Making Sense of Pensions

David Davison

A concerted campaign to provide charities who participate in the local government pension scheme with greater flexibility in managing their risks and associated costs at last seems to have finally resulted in a positive outcome.

The recent publication by the Ministry of Housing, Communities & Local Government of a “Review of employer contributions and flexibility on exit payments” at last seems to offer some hope for charities seemingly trapped in LGPS.

The problem has always been that when charities run out of contributing members or look to exit LGPS a cessation (exit) debt will be calculated. This is carried out on a ‘nil risk basis’ which means that the liabilities, and therefore any deficit, is much higher than on an ‘on-going’ or FRS102 accounting basis. Many third sector organisations therefore find themselves with the Hobson’s choice of continuing to build additional unaffordable liabilities or an unaffordable exit payment. A number of organisations have recently found themselves driven in to insolvency by the weight of their pension liabilities.

In order to help with this the Government is now planning to amend the LGPS Regulations in two key ways:-

  1. Greater flexibility on exit payments – this would allow exiting employers to enter into agreements with LGPS to fund any cessation debt due over a period of time. This would allow uncertain pension liabilities to be turned in to a stream of fixed payments to be set over an affordable agreed term.
  2. The introduction of a Deferred Debt option – this would allow schemes to defer any exit payment and to permit the employer to carry on in the scheme on an on-going basis. The employer would retain all the same obligations to the scheme with future payments uncertain. However, immediate costs are likely to be lower and therefore much more affordable, allowing employers to better manage the risk of future benefits building up. Valuations would be carried out regularly and contributions adjusted if necessary.

These changes will be hugely welcome for many charities.

Fortunately, a number of Funds had already seen the common sense in making pragmatic arrangements to deal with exits however, to date they have been in the minority with the vast majority choosing to await a formal change in Regulation, which hopefully now should not be far away.

It is proposed that the new Regulations will provide Funds with a lot of discretion over how they are operated based upon their local experience. To ensure consistency and transparency funds need to consult with their professional advisers and to publish their approach in their Funding Strategy Statement.   

Given the imminence of the changes, the level of control this is likely to provide Funds and the value in dealing with further accrual as quickly as possible I would like to think that they should be prepared to engage with charities to look at their future options straight away, especially given that any solution is likely to take a number of months to agree. Charities should therefore engage with their professional advisers and the Funds to consider what approach would best suit them.

Article first published in Charity Finance Group Finance Focus – September 2020.

Matt Masters

With a focus on defined contribution schemes, a “call for evidence”, announced at Budget 2020, is seeking views on an unintended consequence in the way pension tax relief operates.  While not well understood, around 1.75 million lower paid workers, of whom women represent around 75%, could be affected.  The government is rightly concerned about this and keen to explore the issues to understand what options for change may exist.  Responses are invited by 11pm on 13 October.  However, is this simply diverting attention and energy from the bigger question?


Pensions were originally provided through workplaces, which meant tax relief on pension contributions could be made from income that had not yet been taxed (a “Net Pay” arrangement).  The introduction of personal pensions, however, meant another system for administering pensions tax relief was required, as pension contributions could now be made from taxed income (“Relief at Source”, or “RAS”). 

In a RAS scheme, the employer deducts only 80% of the pension contribution from the employee’s salary; the scheme then adds an amount equal to basic rate tax relief, which it then reclaims from HMRC. The key point to note is that the scheme adds this top-up to the employee’s contribution whether or not the employee is earning enough to pay tax in the first place.

How does this affect individuals?

For individuals in the basic rate income tax band or above, this only affects the paperwork.  However, for those who earn less than the personal allowance (currently £12,500), there is a real impact.  

By way of example, both John and Suzie earn £10,000 and have the same level of take-home pay.  However, Suzie has a larger contribution going into her pension pot:

  • Suzie is a member of a RAS scheme, and it is therefore assumed, for pension purposes, that she is at least a basic rate taxpayer.  So, while Suzie also contributes £800 into her pension pot, her pension provider claims £200 in tax relief from HMRC to top the total pension contribution up to £1,000.    
  • John contributes to his pension scheme through a net pay arrangement.  Over the year, £800 is deducted from his pre-tax salary of £10,000 and £800 goes into his pension pot.  This leaves John with take-home pay of £9,200.  Under this arrangement, John has missed out on £200 of tax relief.

