£2,139.60 a year. That’s what it now costs to keep selling Golden Charter plans. On 3 September, Golden Charter told its funeral director partners that every firm selling its plans as an appointed representative will pay a new annual “regulatory oversight contribution”. Invoices land in mid-October, with 60 days to pay.
SAIF asked for a six-month delay. Golden Charter said no.
So firms have weeks to decide: pay up, or stop selling. For many, the hard part isn’t the fee. It’s what happens to the plans that already name their firm.
Golden Charter’s Case
Chief executive Chris Wilson says the charge covers the direct yearly cost of the governance, oversight and administration behind a regulated network, and “is not intended to generate profit”. There’s a real basis for that. Since 2022, a plan provider has been answerable to the FCA for the conduct of every appointed representative selling its plans.
After hearing from partners, Golden Charter has capped the October 2027 fee at this year’s level. Payment terms are 60 days, double its usual 30, and it says flexible arrangements are available for firms with a real cash flow problem. But it won’t delay. A pause for everyone, it argues, isn’t fair when some firms can pay now.
SAIF’s Case
SAIF chief executive Terry Tennens told members there were “legitimate concerns” about the sudden imposition of the charge. SAIF and SAIF Scotland & Northern Ireland have since met Golden Charter and asked for the six-month pause. There has also been a call for a wider review of SAIFCharter’s role, which Golden Charter says it will support.
The row is partly about who was asked. Golden Charter says its board approved the fee, with three seats held by funeral directors elected by SAIFCharter members, and that the SAIFCharter Executive was then consulted. Some of SAIF’s National Executive were told beforehand, in confidence. By Golden Charter’s own account, they weren’t consulted on the decision itself.
Every SAIFCharter member is also a SAIF member. So one body that speaks for independents was consulted and the other wasn’t. That raises a serious question about how members were represented.
What Funeral Directors Are Saying
Some have already walked. Some call it the last straw after years of plan values that don’t cover the funeral. And a lot are stuck in the middle: they don’t like the fee, but they’re more worried about what leaving does to the plans already on their books.
What It Costs You
For a firm doing 100 funerals a year, £2,139.60 is about £21 on every funeral, plan or no plan.
Now do the sum per plan. If you carry out fifteen Golden Charter funerals a year, the fee adds £143 to each one. If you carry out five, it adds £428. The fewer plans you handle, the harder it hits.
What the Regulator Actually Charges
A funeral director selling as an appointed representative pays the FCA nothing directly. The FCA’s guidance says the plan provider pays £266 a year for each appointed representative, or £80 for an “introducer” with a narrower role, plus fees based on those firms’ income. Providers are allowed to pass these costs on.
So the regulator hasn’t set a £2,139.60 bill. That figure is Golden Charter’s own estimate of what it costs to supervise its network. It may well be justified. But it’s fair to ask how it was worked out, and whether a firm that only wants to introduce families could stay in for less.
Where the Money Is
Two things from Golden Charter’s own published report are worth knowing.
Your payout isn’t keeping up. The amount you’re paid when a plan matures goes up by about 2% a year. Golden Charter’s own actuary expects prices to rise faster than that, and the report says there’s no contractual obligation to raise plan values at all.
Take a plan worth £3,660 today, and suppose that covers your costs. In ten years, at the current rate, it pays about £4,460. If your costs go up 4% a year, that funeral costs you about £5,420. You’re £960 short, and you’ve guaranteed to do the funeral anyway. The 4% is my assumption, so treat this as an illustration and not a forecast.
The trust has more than it expects to need. The trust is the pot that holds plan holders’ money. Last September it held about £1.25 billion. The actuary’s estimate of what it needs to pay for every funeral promised was about £860 million. That leaves a cushion of nearly £390 million.
It isn’t all spare. The cushion shrinks to about £250 million if payouts keep rising 2% a year. But in that same year, £12 million was taken out of the surplus and paid to Golden Charter, the company.
So payouts are set to fall behind prices, and money is already moving from the trust to the company. Why does this bill go to the funeral director?
The Other Side of It
The surplus is a cushion, and it moves. The actuary’s report shows that a small drop in investment returns would knock tens of millions of pounds off it. Safe Hands collapsed in 2022 with about 46,000 plan holders and a trust that couldn’t pay. Nobody wants that.
Regulation does cost money, and until now Golden Charter hasn’t sent funeral directors a bill like this one.
And plans do bring in work. Golden Charter said it secured more than 48,000 future funerals for independents in 2020/21, the most recent figure I could find. Not every one is a family you’d otherwise have lost. But for some firms the plan book is worth £2,139.60 many times over. For others it plainly isn’t.
Before You Decide
Stopping new sales, ending your appointed representative agreement, and no longer carrying out the plans you already hold are three different things. Find out which of them follows from not paying, and get these answers in writing.
Will you be paid in full on the plans you already hold? Golden Charter’s April 2024 customer terms say the amount paid to the funeral director may depend on that firm’s status with Golden Charter at the time. Older plans may be on different terms, so check your own agreement.
Will Golden Charter contact your plan holders? These are families who chose you. You should know what they’ll be told, and by whom.
Are you still on the hook? The actuary’s report says the funeral director named on a plan “unconditionally and irrevocably guarantees” the funeral, and that Golden Charter, the plan holder or their estate can enforce it.
What happens to your SAIFCharter membership? Membership depends on promoting Golden Charter plans exclusively, so leaving one may mean leaving the other, along with your vote. That exclusivity is SAIFCharter’s rule, not the regulator’s. The FCA says a firm can be an appointed representative of more than one provider.
Three Questions for Golden Charter
- Will you publish a breakdown of what the £2,139.60 covers?
- Why can’t it come out of the surplus?
- Will you put in writing what happens to existing plans when a firm stops selling?
I’m not telling anyone to stay or go. Golden Charter was set up to look after independent funeral directors, and for plenty of firms it still does. But a bill this size, on a deadline this tight, deserves straight answers before anyone pays it or walks away.
When the invoice lands, will your firm pay it?
