Upheld: Fraud reimbursement (APP scams) complaint against 2 Plan Wealth Management Limited
Financial Ombudsman decision DRN-6099130 of 2026-01-23T00:00:00+00:00. Fraud reimbursement (APP scams) complaint against 2 Plan Wealth Management Limited. Outcome: Upheld.
Decision detail
| Reference | DRN-6099130 |
|---|---|
| Decision date | 2026-01-23T00:00:00+00:00 |
| Firm | 2 Plan Wealth Management Limited |
| Product | Pension |
| Claim type | Fraud reimbursement (APP scams) |
| Outcome | Upheld |
| Remedy | 2Plan must pay compensation to Mr X calculated as follows: (1) Obtain notional value of Mr X's SIPP as at final decision date, assuming £50,000 contribution on 28 October 2024 invested in same holdings/proportions as actual £42,450 contribution, excluding the actual £42,450 contribution from calculation; (2) Obtain actual current value of Mr X's SIPP; (3) Deduct actual value from notional value to determine pension loss; (4) If SIPP operator cannot provide notional valuation, calculate loss using FTSE UK Private Investors Income Total Return Index as proxy from 28 October 2024 to final decision date; (5) Pay compensation into Mr X's pension arrangement to increase transfer value by calculated loss amount, accounting for tax relief and charges; (6) If pension payment not possible, pay direct to Mr X reduced by 20% for notional income tax (or 15% if 25% tax-free lump sum available); (7) Add 8% simple interest per annum from final decision date if not paid within 28 days; (8) Pay £500 for distress and inconvenience caused by delays and shock of fraud. |
Summary
Mr X complained that 2Plan sent confidential pension contribution information via unsecure email, enabling a scammer to intercept the communications, create fraudulent forms with altered bank details, and defraud Mr and Mrs X of £100,000 (£50,000 each). Although £84,900 was recovered through the bank's APP scheme, £15,100 remained unrecovered. 2Plan initially rejected the complaint, arguing it was not responsible for Mrs X's compromised email and that Mrs X should have noticed the changed bank details. The ombudsman upheld the complaint, finding that 2Plan breached its own data protection policy and regulatory obligations by failing to use secure methods (portal, post, or in-person signing) for sending confidential information about fund transfers, which the policy explicitly identified as high-risk for fraud. The ombudsman rejected 2Plan's arguments that Mr X bore responsibility, finding the scam was sophisticated and Mr X acted reasonably. 2Plan must compensate Mr X for his pension loss plus £500 for distress and inconvenience.
The Ombudsman's reasoning
2Plan breached its own data protection policy and regulatory obligations under PRIN 2.1.1R, COBS 2.1.1R, and SYSC 3.2.6R by sending confidential information (bank details, SIPP reference numbers, contribution amounts) via unsecure email and Adobe Acrobat Sign rather than using its secure client portal or alternative secure methods like in-person signing or post. Although the Firm Y Contribution Form is publicly available online, the overall circumstances involved confidential information being shared insecurely. The scammer used all the information sent insecurely to create a highly convincing fraud. While Mrs X's email was compromised (not 2Plan's systems), 2Plan's failure to follow its own security procedures enabled the fraud to be carried out. Mr X acted reasonably in the circumstances and should not share liability for the loss. The scam was sophisticated and Mrs X's query about changed bank details was sent to the scammer's convincing fake email address.
How this compares
| Group | Decisions | Uphold rate |
|---|---|---|
| 2 Plan Wealth Management Limited, all decisions | 26 | 33% |
| Fraud reimbursement (APP scams), all decisions | 19,453 | 22% |
| Pension, all decisions | 15,579 | 47% |
Source
Read the original decision on the Financial Ombudsman Service website