As members of RAS pension schemes are granted basic rate tax relief of 20% on pension contributions of up to £2,880 a year, HMRC would top up a net contribution of £2,880 to £3,600.  Over an entire working lifetime, and assuming 3% net investment growth, the difference this makes could be worth more that £50,000, or the equivalent of four years’ salary.

A way forward?

The Government’s position is that any solution should be simple (easy to explain), deliverable, sustainable and proportionate.  This is no easy task.

For example, mandating use of RAS for defined contribution pension schemes, thus ensuring all low earners receive the top-up on their pension savings, would have significant appeal in terms of fairness and simplicity.  However, such a proposal would not be without its challenges, including:

  • potential significant investment in systems;
  • changes to scheme and payroll processes; and
  • a potential review of employment contracts to properly understand the impacts on employees.


 As we are all aware, the Exchequer’s purse has taken quite a hit these last few months.  Consequently, it seems to me highly likely that the question of whether the c.£40bn estimated cost of pensions tax relief is correctly targeted, or even required at all, will be firmly on HM Treasury’s radar. 

 I believe that encouragement is needed to get people saving for their old age, so they don’t simply fall back on State support.  Nevertheless, there is clearly an attraction to the approach of “I can reduce pension tax relief now and leave the fall-out to a future Government”.

That is not to say that a more fundamental review of pension tax relief distribution wouldn’t be merited, and one that is borne of cross-party long-term consensus.  For example, rather than providing tax relief at an individual’s marginal rate, equating this to a single rate (of say 30%) should have the effect of inducing basic rate tax-payers to contribute more to their pension arrangements while continuing to provide an incentive for higher rate tax payers to continue contributing at existing levels.  If there was some money “left over”, this could be used to help deal with smoothing over a change to a RAS approach for all.

Further information

Further information can be found in HM Treasury’s “Pension tax relief administration: Call for Evidence” document at:

Graeme Riddoch

Oranges and lemons

Fruit machines. Somehow, they seem like a relic of the past, consigned to damp and dark amusement arcades, or hiding in the corner of the pub waiting to swallow pound coins on the way back from the toilet.

Other than the big red play button, the only other feature I remember is the nudge buttons, which, with some random pressing, might line up the oranges and lemons to make you a winner. So, for me, nudges have always been associated with a bit of a gamble.

Changing behaviours

In the pensions world, there’s a lot of talk about nudging people in the right direction. That’s behavioural code for getting people to save a bit more.

Historically, the industry’s solution to nudging has used calculators to show accumulated funds and the impact of an increased contribution. So, for example, show the member that by saving an extra £30 a month they might get an extra £5,000 a year at age 65.

However, the idea that we can simply nudge people towards saving more for an uncertain future isn’t a winning strategy. It’s a start, but only part of the solution. If you don’t know what income you need for your retirement, you won’t be very motivated to save more.

Back to front

How about coming at the problem from the other end? Figure out what you want out of retirement, then work back. That can be tricky for people to visualise.

I recently read some interesting research where people were shown an image of their future selves. There are quite a few apps that will age your image. It seems that people have a greater propensity to think about their future when they see an older version of themselves. I’m 58 and I rolled forward 20 years; not pretty!

Staying on the theme of visualising the future, the PLSA recently developed their Retirement Living Standards. These are designed to give people a picture of what their expenditure could be in retirement based on a basket of goods and services. At the minimum level it’s £15,700 a year and at the comfortable level £33,000 a year for a couple. That’s outside London.

Expenditure is broken down into six broad categories. For example, in the comfortable bracket you change your car every five years and have three weeks’ holiday overseas each year. Breaking these figures down into the goods and services, frequency of holidays etc. allows people to visualise what they want out of retirement and what it might cost. Now we are getting somewhere.

Nudge up

This is all good and well, but how do we translate what we have now into what we might need in terms of a retirement lifestyle? I’ve seen a few solutions that attempt to do this, with varying degrees of success. A new product called Guiide gets close to bridging the gap. No, that isn’t a typo.

It’s a free to use tool that quickly allows you to input your savings and see how they could marry up to the income required for three different income levels, equating to a basic, moderate or comfortable retirement. It takes about five minutes to get to an answer and also pulls in the correct State pension figure.

I tried it myself and it’s easy to use. It tackles life expectancy by asking you to self-score from major health conditions to perfect health. It’s a bit subjective but there is only so much detail you can get to in what’s designed to be an easy to use tool.

