The Office of Fair Trading (OFT) has published its report on the defined contribution (DC) workplace pensions market.
The report, which was launched in January 2013 to investigate whether the workplace DC pension market was working well for employees, concluded that there are problems with the market that may prevent some savers from getting value for money.
It has also found that employers, which have the responsibility to decide which pension scheme to choose for their employees, may often lack the capability or the incentive to assess value for money. The OFT said this problem has the potential to grow during auto-enrolment as smaller employers, with limited resources, are required to provide schemes for their employees.
The OFT has proposed five key recommendations, with agreement from the industry and The Pensions Regulator (TPR), to tackle these problems:
- Dealing with old and/or high charging schemes. To address the OFT’s concerns about old and high charging contract and bundled-trust schemes, the Association of British Insurers and its members have agreed to an immediate audit of these schemes, aimed at ensuring savers are getting value for money. This will be overseen by an independent project board.
- Dealing with issues with small trust-based schemes. To address the OFT’s concerns about small contract-based schemes, TPR has agreed to take rapid action to assess which smaller trust-based schemes are not delivering value for money. The Department for Work and Pensions (DWP) has agreed to consider whether TPR needs new enforcement powers to tackle the problem.
- Improving governance. To address the OFT’s concerns about lack of independent scrutiny of contract-based schemes, the ABI has agreed that its members will establish independent governance committees. Committees should recommend changes to providers and escalate issues to regulators where they see risks of poor outcomes for savers. It recommends that the key elements of this governance solution should be embedded by the government in a minimum governance standard that will apply to all pension schemes.
- Improving the quality of information available on costs and charges. The OFT recommends DWP consult on improving the transparency and comparability of information about the charges, including whether providers could disclose a single annual management charge and investment transaction costs, and quality of schemes in order to make employers’ initial choice of scheme easier.
- Preventing future risks of detriment. The OFT recommends DWP consult on preventing schemes being used for auto-enrolment that contain in-built adviser commissions or that penalise members with higher charges when they stop contributing into their pensions.
Clive Maxwell (pictured), chief executive at the OFT, said: “Automatic enrolment has the potential to expand and change the market for pensions in the UK for the better. Whether people are starting pension saving for the first time through automatic enrolment, or have already been saving for years, it is vital that they are saving in schemes that deliver good value for money.
“We have found problems in relying on competition to drive value for money for savers in this market. We’ve therefore worked closely with the government, regulators and industry to agree a set of measures that we believe are an important step in helping to ensure that savers get better outcomes.
“It is important, particularly given that automatic enrolment is already under way, that these measures are implemented rapidly.”
Aegon supports the introduction of independent governance committees to represent member interests. This will complement the protection regulation already offers members of contract-based schemes. The industry commitment, which Aegon helped shape, will create both urgency and consistency to making this happen across the industry.
We also agree that some older schemes would benefit from modernisation. Some have valuable features, but not all may meet today’s value for money standards. Others would benefit from technological advances. A detailed audit is the right next step to developing industry-wide value for money principles allowing for different features and charging approaches.
The OFT’s review was prompted by the surge in membership of DC schemes brought about by auto-enrolment. The industry commitments to the audit and to strengthening governance will go a very long way to giving members confidence they are being auto-enrolled into good schemes. The DWP’s charges consultation needs to weigh up the pros and cons of any further detailed interventions. Critically, we must not risk undermining the broader auto-enrolment agenda.
This report is very much needed and we agree with a lot of the analysis.
We support its proposals to tackle legacy issues, such as high charges, but want to be assured that the proposed audit of legacy contract-based schemes will be properly independent. We welcome the recommendation that small trust-based schemes are subject to scrutiny by The Pensions Regulator to ensure they offer value for money, as all pension schemes should be providing value for money, although we wish the OFT had gone further and recommended consolidation and the creation of super trusts.
We are particularly concerned that the report risks letting down pension savers who need someone solely on their side, with the independence and power to act in their interests, to make sure they get the best outcomes for their retirement savings. We would have preferred a clear direction that employers have a choice – they should either be prepared to provide governance themselves or use a master trust arrangement. The proposal to have governance as part of the provider risks fudging the issue and leading to potential conflicts of interest.
