What’s the point of disclosure if it never gets seen?


Jo Cumbo has been writing some interesting pieces ( https://www.ft.com/content/787ad06e-7e7b-11e6-bc52-0c7211ef3198)  on how what we need to know about our retirement savings can be delivered to us as we want it. We get our shopping or our meals to our door if we pay Ocado or Deliveroo and – considering how much we pay for our pension plans, it’s not too much to expect the terms and conditions of our pension plans to be ready to read on our iphones.

Scottish Widows and Aviva, who are leading the charge into digital comms, are both quoted in Jo’s article. It would seem that the problem is not just with their lack of digital savvy but in the Regulator’s depleted digital toolbox.

By coincidence (or possibly as a result of mystery shopping from Jo Cumbo?) we received this webchat message on www.pensionplaypen.com yesterday (sic)

We have paid for a scrutiny report that listed pension schemes suitable for our company. I just spoke with Aviva which are interested in eventually signing up with them however we would like to read their terms and conditions before hand. They advised us that you will be available to send us the terms an conditions.


An employer, doing do diligence on behalf of staff, should not need to visit a website, make a phone call and then get a letter to read what is a piece of static text. Something is very wrong when what the customer wants is turned into a game of pass the parcel.

Why insurance companies cannot disclose the key features of their products directly to people’s PCs – or better – their smartphones… why we still live in a world where insurers and intermediaries play pass the parcel… why we want to put off organisations trying to help staff to save – is a mystery.

There does not need to be a rulebook about this. There needs to be one rule. The rule is that if it is in the customer’s interest to have a request for information granted, it should be – in the most convenient way for the customer.

If there is any legal dispute about the matter, this rule should be applied. Disclosure should be accurate, speedy and helpful and that’s it.

Lawyers -get ready!

I would like the compliance departments of the workplace pension providers to take some time out and invite in some employers choosing workplace pensions and some “eligible jobholders”, some “entitled workers” and some “uneligible jobholders” and ask them what they wanted to know and how they wanted to see it.

The FCA are about to make some statement on this, probably as a result of one of the many consultations on the go at the moment. If anyone from the FCA is reading this and would like some introductions, I would be happy to link them to those who make requests like the one above.

This is not a marketing issue, it is about customer care. It is about restoring confidence in the pensions we use and it’s important.

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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2 Responses to What’s the point of disclosure if it never gets seen?

  1. Phil Castle says:

    In my opinion all T&Cs, KFDs, KIIDs etc should be published and downloadable from a providers website based on a simple search using year of issue, document ref (often on the back of the paper document) and so on.
    What infuriates advisers is providers who can’t even find their own documents when being an Independent adviser, we have to deal with multiple providers different way of sourcing and holding info. Trying to get a copy of a historical policy T&C for a new client is almost impossible and it should not be in this digital age.
    It has taken several months sometimes to get copies of historical documents from the likes of Scottish Widows.

  2. Adam Saunders says:

    It’s interesting to look at the websites of the pension companies that are listed on The Pension Regulator’s site. Most of the websites essentially say ‘need to auto-enrol? It’s dead easy with us!’ And that is more or less the extent of the information available to make a choice on. Phil’s suggestion about downloadable information seems so obvious that it’s hard to see why that’s not done as a matter of course?

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