There isn’t a charges war Tom, if there was it would be a phoney war. For a war to be going on , there have to be people bothered to fight. Frankly the only people bothered appear to be the platform providers who could see big inflows if there was a way to unblock the legacy pipeline.
that’s not quite true – I’m bothered- wearing my “let’s get people back in love with pensions” hat and Steve Webb is clearly bothered- otherwise he wouldn’t be going on about small pots and Gregg McClymont is bothered , otherwsise he wouldn’t be winding up Ed Milliband to get all militant about this stuff.
However it is not good enough just to blame insurers and tell them to pick up the bill. That’s not how it works.
People entered into a contract with the insurer to get a service over time, typically a long-time. People have paid what they signed up for. The product may not have performed as they wanted it to but that’s another issue. People are paying a price for a product which is now generally cheaper. They have two choices;
- To stick with what they’ve got
- To cut and run, crystallising yet to be charged for charges as an exit penalty.
The exit penalty is there to recover costs that the insurer has already incurred (eg the payment of non-recoverable commission). We cannot force insurance companies into discounting costs just to keep the politicians , pension experts and consumerists onside.
If there had been an identifiable breach of contract that would b e different, but delivering below expectations or market norms or whatever is not “breach of contract”- it’s unlucky.
It’s a question of fairness we need to be fair to insurance companies – we also need to be fair to people about how these exit penalties are calculated.
If Aviva are looking to review their exit penalties – and it’s good that they do so – then they need to start talking to other insurers in the same boat. The way insurers do this is via their trade body, the ABI.
This is what has got to happen. All the pricing actuaries of the insurers selling these “legacy products” need to sit down in a darkened room and agree a common set of assumptions, these assumptions need to be realistic and be based on what has happened in the past and what is likely to happen in the future. This means actuaries!
When they have come up with their common assumptions on how to calculate exit penalties, they need to tootle along to GAD in Chancery Lane and get the Government Actuary to sign off their way of doing things.
The next thing that needs to happen is that the FSA, the Pension Regulator and all the pseudo regulators like the PMI, NAPF et al, come behind this methodology and consider DC pension transfers calculated this way “kitemarked”.
Kite-marked transfer values should be taken without demur, with no comeback on advisers that make this happen. Individuals chosing to transfer on an execution-only basis would be able to do so. The onus would be on the company offering the transfer value to flag any special features (with-profits terminal bonuses, guaranteed annuity rates and loyalty bonuses being given up.
None of this is rocket science but it is an answer to Steve Webb‘s problems with small pots, it does mean advisers can get on with consolidating people’s pensions and those who reckon they can manage their finances themselves, can do so without an actuarial qualification.
So pack in all this talk about amnesties Tom, let’s pursue fairness and a course of action that’s got a reasonable chance of delivering results in the next couple of years.
We can’t make these charges go away but we can at least make them fair, properly disclosed and capable of inciting action among a general public sick to death of not knowing what to do and how to do it.
Related articles
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- Send in forensic actuaries to sort out these “rip-off” pensions! (henrytapper.com)
- “Pensions people can trust” – a proper kick in the nuts. (henrytapper.com)
- “The first cut is the cheapest” – transferring legacy pensions (henrytapper.com)
- Too important to hide;- why the Government has to investigate pension default charges (henrytapper.com)
- Is Steve Webb at war with personal pensions? (henrytapper.com)
- Pensions minister Steve Webb: ‘Scrap penalties to ditch dismal pension funds’ (telegraph.co.uk)
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- New pensions code of conduct ‘fails to throw light on opaque charges’ (guardian.co.uk)