The report has set the future course with the right long-term principles to secure good outcomes for pension savers. But we feel that action is urgently needed now. With automatic enrolment underway we need to get things right now, not further down the line.
As always, the devil is in the detail. We now need a period of consultation on the OFT’s recommendations and a clear plan from the government as to how it would implement them.”
The OFT has called for the DWP to address three key issues: quality and value for trust-based schemes, especially for small employers, changes for legacy schemes with high charges to ensure they deliver value for money and strengthening governance for contract-based schemes.
The DWP should now take forward the introduction of a charge cap on the costs of pension provision to customers for both new auto enrolment schemes and legacy workplace pensions.
This is long overdue and will once and for all break the practice of charging small employers higher fees because they have fewer members in their pension scheme and will bring old legacy pension schemes into the modern low charging world.
We firmly believe that no employees saving in a workplace pension scheme should have to pay more than 0.5% a year of their retirement savings pot whatever the size of the scheme and that low charge should be available for legacy pension scheme members too.
The OFT has raised the issue of scrutiny of workplace pensions and called for improved governance.
We have long been aware as an industry that good governance will deliver better member outcomes for most members over the long term.
Further, we support the need to end the practice of higher charges for members who have stopped contributing, the so called deferred members, to subsidise charges for other members.
We have long been advocates of value for money pensions for the workplace and have avoided opaque charging structures such as active member discounts, consultancy charging fees and commission.
Pension savers should have a single charge, with no hidden fees, whether they are actively paying into the company pension or a classed as deferred members. That way they will be able to easily compare charges when they choose a pension or enrol into their company pension scheme.
If the DWP act on the OFT recommendations, around six million new savers, who are yet to be auto-enrolled into a company pension, will benefit from transparent charges and value for money pensions. That should help to restore confidence in saving for the long term, whether saving in a company scheme or in a private pension.
We would encourage the gvernment act promptly in the light of these findings to pave the way for low pension charges for all savers.
Today, too many people find themselves in old-style workplace pensions schemes which need updating. Auto-enrolment gives all employers the opportunity to review their existing workplace pension arrangements. We would strongly encourage them and their advisers to reassess old-style schemes and grasp the opportunity to ensure they put in place a scheme which meets the needs of their employees.
From the outset we welcomed the opportunity to work with the OFT on this review and we are supportive of the findings they have published today. As far back as 2001, we re-priced more than one million pension customers’ plans to a single annual management charge of less than 1%, with many paying less than 0.5%. We continue to focus on delivering value for money to our customers.
We must remember that charges are only one element of workplace pensions. Investment fund selection, fund performance and the level of employee and employer contributions can have the biggest impact on members’ final outcomes at retirement. So we need to ensure employees understand the key decisions which will influence the income they receive in retirement and that can only be achieved through clear communication.
The introduction of independent governance committees is a positive step forward and will help to instil greater confidence for savers, and we have already commenced our search for the independent members of our committee.
This is a hugely important time for the long-term savings industry. Standard Life will continue to ensure the pension products into which employees are enrolled provide value for money, while also providing them with good outcomes at retirement.
You know you are coming into political party conference season when the rumour mill starts grinding, but the widely expected recommendation of a cap on charges has failed to materialise. Instead the OFT has made a number of recommendations – looking to sort out past practice, as well as protecting future savings. To start with, the ABI has agreed to conduct an audit of old or high charging schemes.
For the future, the OFT has recommended that the government look at “improving the quality of the information available on costs and charges” for pension savers and to look at banning schemes which have in-built adviser commissions or active member discounts being used for automatic enrolment. Charges in DC schemes are coming under close scrutiny from several directions – the DWP proposed ban on consultancy charges came into force last weekend. We understand that the DWP had been waiting for the OFT’s recommendation before taking action on charges so I imagine we can now expect a consultation on charges in schemes being used for automatic enrolment imminently.
Improving outcomes for members in DC schemes is a key theme this year on pensions. Since the advent of automatic enrolment the government is rightly concerned to ensure that members are getting value for money. As a result, we have seen a dizzying number of initiatives and consultations launched in the last few months on workplace pensions, with everyone from the DWP to The Pensions Regulator and the NAPF getting in on the act. The OFT’s recommendations around governance concerns – that contract-based DC schemes establish governance committees, with minimum standards of governance embedded in legislation, and that the regulator assess small schemes to see if they are delivering value for money – are part of this wider drive to deliver value for money.
