Pension Dashboards – time to respond!

At a recent PPI seminar, Laurie Edmans reminded us that he had been responsible for helping Government nearly deliver combined pension forecasts in 2004 – nearly 15 years ago.

I wrote to Laurie thanking him for chairing an excellent event and he wrote back – responding to my comments on dashboards – much of which are included below.

Good luck with the minister etc – as long as something gets going – and ASAP!

Here’s the immediate AgeWage response – which like the response to the CDC consultation will evolve. Please feel free to mail me at with your thoughts. I’m not right, but I’ll be a lot righter for your input!


Dasboard response

List of questions for consultation

Wider benefits of a dashboard

I. What are the potential costs and benefits of dashboards for:

a) individuals or members?  

The PPI tell us that £20bn is missing – lost to consumers because they cannot find their pensions, if this money can be reunited with consumers through a properly operated pension finding system, the dashboard will have succeeded. 

The proposals for a single pension finding service are too vague to be costed. To find pensions, there needs to be a way to interrogate the many databases of insurers , SIPP providers and the in and out of house administrators of occupational schemes. A manual search will be very costly, a digital search means having limited access through an API (application programming interface). The cost of APIs can be reduced by the Government standardising the API.  

b) your business (or different elements within it)?

AgeWage sets out to assist, guide and equip people for their financial later life. To assist people we need them to find their pensions. Most people can find their pensions themselves but those who have trouble often give up and disengage.

To do the guidance and to equip people for the future we need people to engage. If the pensions dashboards help people to engage then they will help our business. But if people have to wait too long just to find their pensions, they may lose interest. This could be bad for business.

Architecture, data and security

II. Do you agree with:

a) our key findings on our proposed architectural elements; and

b) our proposed architectural design principles? If not, please explain why.


The proposals mistake the way technology has progressed. We no longer live in a world of centralised databases that store data on everyone. Data is spread around. There are ways to find data- they include data scraping, a technique in which a computer program extracts data from human readable output coming from another program. Data is highly problematic, it should not be relied. Instead we need to access data via APIs to databases.

The Government has a role to play here; it needs to set up a system of verification. This is hinted at in the paper but not explained. 

The Government needs to create a common API protocol to make it easy for organisations with databases to allow pension finders with verification credentials to find people’s data and get it to dashboards.


Providing a complete picture

III. Is a legislative framework that compels pension providers to participate the best way to deliver dashboards within a reasonable timeframe?

Knowing that compulsion is coming may have some advantage to some organisations. But knowing that it won’t be coming for at least five years (the timetable that the paper sets out), will not be getting those with the data particularly agitated.

We live in a world where failure to meet consumers reasonable expectations is met with immediate reputational damage. Social and conventional media picks up on it and organisations suffer commercial damage. This is more of a risk than the threat of Government intervention in a few years time.

Actually compulsion is less important than the societal need to treat customers fairly. No new legislation is needed to enforce this societal need, it is policed and enforced by consumer organisations and by the tough justice of the media.

IV. Do you agree that all Small Self-Administered Schemes (SSAS) and Executive Pension Plans (EPP) should be exempt from compulsion, although they should be allowed to participate on a voluntary basis?


V. Are there other categories of pension scheme that should be made exempt, and if so, why?

We would partially exempt Defined Benefit schemes from having to display their wares on a dashboard. We know from transfer requests that there is no end to the granularity of detail that can be requested. I would suggest that all that needs to be requested of a DB scheme is the prospective pension at scheme retirement age.

Implementing dashboards

VI. Our expectation is that schemes such as Master Trusts will be able to supply data from 2019/20. Is this achievable? Are other scheme types in a position to supply data in this timeframe?

Most master trusts should be able to supply data pretty well immediately. Some have built API layers into which external organisations can plug. Master trusts should be able to advertise themselves “dashboard ready” – assuming they have built and tested the API for pension finders to use

VII. Do you agree that 3-4 years from the introduction of the first public facing dashboards is a reasonable timeframe for the majority of eligible schemes to be supplying their data to dashboards? 

