(Almost)
every stakeholder in the pensions industry wants the same thing – better member
outcomes. Sponsors. Trustees. Regulators. Government. And, of course, members.
Why the odd and perhaps grammatically shady parenthesis at the start of the sentence? Well, unfortunately, operating on the fringes, or even lurking in the shadows, are parties less interested in the member outcome and more interested in personal gain. Sponsors do occasionally misappropriate members’ pension funds. Not all financial advice is given exclusively in the interests of the member. Scammers will leave retirement plans in tatters and jet off to sunnier climes without a second thought.
Governance is used widely across the industry to reaffirm how seriously we take our duties in support of better member outcomes. Quite rightly, we need to be rigorous in how we govern schemes in relation to matters of investment, risk, administration and member communications.
However, when it comes to protecting members’ interests when they transfer out of schemes, the industry is sometimes caught between a rock and a hard place. The rock being the individual’s statutory right to take their pension in a different shape or form, through a more flexible arrangement; the hard place being the industry’s desire to protect the member from making decisions that could have a detrimental effect on their financial future.
Perfect storm
To paraphrase a well-worn cliché, every cloud has the potential for rain. The significant fall in gilt yields over the last year has proved good news for defined benefit transfers with the average amount having risen substantially. However, the allure of pension freedoms, coupled with increased transfer values, may have brought on something of a perfect storm.
Members need to be aware that the decision to sail away from the safe harbour of defined benefit to the unchartered waters of pension freedoms will not always lead to an island paradise. They will need to first avoid the pirates and sharks.
The FCA has previously stated that defined benefit transfers are not generally in the interests of individuals and that advisers must provide compelling factors that mitigate the transfer. Nevertheless, between April 2015 and September 2018, seven out of ten transfers from defined benefit schemes were apparently approved by independent financial advisers.
The government has ruled that every individual with a transfer value of more than £30,000 must take independent financial advice before transferring from a defined benefit scheme. Without sufficient education and support to make the right decision for their own specific circumstances, members may not make the most appropriate decision for their future. The Work and Pensions Committee has said that the rise in defined benefit transfers is a ‘major mis-selling scandal’ and sees contingent charging – where advisers only receive payment when transfers go ahead – as a ‘key driver’ of poor advice.
Industry collaboration
Step forward the Pensions Administration Standards Association (PASA). It has launched new transfer guidance to help support members of defined benefit schemes to make better choices. PASA’s transfer guidance aims to improve the administrative efficiency of transfers, assist the overall member experience (both in terms of speed, and crucially, safety) and provide better communications and transparency. PASA’s DB Transfer Guidance is intended to make it easier for providers, advisers and members to see all the information they need to make better informed choices.
While many within and without the industry firmly believe that members are likely to be better off staying in their defined benefit scheme, the appeal of pension freedoms will often be too strong to resist.
Those members that choose to transfer need all the support the industry can provide. This new guidance is a good example of the industry working collaboratively, along with government and The Pensions Regulator, to help provide more support to members and deliver the better outcome (most) stakeholders are looking for.