It seems to me that simple solutions like this can add power to the nudge. If we can apply this to pensions and, for example, pre-populate defined benefit and defined contribution fund values, this would make them more accurate and easier for the member to use. Add into the mix the long-awaited Pensions Dashboard and we can surely help members see the bigger picture and plan for their future lifestyle accordingly.

And perhaps we can start lining up those oranges and lemons!

Colin Wheeler

Data, in the context of pension schemes, has probably never been talked about as much as it is now. And there is one question that trustees keep getting asked – is your scheme’s data “in order”? But just what does this mean?

To those not immersed in the nuances of the subject, it may appear that data is data – how can it not be in order? When it comes to pension schemes there are a multitude of reasons as to why this is the case. For example, if we consider a typical member who joined a scheme in the 1980s, some or all of the following may have happened, which could cause their data to ‘decay’ over time:

  • employer is taken over
  • scheme administration is outsourced
  • scheme records went from paper to microfiche to computer based
  • scheme has passed through several third-party administrators
  • member left and became a deferred member
  • member retired
  • legislative changes caused benefits to need tranching-out
  • member transferred-in a previous company pension
  • scheme was merged into another run by the same or a different employer.

The list of reasons could go on and on.

During all the above, the member’s data will have been handled, giving rise to the possibility of it being changed, correctly or not.

Administrators, trustees and sponsoring employers all have a part to play in the data journey. Administrators should be reporting on data on a regular basis and, when we say data, it should be data which is meaningful in the context of buy out, so conditional or scheme specific data. Trustees and sponsors have a duty to be taking these reports seriously and taking the appropriate actions coming out of these reports. Over the last five years or so, many data reports have been produced with little or no thought given to their eventual use, and have merely ticked a box for trustees. This is not good enough.

High expectations

Data will need to be in order for a number of projects, including member derisking exercises, full calculation functionality and member online portals. In this blog, I want to discuss specifically data requirements for buy out.

When trustees go to market to insure member benefits via a buy-out, or a buy-in for that matter, there is an expectation placed upon them by insurers that they will have taken the necessary steps to get their data in order. In turn, trustees will expect their administrators to have data ready to share with insurers when quotations are sought. It is this engagement between trustees, scheme sponsor and administrators which is key to data readiness, and which needs to be in the project plan and discussed at an early stage.

When reviewing data in preparation for buy out, it is necessary to think about the insurer requirements, and the issues which will have the biggest bearing on their pricing, and indeed whether they will want to quote at all. The capacity in the market is limited and insurers can afford to be selective over which schemes they want to transact with. A scheme which can demonstrate that it has taken the time to prepare for going to market is more likely to appeal to insurers than one which hasn’t. Schemes which have invested in data preparation will see this reflected in the price compared to a scheme with incomplete data

For a relatively mature defined benefit scheme, the typical data issues which are likely to need addressing could include:

  • Pensions payable to spouses or dependants on the death of a member. This is particularly the case with pensioners who commuted pension for cash, but the pension on death is based on the pre-commuted pension.
  • Tranching of benefits, particularly for deferred members where different revaluation rates will apply to different tranches, and indeed some tranches will have different minimum retirement ages.
  • Treatment of transferred-in benefits for deferred members. This assumes that the transfer-in can be identified in the first place!
  • Data on marital status of members, and for those married, their spouse’s dates of birth.

It is not just a scheme’s core data that insurers will expect to receive. Other data not needed for day-to-day administration, such as mortality experience and marital status, can help insurers when valuing liabilities. The more data a scheme provides, the fewer assumptions an insurer will be required to make, which will allow it to price with a degree of accuracy.

It is also worth noting that many schemes will have members with “special benefits”, which have been documented in individual member letters or augmentations agreed with the sponsoring employer. In such cases the trustees must ensure that all instances of those benefits are identified and reflected in the data on which insurers are asked to price.


This is an area that insurers will look closely at, to understand exactly how the scheme equalised retirement ages, and how this has been reflected in data. They will seek the usual legal evidence, but when it comes to data, they will expect to see the respective “Barber” periods of service tranched out separately, with clear guidance to show what retirement age applies to each.

