Who will patrol the investment pathways?



Four different paths

Investment pathways are the big idea to help those getting to 55 and with pension freedom in sight. From August, people will be presented with four paths for their money. One takes them to a point when they can cash out their pension, another to an annuity, another allows them to draw an income and a final one lets the money build up and be passed on to the next generation.

Four paths and the job of patrolling them has been given to IGCs and to 60 new GAAs who will be patrolling the beat for the policyholders of SIPPs and insurers who aren’t offering workplace pensions.

There is guidance laid down by the FCA about what patrolling means, but if I’m encouraging an image of Dixon of Dock Green on his beat, then I’m probably talking to the right generation and instilling my idea of what the IGCs and GAAs should be doing



Thinking among IGCs I’ve been speaking to has generally been confused. Most IGCs think they have a responsibility to test the pathways themselves while one (David Hare) thinks the job is to test the working to make sure that the process which led to the pathways construction was robust.

As usual, I tend to side with David, if only because the job of providers is to provide and for governors is to govern and when governors start sticking their oar in. then accountabilities get confused, incompetent provision can come from a good process but that is not the IGC’s fault. If providers get lucky by getting it right after sticking their fingers in the air, the IGC should still “call them out” for not having a process.

How effective is the Bobby on the beat

The FCA say they will measure the IGCs

“The rules will require IGCs to include in their published annual reports their opinion on the adequacy and quality of the firm’s policies on these issues for the products that IGCs oversee, any concerns that IGCs have raised, and how providers have responded”

As the IGCs are paid to do their job, the FCA and the provider should expect a good job to be done. This summer the FCA are going to be reporting on the effectiveness of IGCs so I expect the 2020 reports to be particularly good. Each year there are less and less reports to read as insurers consolidate.

I learned last night that Old Mutual’s IGC will be swallowed this year by ReAssure. ReAssure are being swallowed by Phoenix who are the blue whale hoovering up millions of legacy policies like plancton. David Hare heads the Phoenix IGC and is probably the most important person in IGC-land.

I may call him Dixon

Evidence at the scheme of the crime

I found this crumpled page on twitter (I think it is the work of PC Mackay and DC Cumbo.


If the cost of managing a pathway is in this range, I think Dixon has some work to do.


dixon 2.jpeg

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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