The data architecture is wrongly considered. Schemes do not need to deliver data as you would send a letter or email, they need to make their data for those with verification to get the data. This is what we mean by open pensions.

Should it take 3-4 years (from the point where the non-commercial dashboard is ready) for provider databases to  be open for inspection –

No. Though some data is in bad state (and needs to be cleansed), it is better to get on with things now and make it possible for those who have got their act together and are dashboard ready to go first. 

Keeping a simple dashboard of those ready and those not would be a useful function of Government. Testing that organisations are dashboard ready would be another useful function. We would like to see a dash for the dashboard – rather than this distant time horizon.

VIII. Are there certain types of information that should not be allowed to feature on dashboards in order to safeguard consumers? If so, why? Are there any other similar risks surrounding information or functionality that should be taken account of by government?

The Data Protection Act 2018 allows anyone the right to access their data in a machine readable format. There may be exceptions to this (where the data is a matter of national security for instance) but data relating to your pension – including the timing and incidence of contributions , fund value, prospective pension at SRA and so on – fall within the scope of DPA 18. There is nothing that should stand in the way of someone’s data access request.

IX. Do you agree with a phased approach to building the dashboard service including, for example, that the project starts with a non-commercial dashboard and the service (information, functionality and multiple dashboards) is expanded over time?

No. There is no sense in this. There is no such thing as a non-commercial dashboard. The Single Financial Guidance Body (SFGB) will be run as a business, as were TPAS and MAS. To suppose that SFGB will not consider its goals as targeted on delivery, is to suppose that SFGB will be run on a non-commercial basis.

SFGB is not for profit but so are many financial services companies (Royal London and LV, People’s Pension and NEST for instance. The building of the technology to make dashboards work should be – as the title of the consultation suggests – a matter of “working together for the consumer”.

X. Do you agree that there should be only one Pension Finder Service? If not, how would you describe an alternative approach, what would be the benefits and risks of this model and how would any risks be mitigated?

No. There should be only one protocol for finding pensions, one verification regime, one API. But any accredited pension finder should be able to get the data. Accrediting a pension finder service is not going to be hard. The process has been done with “Faster Payments” and can be done with “Pension Finders”

Protecting the consumer

XI. Our assumption is that information and functionality will be covered by existing regulation. Do you agree and if not, what are the additional activities that are not covered?

The dashboard is doing nothing new, will show nothing new and needs no new regulation. All that should be new is the speed at which data is delivered, this needs the creation of data standards, 

As mentioned above, the accreditation and oversight of pension finders will need to be formalised and we recommend that an independent organisation – the Competition and Markets Authority be commissioned to do for pension what it did for banking. Essentially we see pension dashboards as an extension of open banking regulation. 


Accessing dashboard services

XII. Do people with protected characteristics, or any customers in vulnerable circumstances, have particular needs for accessing and using dashboard services that should be catered for?

It is inevitable that some people will struggle to use pension dashboards. Not everyone is or wants to be computer literate let alone phone literate. Simple matters like using a computer keyboard are beyond some people. Some people still have trouble accessing the internet. 

All of these issues should not prevent us getting on with it. 


XIII. The department has proposed a governance structure which it believes will facilitate industry to develop and deliver a dashboard. Do you agree with this approach? If not, what, if anything, is missing or what workable alternative would you propose which meets the principles set out in this report?

Applying 20th century governance to 21st century problems is not a good idea. I see no reason why the governance structure proposed in this document will be fit for the present let alone the future. We can look at open banking for answers. Build the service and build the governance service to meet the problems that arise. Do not build the governance in anticipation of problems that may never happen.

A greater agility is needed in the conception of dashboard governance.

Costs and funding

XIV. What is the fairest way of ensuring that those organisations who stand to gain most from dashboard services pay and what is the best mechanism for achieving this?

The consumer pays, that is the rule of business. The key to the dashboards success is for the consumer to pay as little as possible. That means keeping levies down by managing the finding of pensions and their digital display as effeciently as possible.

