November 9th, you’re likely fine to continue receiving regular income. But if you were planning to start taking money out or get your PCLS after this date, there’s a potential, if not likely, hold on that. 

We understand this might be frustrating, but it’s a necessary step for now given the complexities of trying to assess ownership of the funds. We have written another article that explains the new information around withdrawals, along with our interpretation and client experience received thus far.

Looking Forward: What’s Next for Your Brite Advisors Investment?

At Cameron James, we understand the challenges and concerns faced by investors during these uncertain times. It’s vital to approach this situation with a combination of patience and strategic planning.

Consulting with a qualified and independent financial adviser, who is regulated within your local jurisdiction, is a crucial step to ensure you do not make the wrong decision for your funds. Establishing this professional relationship early on, rather than scrambling when your funds are ready for transfer, is essential. Haste in such matters, driven by the eagerness to move funds quickly, can inadvertently shortcut the due diligence process, potentially leading to decisions that may not serve your best interests in the long term. Taking the time now ensures a thorough and considered approach to your financial future.

Our team is here to offer empathetic, expert advice to help you navigate these changes. We’re committed to providing clear, understandable guidance, ensuring you make informed decisions for your financial future. If you’re impacted by these developments, don’t hesitate to reach out to us for support.

Categories
Final Salary/ Defined Benefit

What is the Status of my Brite Advisors Pension?

 

Brite Advisor’s and Australian Regulator Court Case

Written by: Eduardo F. Simoes (IFA) and Jonathan Laws (IFA)

The Federal Court of Australia has issued a significant order concerning Brite Advisors Pty Ltd, following the Australian Securities & Investments Commission’s (ASIC) legal actions. This pivotal development in the Brite Advisors case involves appointing Corporate Receivers and Managers for Brite’s assets, marking a potential critical juncture in the proceedings.

Key aspects of the court order include:

  • Appointment of Corporate Receivers and Managers: Linda Smith and Robert Kirman from McGrath Nicol have been appointed to take control of Brite Advisors Pty Ltd’s assets. This move is designed to ensure a thorough investigation and secure the company’s assets.
  • Detailed Objectives: The Corporate Receivers and Managers are tasked with identifying, collecting, and securing Brite Advisors’ assets. Their role includes assessing the financial positions of Brite’s clients, determining the solvency of the company, and evaluating the likelihood of creditors/investors receiving returns in the event of a company wind-up.
  • Asset Preservation Orders: The court has placed restrictions on Brite Advisors Pty Ltd. The company is restrained from activities like removing assets from Australia, engaging in transactions that impact the value of their assets, and incurring new liabilities.
  • Compliance and Reporting Requirements: The Receivers and Managers must report their findings and actions back to the court and ASIC, ensuring transparency and accountability in this process.

This court order represents a crucial step in addressing the complexities surrounding Brite Advisors Pty Ltd and seeks to protect the interests of its clients and investors during this challenging period.

For clients affected by the shutdown of the Brite Advisor platform and the restricting of assets, this court development is significant. Receivership, the process now unfolding, involves appointed professionals (the Receivers and Managers) taking control of a company’s assets to manage and protect them.

This is often a step towards restructuring or liquidating a troubled company. For clients, this phase is crucial as it aims to safeguard assets and potentially recover funds. The appointment of Corporate Receivers and Managers could bring more clarity and structure to the situation, offering a pathway towards resolving the complexities surrounding the frozen assets and the platform’s future. This development is a vital step for clients looking for resolution and access to their investments.

Our Thoughts

Just a quick caveat, but this section is our own opinion on the matter, and should not be construed as any sort of opinion from a legal authority. Whilst we are very knowledgeable advisers, and many of us have professional qualifications, we aren’t lawyers! 

Many of you might read the above summary, and the actual regulatory announcements, and get very worried. But, in our opinion, this latest development is actually a positive. Whilst it does indicate that there are indeed issues with reconciling all the client assets, that is something that we, and most of the clients we have spoken with, anticipated. Hence, it is not a great shock.

We see it as a positive as it indicates that the regulator is being proactive, and is putting in place steps to secure your money. Long story short, it makes it likely that you are closer to a conclusion, one way or the other.

At this stage, the best approach is to carry on a normal advice process with a regulated financial adviser, especially until the Receivers complete their report. What will ultimately be the outcome is hard to know; but if we had to guess, it is likely some form of haircut to client funds once all funds reconciled, and loans settled etc. However, we can not know for sure, and that is just our “laymen” opinion based on similar situations that have occurred. Also, you never know, they might secure all the assets, and there is no loss, and all the panic and worry was for nought! 

We would also, as we always do, preach patience. Whilst the regulators have been very swift so far, it would not surprise us if this drags on for months and months, perhaps even until 2025 and beyond. However, gauging from how swift the Australian Regulator has moved, and given that the US SEC is involved, and thus there is now their significant authority, financial, and man power involved, that hopefully it won’t drag out that long, but do want to set out expectations, as a speedy resolution is not likely.

Staying on top of the proceedings, which we will also endeavour to do via regular updates such as this, and going through a proper advice process with a Regulated Financial Adviser is the best strategy at this stage.

Transferring Out of Brite Advisors Pension & Platform

Currently, it does not appear possible to transfer out of the Brite Advisors platform due to the restrictions imposed by the Australian regulator. With the SEC looking to terminate Brite’s regulatory permissions, a transfer in the future seems increasingly likely, but will likely require the resolution of legal proceedings, especially those occurring in Australia. We have written an article on this previously, which you can read about through the following link.

For now, the best course of action is to undergo a thorough advice process. This preparation ensures that you are ready to make a swift and informed transition when the opportunity arises.