The OFT has made some very welcome observations on the workplace pensions market, namely on quality standards, charges and governance. We wholeheartedly support the aim of ensuring consumers get access to a good quality, good value, long-term savings product, which will help them achieve good outcomes in retirement. NEST was established to ensure all employers had a low charge, high quality scheme available to them to meet their automatic enrolment duties.
We also welcome the OFT proposal that all schemes, including contract-based, should have governance committees to help serve consumers’ interests. NEST has found that consumers are particularly reassured by NEST’s independent governance, which has members’ interests at its heart, and the fact we are run on a not-for-profit basis.
This is a damning report in many respects and is clearly looking to the pensions industry to put its house in order on charges with a view to pension savers getting much better value for money than they do at the moment.
The series of reforms it has recommended are in the main sensible and practical and include new powers for The Pensions Regulator – to monitor and where necessary enforce many of the changes to be made.
The OFT has rightly recognised the changed landscape brought about by the introduction of auto-enrolment and the need to ensure employers are provided with the necessary information about cost and quality in order to make their important choice of scheme on behalf of their employees easier. In this context, the regulator will be taking “rapid action” to assess whether smaller trust-based schemes are not delivering value for money and may need to be excluded. Further reflecting their concern the OFT has also asked the DWP to consult on preventing schemes being used for auto-enrolment that contain in-built adviser commissions, or that penalise members with higher charges when they stop contributing into their pensions.
It is encouraging that the ABI has accepted the need for better governance of current contract-based schemes, as well as conducting an immediate audit of high charging legacy schemes. Many of these old personal pension schemes, which in total contain some £30 billion worth of savings, have very high exit fees, trapping the plan holders in them and effectively preventing them moving their funds to more equitable arrangements elsewhere.
“Probably the only real surprise in the OFT report is that it has stopped short of recommending a specific cap on annual management charges – on the grounds that it would be too complex and problematic to implement. This is still open, of course, to the Government to introduce particularly in respect of default funds in auto-enrolment schemes and it is possible this will still happen in due course.
We welcome much of what is being suggested by the OFT today, although we do not feel they are being sufficiently radical in their approach.
Two much needed steps should be taken. Firstly it should be much easier to make pension transfers from old and poorly governed legacy schemes into large scale, modern and well governed schemes.
Secondly, policymakers should consider introducing a compulsory, standard, transparent, industry-wide charging structure so that consumers and their employers can make an informed choice rather than having to consider the implications of the multiple types of charges that currently exist in the market.
This will ensure competition on products and service delivery, rather than on obscure charging mechanisms, inevitably leading to the driving down of prices.
The OFT have released their report into DC pensions today. This was very much as expected. However, the governance measures proposed are weak and the missing link is getting people engaged with their pension savings. No one looks after your money as well as you do and the fundamental problem with the governance of workplace pensions is that someone else (your employer) is choosing your pension for you. Some employers do a good job but inevitably not all do. In the long run where we need to get to is to use the efficiencies of setting up group pensions through the workplace and then put individuals in control of their own retirement savings.
The OFT report brings fresh perspective to the issues around workplace pensions and I am encouraged that there is such a strong focus on governance and employee value, for trust and contract-based pension schemes.
Better member outcomes, specifically better pensions, are best served by striking the right balance between low charges, good governance, employer engagement and employee understanding. Much debate has focused on the first two, but the latter two are equally important if we are going to see SMEs successfully auto-enrolling their workforce and many more employees saving adequately for retirement.
I agree with the OFT that, with the right governance and market conditions in place, a blanket cap on charges may prove counter productive. It is notable within the report that the market has significantly reduced the price of workplace pensions over the last decade, well below 1% in most instances. We welcome the ABI review of pre-2001 ‘legacy contracts’.
In terms of active member discount, a number of our corporate clients using this charging structure may be disappointed at having to implement additional change to their DC schemes at an already busy time with auto-enrolment. There will also be some disappointment that they can no longer discount pension charges for their existing employees.