For schemes that tackled equalisation by awarding additional service, or some other form of compensation, this needs to be clearly labelled in the data. We may be 30 years on from the original Barber judgement but it is still proving to be a thorn in the side of scheme administrators. And Guaranteed Minimum Pensions (GMPs), specifically inequalities arising from GMPs, are rearing their ugly head, but that’s another matter…

It’s not only data that is needed

As well as data, a scheme going to market will need to provide a comprehensive, and legally endorsed benefit specification. The insurer will use this to interpret the data and to test that the scheme is being administered in line with the rules. It is not uncommon for schemes to have specific practices which have evolved over the years and which are applied ahead of the scheme rules. So, if the scheme’s legal advisers are preparing a specification, it is crucial that the administrators review this to ensure that it represents what happens in practice. It then becomes a matter for agreement between the insurer and trustees as to the basis on which policies are set up. If policies are not correctly set up then the trustees may find that they are not fully discharged in respect of the members bought-out. 

So, there you have it, getting data in order is not a task to be taken lightly, or left too late. When it comes to buy out of benefits, preparation is the order of the day.

Brendan McLean

US equities have hit record highs. This is despite Covid-19 continuing to cause disruption and many countries facing a deep recession. Is this an indication of an asset price bubble?

Asset price bubbles are caused when prices rise above their fair value and can often be explained by behavioural finance theory. Common investor biases – such as groupthink, herd behaviour and the oft cited Fear of Missing Out (FOMO) – can take control of logical investment theory pushing prices higher. There are hints that this might be taking place now.

The key drivers of the recent rally in stock prices are:

  1. Government and central bank stimulus
  2. Technology stocks

Government and central bank stimulus

Governments and central banks have recently injected huge amounts of money into their respective systems, a lot of which has been pushed into assets and has caused prices to increase. Considering that Covid-19 does not appear to be disappearing anytime soon, it is likely that more stimulus measures could be introduced to keep the economies propped up, causing asset values to increase even further.

Central banks cut interest rates to support the economy throughout the pandemic. Whilst this will be of help to businesses and some individuals, it has caused asset values to increase. Lower interest rates reduce the cost of capital borrowing for companies and increase profits, which results in a higher stock price. Lower yields make it harder to generate a return, which pushes investors into riskier areas of the capital markets, such as equities, causing that price to increase.

Technology stocks

The main US equity index S&P 500 is currently up around 58% since it bottomed in March; however, much of this gain has been concentrated in several tech stocks which have benefitted from Covid-19 with people locked down and in need of technology. Key winners include Facebook, Amazon, Google (Alphabet), Apple and Microsoft. Apple was recently the first US company to hit a market value of $2 trillion, only 18 months after being the first to be valued at $1 trillion. Is this rapid increase sustainable?

Why investors might have cause for concern

Bubble popping

How much further can stocks rise? There are many challenging issues facing investors which could cause sentiment to change and, therefore, a sudden decline in prices, such as:

  • a Covid-19 second wave
  • US elections
  • US-China trade relations
  • high equity valuations (particularly in the tech sector)
  • recession
  • surging levels of government debt


Central and government bank stimulus has caused many assets to increase in price at the same time. However, could they all decline at the same time? This could cause traditional portfolio construction to fail with defensive assets not protecting capital. It happened in March 2020 and could happen again.

Many risks are hard to control, but it is important to be aware of these risks and have realistic expectations of future outcomes. Trustees should work with their advisors to review their investment strategy and ensure it remains suitable.

David Davison

Until quite recently I was blissfully unaware that common sense was regional, at least where LGPS is concerned.

Through advising third sector bodies in LGPS across the UK I get the chance to see variations in practice, good and bad. It is quite startling how widespread these variations are given everyone is working from broadly the same set of regulations but, unfortunately in some key areas good practice is hard to find.

A good example is in the divergence of practice in relation to how funds manage exit debts. Firstly, at a regional level, Regulation is in place in Scotland which provides funds with the option to suspend a cessation debt, which is a freedom not currently in statute in England & Wales. As per my previous Bulletin it is, however being consulted upon, though very, very, very slowly.

Fortunately, a number of funds can see the common sense in making pragmatic arrangements to deal with exits, recognising that it cannot be in anyone’s interests for admitted bodies to be accruing liabilities which ultimately they will be unable to afford. This is not only bad for scheme funding but I would also question if funds are properly discharging their responsibilities in relation to other employers, by exposing them to this level of unwarranted risk.