Whilst we only provide advice specific to each individual, what we can say is that at Cameron James, our preference is for FCA-regulated platforms, known for their high level of asset protection. This approach applies even when managing a Maltese QROPS; we will in the majority of cases opt for an FCA-regulated platform within it, prioritising the safeguarding of assets over the use of offshore bonds, even if they can be a lower cost overall, especially for larger pensions. This strategy is central to our commitment to providing secure and reliable financial solutions for our clients. Sometimes a premium is well worth the security and peace of mind it provides.

STM as Trustee & Appointing New IFA

STM, a QROPS Trustee in Malta and Gibraltar, has recently updated some Brite clients we are in contact with about the situation with Brite Advisors. The main point is that the Australian regulator has put a hold on all Brite’s assets, including the funds belonging to customers. This step is likely temporary and is part of a detailed financial review. While this restriction is in place, you can still withdraw regular money from your accounts, but you’ll need approval from the Australian regulator first, and this seems to be taking a long time to process. STM hasn’t specified any special conditions or how long these withdrawals might take. It is also worth nothing that STM is not the only Trustee involved, or though it does appear to be one of the main Trustees for Brite USA clients. 

Also, if you’re considering moving your money to a different company, scheme, or financial advisor, STM has said that this is okay. You have the option to transfer your funds, but just remember that any transfer will need to meet the standard regulatory rules and requirements.

Again, it might very well be the case that the best advice is to keep your existing scheme, but that can not be confirmed until you go through the advice process and obtain formal regulated advice.

Seeking a New Adviser or IFA

For clients whose pensions are managed through the Brite Platform, actively seeking a new financial adviser is likely to be a prudent step towards securing your future financial stability. The ongoing regulatory interventions and asset restrictions associated with the Brite Platform indicate that an immediate transfer may currently be unfeasible. Nevertheless, forward planning is crucial in this scenario. Being prepared for eventual changes in the platform’s operations is not just advisable; it’s essential for maintaining control over your financial future.

Given these uncertainties, it’s wise to explore and evaluate potential advisers now. At Cameron James, we have compiled a video of 12 things to look out for in a new IFA, which we recommend you watch.

This proactive approach ensures you’re not caught off guard should a swift transition become necessary. It allows you to make informed decisions based on a comprehensive understanding of your options, rather than hurried choices under pressure. By preparing in advance, you position yourself to respond effectively to changes, safeguarding your pension and ensuring continuity in your financial planning.

Other Financial Advisers

Be wary of financial advisers getting in contact with you directly, especially unsolicited. Whilst it is banned to cold call people about their UK pensions, there are some loopholes that can make it possible for overseas advisers to contact you in a certain manner within an interesting interpretation of the rules, it is still not a client finding technique that inspires confidence.

At Cameron James, we do not cold call. All our clients come to us through our website or referrals. We consider cold calling to be a remnant of a bygone era, an era that needs to end sooner rather than later. With recent calls from the FCA to ban all cold calling in regard to UK financial services, that era might be ending sooner rather than later.

Also, be wary of any sort of offers to “bulk” transfer or provide or accommodate any sort of “one-size fits all” approach. Financial Advice is tailored to each person’s unique situation, it can not be applied by rote to every individual.

Every client, regardless of whether they are from Brite or not, needs to have a proper, thorough advice process, and obtain advice tailored to their unique circumstances. Whilst it is likely that a lot of people receive relatively similar advice, given the relatively homogenous nature of Brite Clients, that does not mean everyone will have the same advice, so going through the process with an adviser is of paramount importance. This includes filling out a client profile, acquiring hard facts, and producing a formal recommendation, in writing.

Some people might keep their Trustee, some might change it, some might even completely change jurisdiction, it all depends on you and your circumstances.

We would also mention to those of you who moved to Brite from a legacy product which still contains an exit penalty due to the repayment of an original commission paid, that any advisers offering to help you transition your exit penalty over, should be considered with the utmost due diligence and attention.

Whilst it could be the case that you are not paying any extra fees, the offer of transferring an exit penalty partially explains why some of you are in the situation where you are now. Perhaps you did not, completely understandably, want to stomach such a large fee being paid in one go, and so the desire to spread it out made Brite’s offer attractive. You also have to remember that the exit penalty is a sunk cost, you are going to be paying back that commission, whether you bite the bullet and do it upfront, or you spread it out over several years. Whilst technically spreading the payment period out can result in less impact on your pension value, that is only applicable if your pension pot rises, and as I am sure you are aware either personally or from reading up online, investment portfolios attached to commission products have a nasty habit of not increasing in value, even when the wider capital markets have soared.

Given that it is also very likely you want a clean break, and to say goodbye to this entire saga, signing up for yet another exit penalty, even if it is the continuation of an existing one, is unlikely to be a sensible option. This offer also signals to you that you aren’t dealing with a modern “fee-only” adviser and are engaging with an adviser who continues to use commission products. Whilst commissions don’t necessarily mean higher fees, in our opinion they are opaque and have a bad reputation for a reason, and are best avoided.

Otherwise, the standard warnings apply, which again, you can read through and use to assess advisers you speak with, using our  12 things to look out for in a new IFA YouTube video and document.

Other Things to Consider

It should also be noted that this is likely to be a significant portion of your retirement funding, and you want to make sure that the adviser you choose now to help you out of this situation is someone you like and trust.

Building a long-lasting relationship with an adviser you trust and someone you not only would be willing to work with, but enjoy working with, is incredibly important.

That is also how we work at Cameron James. We only take on clients who we want to work with long term. A transactional relationship is not what we are after, and in our experience, many clients who seek out a transactional relationship get burnt, as many of you reading this may have already experienced. 

Transactional relationships often lead to subpar client experiences, characterised by minimal engagement, inadequate information, and a general lack of comprehensive service.