The idea that you build an infrastructure over years before launching is out dated. You test and build as you go along and discover your costs as you progress. You find out your users and apportion costs accordingly. You don’t determine cost apportionment till you know your costs and your users.


XV. Do you have any other comments on the proposed delivery model and consumer offer?


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Contingent charging – “commission” by another name?

ifa commission

Along with Al Rush, Jo Cumbo , Michelle Cracknell – I was interviewed yesterday by the BBC Moneybox team for a Christmas special on pension transfers.

It’s always good doing these things as it forces you to say what you really think.

Yesterday I found myself talking abut the curse of contingent charging which – like Paul Lewis – I consider as commission by another name.

In this I disagree with Al Rush who uses contingent charging to help what I consider “vulnerable customers” with special needs for cash rather than income.

For Al, the opportunity to charge contingently allows him to advise people on their DB pension rights in a way that he couldn’t if he had to demand a cheque upfront.

So when I wrote a blog on this earlier in the week, I was struggling with the conflict between “financial inclusion” and “consumer protection”. Frankly 9 times out of 10, I would argue that if you haven’t got the cash to pay for advice, you don’t have the cash to take the risks of pension drawdown.

Nic Millar pulled me up on “spotless” – (of course all advice should be spotless), I should have said “proportionate”.  The FCA are rightly worried that the proportion of those who pay a contingent charge and are worried about the advice is much lower than those who pay for the advice independently. In one sense  the risks of taking a transfer should be disproportionally promoted to those paying by a contingent charge. The Transfer Value Comparator should be posted at the front of any suitability report paid for by a contingent charge.

The other relevance of the word “proportion” is to do with numbers paying for advice out of the fund. In my view, the numbers out of all proportion to the need. The need for contingent charging is a “special need”.

The FCA’s definition of a vulnerable customer is interesting

vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.

The FCA’s report on the quality of transfer advice  contains this alarming set of statistics

As part of our review of the 18 firms’ processes we reviewed the advice they gave on 154 transfers. Our suitability findings were as follows:

  • suitable: 74 (48.1%)
  • unsuitable: 45 (29.2%)
  • unclear: 35 (22.7%)

These results are little different from their findings in 2017 and compare unfavourably with their research into retirement income advice where over 90% of advice was deemed suitable.

IFAs know what they are doing and what they are doing is providing unsuitable or unclear advice over half the time.

Can we really pretend that the disproportionate incidence of poor advice is down to IFA ignorance or lack of talent? I don’t think it’s that. I think the reason that IFAs get it wrong is that they have to distort things to get paid.

This is the problem with contingent charging, it distorts good quality advisers into poor quality advisers, it is storing up problems for the future and that the FCA has yet to address this problem – is worrying. The door has been left open for the FCA to ban conditional charging – I have called for that draconian action in the past

I am now going to change my position. I think it enough for the FCA require anyone who is requiring conditional charging to be deemed a “vulnerable customer”.

This is because I agree with Andrew Warwick-Thompson

but I see the needs of Al Rush. By making contingent charging available only to those with special needs, advisers will have to make sure the advice is proportionate to the special needs of the customer, the PI insurer and the regulator. There is one final point to consider – tax.


Right now – contingent charging is being used as a tax-dodge for higher rate tax payers, I can hardly see “wealthy clients” who can pay their taxes, being allowed to escape them through a regulatory loop-hole.

If the fact-find reveals that a client has the means to pay for advice, then the option of a contingent charge should not be available.

Posted in advice gap, pensions | Tagged , , , , | 3 Comments

Re-deploying our pension winners!

Webb for Regulator?

This rumour has sparked a twitter storm among those who think Steve Webb is conflicted in potentially exercising the powers of the Pensions Regulator on policies he initiated as pensions minister.

Personally I see any conflicts as manageable. It is after all tPR who advise the minister on policy in the first place. It’s an open secret who in tPR advised Steve when he was minister and as that person is influential in Government policy today, we might logically consider him conflicted too.

