“A roadmap is useful if it gets you to where you want to go and, from the AMNTs perspective, this one moves a fair way towards our preferred destination. We look forward to working with Government and the Regulator to take these multiple workstreams forward”, said Maggie Rodger, Co-chair of the AMNT.
We particularly welcome that this marshalled programme of activities which includes legislation, regulation and consultation starts from the member perspective. Working for a system that delivers the best for savers/scheme members and the economy as a whole is the position we have been articulating to Government and the Regulators. It is good that our arguments have been taken on board. Whilst there is a slight conflict of interest from the Government perspective, it is true that members will experience a better standard of living in a stronger rather than weaker domestic economy.
Surpluse sin DB schemes have been built up, both from employer deficit contributions and from members reduced accral and increased contributions over recent years and we are pleased to see that all references to DB surplus, whether being released or used to run on for longer term benefits are to improve the economy through being returned to sponsors AND to improve outcomes for members.
Investment mandation seems to be very difficult to reconcile with fiduciary duty so, whilst we would prefer it not to exist, it is good it is clarified as a "last resort" power – although of course that phrase will need further clarification.
We also welcome the wider discussions about adequacy and system inequalities for future generations through the next phase of the Pensions Review. This will take place in the "near future" and we look forward to participating fully in that process. Hopefully the “near future” means what it should as addressing this intergenerational challenge is a vital issue that should not be left to drift.
The proposed consultation on the governance of trust based schemes is welcomed. This has been left in abeyance for a few years now and it is good to see it back in play. The role of trustees and their duties to members, which underpin "the evolving pensions landscape" can be fully interrogated - and we look forward to taking an active part in the discussions.
Additionally, among the myriad of challenges being reviewed we are particularly keen to note that:
- The emphasis on the investment opportunities for larger schemes includes active ownership of assets. We hope the roles, not only of trustees, but of investment advisers and asset managers are included within this;
- Issues around DC are treated holistically - including both investment strategies designed for returns and value, with costs being reduced through consolidation and not a limited pool of assets, tackling the inefficiency of small pots. The clear emphasis that a DC pot at retirement is not a pension and that a scheme's job has not been completed on the day of retirement is welcomed.
- The proposal that there need to be clear default pathways for savers (with optout rights) which lead to a retirement income and the acknowledgment that the need for liquidity in the transition from accumulation into retirement is another inefficiency in the system. This could be met by CDC whole life schemes, or by existing DC pots being able to be defaulted into CDC for retirement incomes. It is good to see CDC, a development that the AMNT has long championed, take its place within the strategy and the roadmap.
- Alongside this responsibility for default pathways it is very helpful to seethe proposed development of targeted support to bridge the difficult space between guidance and bespoke advice for members.
- Amongst a host of other detail we welcome flexibility for the PPF to be able to reduce levies because they know they have the power to increase them again should there be a crisis.
AMNT also welcomes the additional announcement made today to allow retrospective confirmation of benefit changes (Virgin Media). This will help trustees enormously. Many of their discussions, including end-game considerations, have in limbo because of the potential for unexpected considerably higher liabilities without this legislation.