Commission has always played an important part in the SME market. As noted by the OFT, employers are “keen to minimise the cost of AE” and commission, applied within a responsible charging structure, can help to do this. It can also pay for employee services that enhance the understanding of often complex pension arrangements and encourage individuals to contribute more to their long term saving.
“The withdrawal of commission will only have a very limited impact on large employee benefit consultants, such as Capita Employee Benefits, but swathes of corporate IFAs may struggle to survive with its removal. These are the very firms who would otherwise be supporting the SME market through auto-enrolment and beyond. It would be ironic if a well intended reform such as the blanket removal of commission had an adverse effect on the success of auto-enrolment in the small to mid-market and impeded employee recognition of the importance of saving for retirement.
“Whichever way the DWP acts, we hope that employers are given sufficient time to manage the changes that they may need to make.
As DC becomes the dominant form of workplace pension in the UK we agree that quality benchmarks are important in delivering good outcomes for members, as well as reassurance for scheme sponsors, particularly smaller employers who do not have ready access to advice. This is another step forward in rebuilding the consumer’s trust in pensions.
We are encouraged that the OFT recognise that charges are not the only measure of value for money and that scheme quality is equally important. We also welcome the acknowledgment of the importance of the decumulation phase of DC even though this was out of scope of this report.
The OFT study is an intelligent, well-structured report and the conclusions echo elements of JLT’s recently released white paper ‘Achieving the 21st century pensions settlement’, which introduced the concept of ‘Active Intervention’ powers for governance bodies in contract-based arrangements and ‘tariff checks’ for pension scheme providers to inform members when they might save money by moving their pension savings.
We firmly believe carefully planned and well-governed DC schemes can offer value to both employees and employers. We support the messages coming from Steve Webb and the OFT in relation to the continuing overhaul of any legacy DC plans that are not providing value for money for members and are not subject to appropriate governance.
The governance committees that are being set up to manage contract-based schemes should follow the new Code of Practice coming into play for occupational plans in November. The new code’s focus on value for money, appropriate investment options and good outcomes for members goes hand-in-hand with the OFT recommendations.
In our view ‘small’ does not equal ‘dysfunctional’, nor necessarily ‘poor value’, so whatever comes out of these recommendations needs to accommodate the good value, well governed small trust-based DC scheme. That said, we do see the master trust market being able to deliver value through scale, where employers are less able to support a standalone structure, but still want to ensure that there is some employer sponsorship through a trust structure.
Pensions should do what they say on the tin – provide a lifetime income in retirement that is fair value relative to the contributions paid. Unfortunately, trust in the UK pensions industry’s ability to deliver this has been severely dented over the years.
The success of auto-enrolment will depend on the ability of providers to build trust and earn confidence among their members. If members don’t trust their provider and they see their hard-earned pension pot being eaten up by high charges and their fund performing poorly, the motivation to stay enrolled will be sorely tested.
To help employers select a scheme that is fit for purpose and is going to deliver on its promises to members, we support the OFT’s recommendation that the DWP consults on improving the transparency and comparability of information about the cost and quality of schemes.
The Cass Business School in its Caveat Venditor Report estimates that there are over 205,000 DC schemes in the UK market. This is a ridiculous number and it is unrealistic to expect employers to have the knowledge or ability to sift through these schemes to find the right one for their employees.
Giving employers the ability to easily compare the schemes on offer in the market will go some way to helping steer them through the pensions minefield. It’s important to recognise that some good work has already been done in this area with the establishment of the NAPF’s PQM Ready standard. Schemes with the accreditation are recognised as being well-governed pension schemes with low charges and good member communications.
More broadly, the growth of master trusts in the industry is addressing many of the concerns raised in the OFT report. Typically, master trusts have lower charges and better governance than traditional contract-based schemes, although more needs to be done to ensure that master trust standards are protected and maintained.
Buck welcomes the findings of today’s OFT report. Automatic enrolment is an important step in addressing the retirement needs of UK citizens, recognising that the state cannot afford to make provision itself. However, to make the system work effectively, it is essential that the money invested generates decent returns.