Following this path, we would have no-one talking to anyone; a state of affairs that would be quite the opposite of good Government. The pension policy successes of the past ten years have resulted from open government – the failures from the diffidence of civil-servants and politicians to get things done.

The assumption that Steve Webb should play no further part in the governance of pensions is silly, we don’t have many people of Steve’s calibre and he’d make a good pensions regulator.

I’m not sure I want him as my pensions regulator for two reasons. Firstly there are others who could do the job – probably as well and secondly Steve is doing a very good job where he is – at Royal London. But that does not mean Steve shouldn’t be considered for the job of CEO of the Pensions Regulator.


The good that they do

Conflicts between those in public life are most apparent when they look to monetise their experience in private life. Steve is doing just this at Royal London, Gregg McClymont at B&CE and Ros Altmann at PensionSync are all being paid not just for their experience but for their influence.

Do we object to those who have served as MPs (or in Ros’ case as an active Baroness) influencing as lobbyists? All three are very vocal, very prominent in public debate and are all getting things done. Steve’s petition, Gregg’s work on health issues for builders and Ros’ campaigning on net-pay are examples of the practical application of influence for the public good. There is a dividend in having former politicians in the private sector, they move things along.

We may feel awkward that they are leveraging their positions in Government for personal gain but I think the judgement should not be “Whether” they do this – but “how” they do this. As they are opinion formers, they need to be challenged and I have challenged them on this blog.

In the case of these three, all are quite accountable, all engage in debate  and all three have been highly effective in their work. The proof is in the pudding and the pudding tastes good.

The good they might do

There are examples of conflicts that go un-reported which worry me more. I worry when I see senior civil servants from both FCA and tPR  working within consultancies and influencing the course of policy through what can only be called “insider knowledge”. I have made these points in relation to the RAA of BSPS (as an example). There are plenty of civil servants who have served time in Brighton or Canary Wharf  who could be tempted to arbitrage against regulatory weakness for commercial gain. We should call that out.

Does this mean that we should stop figures as disparate as Rory Percival and Andrew Warwick-Thompson from doing the work they are doing – NO!

We need experience in the private sector , but we need transparency. What we can’t have is the kind of kiss and tell relationships between former regulators and those currently in the job. I don’t think there is a lot of this about because we generally have the controls with the regulators to stop it. We also have scrutiny from the media, social and otherwise.

The good they will do

Someone will take on Lesley Titcomb’s role when she leaves in the spring of 2019. There are several candidates and I doubt that many will be life-long civil servants. I expect to see people who have worked in the private sector prominent in the selection proceedure.

I am pleased that Steve is being mentioned, not least because imagining him in Lesley’s place, makes me realise that she leaves big shoes to fill. She succeeded Bill Galvin who is now CEO of USS ( a highly political role). I hope that Lesley can do more work in the public sector but would feel comfortable working with or competing against her in a commercial role.

The jobs that people like Caroline Rookes , Charles Counsell and Michelle Cracknell do is important to pensions. All three will I think be under-employed in months to come. All three will be looking at how they can make a difference without creating conflicts for themselves.

People like these don’t get to the positions they’ve enjoyed without having done good work. Their potential to do more is great. We should not be stopping them applying for roles on the basis that they are conflicted, we should be asking them how they will manage those conflicts.

We don’t have such a talent pool that we can discard the talented on the basis that they’ve done their bit. If they have a bit more to give – we should be grateful!

Posted in Big Government, Blogging, pensions | Tagged , , , , , | 2 Comments

The FCA finally get to the bottom of why transfers have been mis-sold.

port talbot 4

I feel like singing hallelujah!

The FCA’s findings from their transfer review are brilliantly presented here by NMA’s Talya Mistry.Misiri

Here’s how she sums things up

The findings highlighted that less than 50% of advice was suitable. It said that several firms failed to collect sufficient information on clients’ personal circumstances, such as other pensions arrangements or retirement plans. Where this information was collected, firm did not fully consider it when making a recommendation, the regulator found.