Some funds are issuing options papers which outline all of the options including a ‘suspension’ along with supporting details, which allows employers to make an informed choice. This seems like a sensible approach for all concerned.

Whilst ceasing further accrual can be seen by the admitted bodies as a desirable outcome in responsibly managing risk, something equally well recognised across all other DB provision in the UK, unfortunately this simple truth does not seem quite as obvious to some funds. They instead are taking a King Canute approach and just trying to avoid the rising tides around them and expressing the view that they couldn’t possibly do anything pragmatic without the specific Regulation being in place to allow them to act in a sensible way. They are much happier to see employers continue to build liabilities beyond their means, as recognised by the employers, rather than take steps to deal with the issue.

What I find interesting is how quickly action was taken to address a flaw in regulation around the treatment of surpluses, as this had a negative impact on funds’ finances, but we seem to be in an interminable loop of consultation on exits without any sign of implementation.

We’ve already witnessed numerous insolvencies directly as a result of LGPS pension participation (and indeed in other schemes such as Plumbing Pensions with similar legislation), and against a background of Covid-19 the outlook doesn’t get any more promising.

To those enlightened souls out there taking a pragmatic approach to this issue, I salute you. To everyone else including MHCLG, please get your finger out!

Matt Masters

I need to declare an interest. I’m a Scheme Actuary. I like to believe that I always provide a great service to my clients. But, how do I know it is always the service that they require?

I’m proud to be part of a profession that sets the highest professional standards of honesty and integrity. It goes without saying that your Scheme Actuary will be technically proficient, but is that enough? 

Question time

Even if they are getting the answers they want to hear, Trustees should feel able to challenge their Scheme Actuary. It is important to question the advice they receive so that they can satisfy themselves that their Scheme Actuary is genuinely giving the best advice for the specific needs of the scheme? Is your Scheme Actuary willing to have difficult conversations when required?

If your scheme has an Independent Trustee, they will be well placed to comment on the Scheme Actuary’s performance. They will have a view from across the wider industry, meeting Scheme Actuaries from many different firms with many different viewpoints and opinions. This will afford them a unique opportunity to compare and contrast different styles and approaches to similar issues as those encountered by your scheme. 

Is the same advice being given on different schemes, when perhaps a difference in approach is justified? Is there a current “flavour of the month” or latest “sales push” that can be seen?

My experience suggests that this is not uncommon in the industry and also, that there is a tendency to put less experienced Scheme Actuaries onto smaller pension schemes. Often, it is these very schemes where tricky issues arise and a more experienced head is needed

Rising to the challenge

Nobody gets it right all the time. Scheme Actuaries should be able to accept challenges and consider alternatives that might change or enhance their original advice and better suit the particular scenarios of your scheme. Challenge is healthy and might lead to more tailored advice to achieve better outcomes for your scheme members.

More than ever, a Scheme Actuary needs to be not only technically accomplished, but also an expert communicator. This is not easy when dealing with technical subject matter, and various different legislative and client specific requirements. But it is eminently possible if trustees and their Scheme Actuary engage in open and regular dialogue about the issues facing the scheme and the best way of resolving these.

Graeme Riddoch

I hit my favourite café for a half price coffee this morning. Eating out to help out in my own small way. As usual I was presented with a QR code to scan. That took me to a web page where I logged my name and phone number for tracing purposes.

QR codes have been around since the 1960s; as we come out of lockdown they seem to be everywhere. QR stands for Quick Response. Essentially, it’s a type of barcode which, when read by your smartphone camera will take you directly to a website, video or an app, without the need to type in a fiddly web address.

Old age thinking …

We’re now using QR codes to take DB members to our pensions app. It’s a simple experience. Open the camera, point it at the code and it takes you to the Apple App Store or Google Play.

I showed it to a trustee about six months ago. “Our members won’t use that” he said. Unfortunately, that’s an all too common reaction to new technology in the DB pensions arena. The membership demographic is older, the trustees are often older and they hold the perception that it’s only 20-year olds who use smartphones and apps.

Right now, if a DB scheme member wants to order food at a restaurant, they are probably using QR codes to access the menu! There is no doubt that the current pandemic has accelerated certain trends; one in particularly is the move to online.

Why wouldn’t DB members want the same sort of experience from their pension scheme as the one they can get from the retail and hospitality sectors, or indeed other financial services?

