Industry experts have stressed the importance of protecting savers and the consumer journey as part of the pensions dashboards framework, with particular concerns emerging around the proposed data requirements.
The Financial Conduct Authority (FCA) and Pensions Dashboards Programme (PDP) recently held consultations on the proposed design standards for pension dashboards, and the regulatory framework for operators, both of which closed yesterday (16 February).
Industry experts welcomed the consultations, with the Society for Pension Professionals (SPP) stating that it offered “broad support" for the proposals, including that Pensions Dashboard Service (PDS) firms should be subject to the Senior Management Arrangements regime.
However, the SPP’s response to the PDP also draw attention to some areas that it suggested could put consumers at risk of harm, raising particular concerns around the mechanisms and effectiveness of the notification regime.
“We would wish for further information to provide comfort that all parties concerned, PDS firms and regulators will be enabled to take timely and comprehensive action when you receive reports that impact the pensions dashboards service community," it stated.
In addition to this, the SPP argued that the options available to a customer after they have used a post-view service and want to continue their digital journey could be another area with the potential for "considerable impact and harm to dashboard users".
The SPP explained that while the proposed options only allow the customer to progress directly from the post-view service to MoneyHelper, MoneyHelper is limited in the assistance it can provide, especially to the under 50s, with the SPP warning that many people, especially those brought into saving by auto enrolment, will be unable to afford financial advice.
In light of this, the SPP argued that this could create a “hard break”, where customers become frustrated and abandon the journey, or potentially take their next steps into a space lacking regulatory oversight, "both of which may cause more harm than what the rule seeks to prevent".
The SPP continued: "The focus on the customer journey also links to the proposed 30-day data storage limit.
"When allowing the customer time to make comprehensive and effective use of the post-view service tools and considering the additional information that may be added in, when advice or guidance is being sought, 30 days seems like an unnecessarily limiting amount of time.
"To allow the customer to move through their journey at a considered pace, having time to pause and reflect, without having to begin all over again, we propose a longer time limit of 90 days.
"This will help prevent customer frustration and abandoned journeys without compromising the aims of applying the limit in the first place."
Indeed, although some industry organisations have welcomed the increased security for members, others have warned that the proposed rules around data exporting could risk creating a ""two-tier system, distort competition, with the potential for consumer harm".
Adding to this, AJ Bell head of policy development, Rachel Vahey, emphasised that savers will need the right support to understand how to use the information to make better pension decisions, arguing that it is "essential" the FCA set the right regulatory framework around the presentation of this material and the help and prompts people will receive.
She continued: "Ultimately, dashboards could be a driver of consolidation activity and encourage people to seek the help of a financial adviser in building a stable retirement plan.
"Demand for advice is likely to be high where people have multiple pension schemes with different rules and benefits that need explaining and understanding before a decision can be made about whether they should be left where they are or consolidated into a single scheme.
“People with simpler needs or who can’t afford advice will also need help and the FCA needs to consider whether the development of personalised guidance services have a role to play in helping these people make the best decisions.
“Whichever route is chosen, the FCA must set out clearly how dashboard users can pass their information to legitimate parties. But, equally importantly, if anyone else is asking them for dashboard pension information then this is a red flag and they need to be alert to potential scams.”
More broadly, Vahey also noted that there is “not one, nor two, but three bodies involved in setting the regulatory framework”, warning that while all three have their areas of expertise, such a crowded approach could risk "diluting the focus on what should be the most important factor – the journey for the consumer”.
“There is risk that too many cooks contrive to serve-up overlapping or contradictory messages, or critical gaps,” she explained, continuing: “We need to have a single view of the customer journey to make sense of it, and understand where protections are needed.
“The launch of the pensions dashboards, is just the first phase of a bigger government project to roll out information to pension scheme members and it’s no secret government have aspirations for further developments.
“But to allow the industry to respond fully to these important consultations on dashboard design, we need sight of the government plans.
"Showing the industry a detailed future roadmap for dashboards will help providers understand where the government wants to take this project, and what needs to be put in place now, at the beginning, to protect pension savers.”
Industry experts also previously raised concerns around the lack of test dashboards, with the Pensions and Administration Standards Association (Pasa) suggesting that further user testing could push the dashboards available point until 2026.
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