What the FCA’s findings show is the fundamental preconceptions that have crept into wealth management about what people want from their savings

The FCA observed that the firms were relying on ‘generic objectives’ during fact finds with clients who wanted to transfer. This included using terms such as ‘flexibility’ or ‘increase pension’ without going into detail about what this meant to the client.

It said firms were not asking ‘whether the client is able or willing to take the risk required to achieve those objectives, or why they were prioritised ahead of the other needs and objectives of the client’.

Under a slogan separating “facts” and “myths” , Misiri details the specific preconceptions as misconceptions

The FCA said firms were putting too much emphasis on the inheritance tax benefits of a transfer.

In an eerie echo of the Brexit debate , Misiri looks at the philosophical basis used to recommend transfers

Firms were ‘basing a recommendation on the client’s objective to take control of their pension without exploring the reasons for this

The one-size fits all approach, continues with regards cash-flow planning

According to the FCA too many firms were not considering how much clients were spending or had coming in before making personal recommendations

The fundamental objective of any retirement plan is to ensure the money lasts as long as the client, but once again the FCA found advice wanting

….the regulator was concerned that advisers had not considered what happens when a client lives longer than expected after transferring their pension.

Advisers simply ploughed their furrow with little attempt to think about a client’s situation holistically

‘recommending a transfer because the client wanted immediate cash and income in retirement and to leave death benefits to their heirs without considering or demonstrating to the client the impact that achieving one objective may have on the client’s other objectives’

Meanwhile, the product into which their client’s money was to be transferred was simply not up to the job

The FCA found evidence that advisers did not look at how charges might affect a client’s income after a transfer.


The FCA’s report also details inadequacies in the way that some financial advisers talk about risk and explain risks to clients.

I have seen many angry comments from advisers, but I have also read this wise council from Rory Percival.

Underpinning all this is a fundamental question of agency. Every criticism comes down to an adviser putting a sale before advice , a wealth management product before a pension and his or her own interests before a client’s.

Why this desire to sell products? The answer must be staring the FCA in the face, it is of course because without the product, there is no way for the adviser to get paid. The product is not just providing the initial fee for the advice (under what has become known as contingent charging), but usually it provides ongoing fees. Those ongoing fees can either be embedded in the product as investment management or collected by an advisory agreement. Occasionally fees will be paid to unregulated bodies (such as Celtic Wealth) as marketing allowances.

In all cases, the perverse consequences of contingent charging are plain to see. I jump for joy and shout hallelujah because I know that an evidence-based regulator has now got it.

With all these brilliant insights, it is impossible to think that the FCA can continue to tolerate contingent charging as the primary means by which a financial adviser is paid on transfers.

Contingent charging is the root of transfer evil. It turns advice into a sales process. It focusses the adviser’s mind not on the client’s objectives – but on the advisers. It leads to decision making which is designed to put the adviser first.

Evidence of the destructive power of contingent charging are everywhere. In the midst of a turbulent week in politics, Nick Smith had the chance to put to the Prime Minister the plight of one of his constituents, diddled out of his pension saving. The Prime Minister had this to say in parliament

‘I’m very sorry to hear about his constituent in relation to his pension and the actions of that financial adviser,’ ….. ‘I will ensure the Treasury looks at this issue with the FCA in these sorts of cases”.

The litany of sad stories emanating from Port Talbot and elsewhere repeats the same fundamental failing. It is a failure to prevent the conflict of interest between the client and the agent.

I will finish with the sad story of Richie Clayton who lost £169,000 by investing his transfer value into the predecessor of the Vega DFM into which so many Active Wealth clients were placed. Here’s his testimony to NMA

“There were 750 of us who all exited [took redundancy] at the same time. Celtic Wealth then began contacting people who had come out, all of whom had quite high sums in their pension funds, I had a contact from within the unions at the steelworks who recommended the company.

I was contacted several times by Celtic Wealth saying: “you need to sign up, you’ve come out, you won’t be protected. If Tata pull the plug on Europe, they’ll take your money, you won’t get a penny. If you die tomorrow, your wife, children won’t get anything, you need to do it as soon as possible. I spoke to a few people at the time and everything looked good. They didn’t tell me about the risks.’