Alistair McQueen, Head of Savings & Retirement at Aviva, picked up on this issue recently on Twitter, further discussed in Henry Tapper’s excellent blog. The fact that 76% of people now bank online is clear evidence that there is both the appetite and capacity to transact digitally.

Breaking down barriers …

I’d go further. The Deloitte Digital Survey (UK edition, Deloitte Mobile Consumer Survey 2019) shows that in the 45-65 age group smartphone ownership is around 80%. Apps are now the way that most people access the internet.

Some trustees may be reluctant to adopt new technology but it could be argued that they have a duty to ensure that they do not act to the detriment of their members and are not the first barrier to better digital engagement.

The next barrier to getting members online is the registration process. Two factor authentication and remembering passwords are often cited as problematic. Experience shows that if you make something easy people will use it. For example, the QR code used to get to the app store is personalised like a password. That means a much quicker and easier process to register for the first time. In our initial testing, 99% of people successfully used the QR code to register.

Designing an app for smartphones means that we can work with their inbuilt security features, such as fingerprint and facial recognition. Once registered, a customer can access the pensions app like any other app on their phone.

From stone age to digital age to engage …

We are in the customer testing stage of the app which allows members to manage their benefits from their smartphone. Everything is possible, from a change of address to viewing benefits, to retiring. Initial feedback is that it gives members what they need in the way they want it.

The other benefit is the potential cost saving to the scheme. Our modelling suggests that as much as a 30% saving in administration cost is possible. Some or all of that could be passed onto the scheme. But only if we can get trustees to realise that “their members will engage”.

Matt Masters

We are now more than four months into something that has had one of the biggest impacts on our way of life in living memory. There is no clear historical precedent for the nature and scale of Covid-19. Nonetheless, previous pandemics and other crises can offer clues as to what to expect, both in terms of the potential impact on lives as well as on the wider economy. 

Two lessons of note:

  • There is a trade-off between economic stability and public health and safety. The more short-term economic pain people are willing to endure, the more lives will be saved; and 
  • Disasters often create permanent change, with the most affected areas of a country or an economy taking potentially years to recover.

So what does this mean for pension schemes?

We are starting to see differentiation between countries in their responses to Covid-19, with the Euro area and Japan fairing relatively well in virus control, the US and Latin America being less successful, with Canada and the UK somewhere in the middle. 

Nevertheless, based on the performance of Western stock markets over the past 100 years, market declines of the size recently seen typically take around two years to recover from (my colleague, James Sweetnam, wrote an excellent article in June 2020 looking at how long it takes to recover from a bear market). 

Whether you see this as good or bad news depends on your investment horizon. If you have a longer-term perspective, like many pension schemes, then a two or three-year hiatus need not be particularly unsettling. 

Ultimately, the aim of the game is to pay members their benefits over the long term, so panicking or making short-term decisions is likely to be counter-productive. Instead, speak with your advisers and focus on ensuring the right long-term investment and funding strategies are in place.  

Andrew Kerrin

Over the last three months we have experienced an unprecedented degree of uncertainty in our lives.  The question, “What’s coming next?” has been a frequent utterance, with very few (if any) sure answers being provided.  Gaining a grasp of what we will be doing next week, never mind next month, has often been difficult and unsettling.

Set against our uncertain, pandemic themed, world, the pensions industry now seems stable and straightforward by comparison – a testament indeed to the strange times in which we now live!  So, let us look to the main issues that occurred over the last quarter and then ask what is coming up next in our industry, in the knowledge that there are still events that we can respond to and plan for with more certainty.  That should make for a pleasant change from the ambiguity that has become our norm.

Spence have compiled our latest report, highlighting any actions that trustees and sponsors of pension schemes may need to take in the near future.  As you’d expect, the Covid-19 pandemic takes a prominent role in the report, including an update on the latest guidance from the Pension Regulator (TPR). However the report also looks beyond the pandemic, addressing important developments, such as the lightning-paced enactment of the Corporate Insolvency and Governance Act 2020, TPR’s recently issued Annual Funding Statement, the latest on legal sagas involving the Hampshire judgment and RPI/CPI substitution, and our own effort to answer that question, “what’s coming up next?”.

As always, we hope that this quarterly report can be of assistance. From everyone at Spence, we hope you continue to stay safe and enjoy the read.

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