DC
legislation: triumph or trouble?
Pensions Age
DC roundtable
New pensions
legislation may offer DC members increased flexibility and investment
choice, but it also adds complexity to an already over-complicated
system.
No doubt more financial education will be necessary for members
to make the most of these changes, but who is going to meet the
cost of this? Does this extra choice really represent change for
the better? And will it lead to a better world for DC members?
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The
cast:
Chairman: Roger
Cobley having recently been re-elected as President
of the Pensions Management Institute (PMI), boasts extensive experience
in the pensions sector. He is currently a director of Stamford Associates
Limited, the investment consultancy firm, chairman of several pension
funds, a fellow of the Institute of Actuaries, an associate of the
Society of Actuaries as well as a Freeman of the City of London,
to name but a few of his achievements.
Robert
Branagh is director of client development at
Paymaster, having joined in 1999. He is responsible for Paymaster's
relationships and service offerings to existing clients and is a
fellow of the PMI.
Jeremy
Ward is
head of pensions marketing at Friends Provident, where he has worked
since 1994. Previous roles at Friends Provident include head of
product management and head of strategic marketing.
Richard
Parkin is head of DC product development at
Fidelity Investments, having joined in September 2002. He has also
been an associate of the Pensions Management Institute since 1992.
Andrew
Cheseldine is a senior consultant in Watson
Wyatt's Benefits Practice. His principal area of expertise is in
advising on and implementing employee benefit programmes, particularly
DC pension arrangements in replacement of existing DB pensions.
The debate:
New
legislation
Chairman: "The
Pensions Bill is, slowly but surely, grinding its way through Parliament
and since we last met, a few further legislative changes have come
to light. What impact will these have on the DC market?
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Parkin: A few things of relevance have
been added. First, the vesting element – which the government
has confirmed to be a three-month period – could be something
that may make employers less attracted to occupational plans (or
at least put them on a par with personal pensions).
A second, more unexpected change was the removal of LPI on DC occupational
pensions, which was welcome. It’s just a pity they didn’t
go the whole hog and take it away from DB too. Given that research
shows you need to live until about 91 years old before the LPI protection
actually pays off, it will not only mean that members are going
to get a slightly better deal at retirement but from an administration
point of view makes life that much easier.
Branagh: Certainly from an administration
point of view it is also very welcome as it relieves things going
forward. But, there is a slight concern that members still need
to be educated if they are going to benefit from the change. This
leads on to the question of how useful SMPI is. The feedback we
have been getting from members has been mixed. In fact, not many
of them think these new statements offer anything substantially
better than what we had before.
Parkin: Another concern I have about SMPI
is the fact that some of the assumptions about contributions are
pretty dangerous, particularly if you have age and service-related
contribution structures. So, it would be helpful if statements basically
said: this is what you’ve got now, this is what you might
get if you stay until retirement, and this is what you would get
if you stayed for the next, say, five years. From an administration
point of view, though, that might create a monster.
Chairman: But let’s not lose sight
of the fact that one of the main reasons behind the SMPI was to
wake members up to the fact that they need to save more for retirement
– has this been achieved?
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Cheseldine: I think it has forced people
to take the first step in that direction. For example, at Watson
Wyatt we have had feedback from members saying ‘hang on, this
isn’t giving me as much I thought’. This in turn has
led us to conversations with employers whereby they are slightly
more prepared to fund financial education in order to try and raise
awareness among employees.
Branagh: And post-2006 this is going to
be more important as members will have more power to make their
own choices. Trouble is, if you still only have about 20 per cent
of the population who are financially literate it won’t matter
a jot if there is more modelling – you still have got to tell
people that they need to take ownership themselves and we have got
a responsibility to help them do that.
Chairman: But whose responsibility is
it to educate members on financial issues?
Cheseldine: I think there is a general
consensus that employers are going to have to take more responsibility
for this and that is partly driven by the consultation rules that
are coming in as part of the Pensions Bill, as well as the DTI employment
relations consultation rules.
Trouble is, while it appears that the government is making employers
responsible for financial education, is the infrastructure there
in terms of allowing them to give information without breaching
the Financial Services Act? That is debateable.
Chairman: But whether they are breaching
the FSA is a fixable problem – the more pertinent question
perhaps is to what extent will employers be required to do this?
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Parkin: There are two levels to this.
I think it is right that employers should be encouraged to promote
their pension schemes more clearly and try to encourage membership;
but it becomes more dangerous when they are trying to encourage
members to make additional contributions as there may be other places
their members should be putting their money, for example paying
off their credit cards.
Ward: Yes, it becomes dangerous for employers
when they cross the line into individual financial advice. While
for the majority of people it will be fairly clear whether or not
it is beneficial to be a member of the pension scheme, once you
start looking at how much should be contributed you are getting
into the whole issue of individual advice which employers aren’t
generally best placed to provide.
Chairman: But if the employers aren’t
best placed to provide it, will the employer be virtually required
to provide this as an additional service by, for example, appointing
an IFA?
Branagh: I think it will come down to
normal commercial pressures – if you are in an industry where
you are using your pension scheme as a business tool to retain staff
then you will do as much as you can to maximise the return on that
tool.
However, the general perception is why spend money to educate your
workforce if they are going to go down the road to your competitor
two weeks later? As a result, employers are less inclined to do
anything extra for their members unless they absolutely have to
and eventually compulsion will be needed to make employers take
more responsibility.
Ward: But I don’t think compulsion
is where the government is heading.
Branagh: Well, once more people have retired
from DC schemes we will see if there is a backlash of employees
blaming their employers for their disappointing investment returns.