In the case of smaller companies, which have yet to reach their staging dates, the OFT have rightly identified that the responsibility of selecting a scheme lies with the employer whose focus, in some cases, may not exactly align with those of individual members. Without access to good advice, such employers may not be in a position to make a suitable assessment of the quality and appropriateness of the schemes on offer.
With the abolition of commission from the funds invested in the scheme, as a means of payment for that advice, employers will find themselves faced with having to pay fees, which many will be unwilling or unable to do. Therefore, much of the regulatory focus is on making sure that any pension scheme product available in the market is of a minimum standard. Today’s OFT report builds on this focus on value for the member.
This is a reasonable approach and will help to address the “advice vacuum”. For smaller employers, this will help to reduce the amount of management time and cost that an employer or trustees will have to expend at the scheme level.
The need for a scheme like auto-enrolment has been apparent for many years. The Forum has supported the timetable for its roll-out, ensuring small businesses have the longest time to prepare for this cost pressure.
What the OFT highlights today is the difficulty many such businesses face in ensuring that the scheme it picks is a good one for its employees. Its recommendations should help to ensure that poor schemes are weeded out and that it is easier to compare the cost and quality of pension schemes. It is also essential that businesses seek out the advice and support available from business organisations like the Forum and specialist advisers to help navigate them through the pensions market.
Equally as important as the OFT’s report itself is the pension minister, Steve Webb’s, pledge to act on the recommendations in short order.
While assessing what constitutes good value can be largely subjective and extremely complicated whatever the size of the scheme, it is nevertheless true that some employers – particularly at the smaller end – lack the necessary in-house expertise to determine the value being provided by their pension pot.
This problem certainly needs addressing as a matter of urgency, as auto-enrolment heralds millions of individuals entering schemes, some of which will not be fit for purpose. One solution would be the creation of more and larger pooled pension funds, which combine the assets of many smaller schemes to create pots of significant scale which are then managed on an effective and efficient basis.
The OFT warns that commission structures can result in the member paying the adviser through their charges without realising it and can deter advisers from recommending better value schemes if this affects what they get paid.
It’s surprising that policymakers have not focused on this sooner given how much attention has been paid to charges in pension schemes. By the time that any ban comes into effect, automatic enrolment will have been up and running for well over a year, during which time significant amounts of commission will have been paid. If the government only stops new members being enrolled into commission-based schemes, more commission could still be paid when people who have already been enrolled increase their contributions in future.
Commission is hundreds of times more prevalent than the new style of consultancy charges that the government stamped out more quickly – the irony was always that most of the charges that ended up with consultants were not ‘consultancy charges’. It can also be the root cause of the high charges for former employees that the OFT dislikes; this is one way in which pension providers can recover the money they paid out.
It’s important to ensure that other payments advisers seek from providers are not allowed to drive up charges in workplace pensions or compromise the independence of advice. The Financial Conduct Authority said this week that these can include subsidised IT systems, payments to advertise in advisers’ magazines or to meet their management, and funding for overseas seminars that advisers could bring their partners to. We’d also encourage employers to satisfy themselves that places on advisers’ panels of preferred providers have not been awarded on a pay-to-play basis.
People who never consider changing their bank account are unlikely to drive a hard bargain with their pension provider. Employers and trustees are more likely to be informed buyers and many already do this job well.
Employees should be able to feel confident that their employer’s adviser is getting paid to help them and not to help the pension provider. Often, they already can. However, the OFT found that some advisers’ interests have not always been aligned with those of scheme members. It said that commission-based advisers were more likely to switch providers when this could still earn them extra commission and are now reluctant to do so.
We support the OFT recommendations for the DWP to consult on key issues affecting the pensions market and Friends Life will play an active role in these consultations. It is essential that we, as an industry, improve engagement with consumers to ensure that they save enough to provide for their retirement, so any initiative aimed at delivering a better outcome for the consumer is welcome.
The OFT’s report is very measured and well thought through and, pleasingly, there is no knee-jerk reaction in it.
The cost to employers and members was always going to be a principal focus of the report. While the much-flagged charges cap has not materialised, the fees members pay remain under the spotlight.
It’s encouraging that the evidence shows the charges levied on new schemes has fallen from 2001 to 2012 with the average annual management charge (AMC) reducing from 0.79% to 0.51%.
