What’s all this pensions VFM malarkey then ? Find out tomorrow at 10.30 am!

It’s only the pension’s consumer duty – innit!

I’m still of the view that the DWP are onto a winner with this VFM Framework. But my list of questions just got a bit longer as I spent the weekend watching the racing reading the DWP’s consultation

Which is 95% good and 5% bad , but could be 100% good with a bit of – well – consultation.

Anyway, you’ll see what I mean when Des Healy and I sit down and have a good chat about the new questions that I have – as well as the old ones that I bored you with last week


  1. There seem to be two ways you are thinking of assessing VFM – one using a step by step approach which gives quite a lot of discretion and the other three test against thresholds set by DWP, which doesn’t give much discretion. Am I reading this right?
  2. And can you explain how each would work?
  3. Is it “either or” or do you see both types of assessment working together?
  4. You want to get a value for money assessment for quality of service by splitting out the cost of service from the cost of investment in the AMC – can you explain this?
  5. and perhaps explain concerns you seem to have about how this could work (or perhaps not work)?
  6. The paper worries about employers subsidies of the AMC. Can you explain why this is a concern?
  7. And how you want to solve your problem?
  8. You are keen to see the VFM reports published and for VFM assessments to be compared, can you explain the two ways you are thinking of doing this?
  9. Do you have thoughts on the pros and cons of each?
  10. Can you explain the reasoning for leaving ESG out of the VFM framework?
  11. Do you think that optionality at retirement will become one of the factors of quality of service in due course?
  12. How have you found working with the FCA and TPR on this?
  13. You kicked this off under Guy Opperman , has Laura Trott made a difference to the consultation?
  14. What are the timescales for the delivery of the VFM Framework?
  15. What is the employer to do about VFM assessments for their scheme?
  16. Who will be able to conduct one of these assessments – will they need qualifications?
  17. What benchmark should be used? Other schemes or a DWP defined benchmark?

That’s enough questions (ed)


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About henry tapper

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