If that starts happening on a large scale I think you are going
to see encouragement for employers to do more, and that may be in
the form of compulsion.
Chairman: But there was talk that the
government would exonerate employers and give them some sort of
leeway if they were expected to give advice.
Parkin: I think the rules being proposed
by the FSA are fairly limited around being able to promote the scheme
and membership of the scheme, and it is when you go beyond that
the problems arise.
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Role
of IFA and the stakeholder cap
Chairman: Going back to the whole business
of financial education then, is this open season for IFAs and is
that good news or bad news?
Parkin: IFAs do have the potential to
play a role but I think in a corporate pension scheme it is questionable
whether an employer would want to pay for an IFA, and that could
lead us back to schemes being written on commission. But, even then,
does that necessarily promote the right type of advice?
Ward: We are seeing more being written
on commission and I think an interesting legislative change that
has come in since our last meeting has been the cap being raised
on stakeholder charges from one per cent to 1.5 per cent for the
first ten years (which from the provider’s perspective offers
the worst of all worlds in that it makes things more complicated).
I think a number of corporate IFAs out there, though, might be thinking
this offers them scope to make a bit more money. Although the actual
figure doesn’t provide a lot more in reality.
Chairman: This issue of advice brings
us back to Branagh’s earlier point that you almost need some
crisis cases before that message comes home.
Branagh: Yes, and another good example
is where we see people putting all their money into second and third
homes on the expectation that the increasing capital value can be
utilised instead of a pension – reality is, of course, if
there is a correction in the housing market those people’s
assets could be wiped out.
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Alternative investments
Chairman: Well, let’s extend the
debate – the new investment opportunities that have been introduced
under the new legislation coincide with what has already been identified
as a lack of financial education – good or bad?
Cheseldine: I have to say bad. If you don’t
get the education right while you create extra choice things will
go wrong and I have a feeling that some of the extra investment
choice that is being made available has been done under a false
premise.
We have just completed a FTSE 100 DC survey looking at the average
number of investment options available under DC schemes (around
half were retail schemes – i.e. stakeholder and GPP, and half
occupational). The results showed, as you would expect, that retail
schemes have vastly more choice than occupational.
The difference is, in retail, you have got a provider behind you
that is offering (albeit limited) financial education, and usually
offers a default; but in occupational schemes you are not necessarily
doing all of that.
Ward: There does seem to be some tension
between the needs of the average member and the state of requirements
of some advisers. We are always increasing the fund choice but that
isn’t driven by the demands of the members, it is driven by
the demands of the advisers. Advisers have their favourite funds
and if those funds aren’t on our platform, they won’t
use us. But does it make a difference to the members? I think not
as most research shows that people are better able to make choices
from a limited number.
Chairman: So, are providers going to have
to offer an option for people to put pension money into residential
property?
Ward: We could – but is it appropriate
for most people to fund their retirement through residential property?
Parkin: If we could be sure that people were going
to construct well-diversified portfolios with an element of residential
property then we would make a vehicle available; but we know certain
people will just put all their cash in it and rely on the property
market.
Chairman: Do you think the DC market will
move into offering alternative investments like hedge funds, venture
capital, and private equity?
Parkin: As direct investments they are
probably not appropriate – whereas if it they are part of
a broader portfolio they may be. There are also other forms of structured
products which effectively do dynamic allocation between equities
and bonds – but it all comes back to the problem that most
investors are not going to be financially sophisticated enough to
make a decision about these.
Cheseldine: Saying that, I do like the
idea of having a fund of funds or manager of managers addition to
DC where you would have some non-correlated risk investments, some
distressed debt, some venture capital, some hedge funds and so on.
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Role
of the adviser
Chairman: The providers here today keep
referring to the “demands of the investment adviser”.
If the market is being totally dominated by the investment advisers,
is that good?
Parkin: The market is dominated by the
advisers and they do add value in guiding the trustees in the DC
market where it is all very new to people and clients do need a
lot of advice in terms of setting up their plans.
I do think, though, that there are always complications when there
is such a diversity of views and in our experience it does cost
a lot of money to meet that diversity of views. That, coupled with
the natural instinct of the adviser to try and get the best price
in the market, causes a lot of financial pressure on the providers.
Chairman: So, is the proliferation good
or bad for the market?
Parkin: I think there are dangers in not offering
diversity although I think things could still be simpler –
less investment choice and slightly clearer contribution structures
in some cases of DC.
Cheseldine: Part of the problem is that
we change our minds all the time but that’s because the market
constantly changes – new evidence comes to light, the economy
alters and on top of that, legislation changes things too.
Chairman: But have we not, between us
all, conspired to create a very complex market with lots of added
costs, which at best is confusing and at worst is cost inefficient?
Ward: I think if you look at where most
of the member money is going, it is going into the default fund,
which, on the whole, is very simple to understand. I think where
you do have the proliferation is around the edges.
Branagh: I disagree. I think it has all
gone too far. There is too much choice, too many decisions to make
and the trustees are asking what is this going to mean to me if
any of this goes wrong? Isn’t it better to invest in the core
product for the benefit of members and make that the best possible
product we can, rather than invest in tweaking the edges, throwing
money at slight improvements here, and adding more investment choice
there?
Parkin: But, as providers, we are trying
to stay competitive. We are always trying to add the latest bell
and whistle to our product so we can be better than the other providers.
Ward: Saying that, by far the bulk of
the investment that providers are putting in is targeted at developing
pension products and targeted at improving the service and systems
,than it is towards proliferating funds.
Branagh: Well that’s not necessarily
the perception in the marketplace among trustee bodies and members.
Chairman: Well, maybe providers are not
communicating that message."
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