Although this is not the same as charges having fallen across the board, it’s an indication that the market does deliver competitive value outside of explicit regulatory enforcement.
The overall message has to be that, while important, the level of charge is not the only factor to be considered. If an individual saver pays higher fees, but gets a better return, can see where those fees are going and knows those fees are being regularly monitored by their employer, they are likely to be more satisfied with their pension. That is why key tenets of the report are value for money, transparency, comparability and good governance.
In the lead up to the issue of this report there was much speculation about the application of a cap on the annual management charge. However, the OFT has recognised that this simplistic approach could have had a detrimental impact.
All companies quote AMCs, but they don’t all include the same range of charges making them difficult to compare. The OFT supports the ABI’s transparency initiative and makes some recommendations towards it.
Importantly, the OFT is not asking for all costs to be included in an AMC, so investment transaction costs, e.g. stamp duty or broker charges, can be charged separately. The rationale is that these costs are driven by the fund manager’s view about the need to trade investments in the best interest of members.
“If these costs were hidden in an AMC, they may result in a disincentive for the manager to trade. However, the OFT is calling for visibility of these costs and is suggesting that good governance should keep them in check
The report finds that defined contribution schemes are not delivering value for money for pension savers. However, this could prove to be a fallacy; historically there isn’t evidence to verify that lower charging schemes perform better than higher charging schemes – the performance of the fund must be taken into account alongside management charges. There needs to be much more emphasis on helping employees understand about investment risk, the charges associated and the potential outcome in later life.
While it’s really important that pension scheme members get value for money, in addressing current charging complexities, government needs to be careful not to damage confidence in an already-fragile pensions sector. This is vital given the major auto-enrolment challenges ahead in the next few years, with 30,000 companies having their staging dates in the four months after April 2014 alone.
We already see a shortage of capacity to cope with the tsunami of stagers next year and thousands of smaller companies are dependent upon advisers and pension providers working closely together to ensure that they don’t default on these rigid dates. The ban on consultancy charging earlier this year has already reduced the auto-enrolment consulting capacity available.
In addition to recommending governance of pension schemes by ABI members, employers have equal responsibility to drive transparency by establishing due diligence of their group pension scheme through jargon free pensions governance and support for employee pensions planning.
Employer and employee engagement continue to be fundamental to the success of auto-enrolment. The recent LSE research we commissioned found that a clear, and recurring, strategy of communication and open dialogue significantly increases an employee’s engagement level with their workplace pension, and improves personal contribution levels above 4%.
The emphasis on pension reform now needs to move on quickly from just focusing on low charges to addressing the bigger picture of achieving better pension outcomes for Britain’s savers through sustained and relentless pension education.
The problem is that no-one has ever actually defined what ‘good value’ or ‘good member outcomes’ actually are. As such, it seems premature to conclude that all older style contracts appear to be poor value without first defining, what ‘good’ or ‘good value’ actually is.
Similarly, I think it is important to prioritise the factors determining member outcomes. Contribution adequacy and investment performance are far more important than member charges, albeit we wholeheartedly agree that excessive pensions charges cannot be justified.
But on the issue of charges in isolation, while they are still a factor in determining member outcomes, it is dangerous to assume that all higher charging contracts represent poor value for money. Many older contracts will have guaranteed returns relating to with-profits bonuses, or possibly guaranteed annuity rates meaning that to provide such benefits in the first place, the charges are correspondingly more expensive for the consumer. While these contracts are now the exception rather than the rule, it is important we don’t unravel important benefits to those who have paid for them.
As a pre-cursor to automatic enrolment, let us not forget that, while stakeholder pensions legislation was a total failure in respect of getting employees to save in to pensions, it was a spectacular success in respect of harmonising legacy charging structures towards a single and fair annual management charge (broadly 1%) across the entire pensions industry.
Where the DWP and The Pensions Regulator are potentially seeking to impose tighter controls on how pension schemes are governed and monitored going forward, it is also important to acknowledge the cost of this governance must be met from somewhere.
So, while we agree in principle to the findings of the report, there is something of a history lesson in to be done in terms of how we arrived at our current situation before setting out any path towards resolution.
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