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We ordered the headscratchers so that those higher up on the list are of most importance (some of the latter ones were practical issues, which are important but could have solutions).

Here is the order of popularity by cicks through to the website:

#4 The cost of transferring or selling an asset is not linked to the value of an asset

#1 Capital is not there just when it is needed

#5 Divergence from cost of wind-down as regime beds in

#3 Uncontrollable calls for capital lead to non-robust business models

#2 Release of capital to SIPP operator despite no change in risk of consumer harm

#11 Selecting the valuation date for AUA

#6 Large number of small plans vs small number of large plans

#10 The simple formula may not be so simple to verify

#12 Monitoring assets held within portfolios

#7 Misalignment of interests between SIPP operators and consumers regarding asset valuations

#9 Capital Requirement will be lower at times where there is a higher risk of consumer harm

#8 Misalignment with SIPP operator charging structures