So long as we continue to allow advice to be paid for on a contingent basis, stories like Richie’s will be repeated. We need to cut this cancer off before it spreads. Sadly with £38.6bn transferred out of DB last year alone, I fear we may be too late. Many people will have to live with the consequences of what the FCA has found out – not just today, but for the rest of their lives.

Posted in BSPS, pensions | Tagged , , , | 2 Comments

Listening to what is being said.

colin meech.png

Listening to Colin Meech

Colin Meech wins the peace

A couple of days ago, I spent an enlightening hour in Parliament listening to the witness of Colin Meech and Jonathan Lipkin to the Work and Pensions Select Committee.

I have known Colin a few years now and have considered him a firebrand. But –  despite of my teasing – Colin stole the show.

It was “the still small voice of calm” that we heard, not the rage against the machine and it was so effective. Colin made the link between the unseen costs of investment management and the delivery of public services. Not to put a finer point of it, every penny wasted in the City is a penny not spent in a local community.

As Colin and Unison’s primary constituency is the workforce employed by local Government, he sees first hand the impact of unnecessary pension costs on the jobs and wages of those he represents.

You can read Colin’s arguments in this report in Professional Pensions

I found myself – while listening to Meech speak, questioning the thin dividing line between the image we project in our work and the people behind the image. Colin Meech is to many people the militant face of unionism – as it touches our bubble; but in the context of the parliamentary meeting – it was clear to see why he is so integral to Jack Dromey’s advisory board.

A time to listen

Occasionally , and this week has been such an occasion, I spend more time listening to others than mouthing off myself.

I should have written this blog yesterday, but was involved in a number of projects that prevented me doing so.

I have spent some time this week listening to arguments both on costs and charges (see my blog on the excellent PPI seminar) and on the dashboard.

Yesterday was a good day to be listening. Many of us had to put down our phones as we had no 3 or 4G coverage. We had to stop our messaging and look around us. Yesterday evening I went to a wondrous show of art at the National Gallery as a guest of WTW (thanks very much). The silent communion with the paintings of Renoir, Degas, Manet and Cezanne (to name but a few) gives an insight into another way of seeing things, much as listening to Colin.

Yesterday was also a day for me to listen to TPAS and better understand the questions that ordinary people ask about pensions. TPAS probably know more about the things that bother people than anyone. I hope that this knowledge will be fully transferred to the Single Finance Body and not lost as TPAS is subsumed in January.

The less said the better

This morning I will be listening again, listening to the OECD and their findings on the British Pension scene. It is not strictly the day job and I have half an eye to what I am told are “networking opportunities”. Infact – we go to listen , not just to hear the views of those outside our sphere, but to widen our perspective on the day to day problems we have to solve.

Whether it be the OECD, or TPAS or Colin Meech – this has been a week when I feel particularly enlightened.

It’s good to write a blog that sticks with positive thoughts, but then my head is full of the visions of wonderful painters and it’s nearly Christmas!

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AgeWage – the value of consumer values

agewage snip

This article is  by Oliver Tapper, who is currently working with me, taking a year out of University. It represents our thinking on how ESG should be integrated into our business and gives some thought to how our business can help others better understand how green are their pensions.

The purpose and value of ESG to AgeWage

AgeWage is a company with a social purpose at its heart. We are looking to make the world of pensions more accessible and transparent to those who cannot or do not take financial advice. This approach will help people save money and will therefore benefit many people economically. However, as well as providing economic transparency we also have a duty to help people engage with the ethical and responsible side of investing. Responsible investment should be promoted by AgeWage both within the company but also through the service we provide. Promoting environmental and social responsibility within AgeWage is something that should be attractive to us as individuals, to investors and ultimately to consumers. By committing to some key ESG principles we are acknowledging the value your money holds in promoting positive environmental and social change.

AgeWage and ESG

Environmental, social and governance (ESG) in its commonly used sense refers to the policies a company may adopt to make sure it is: investing responsibly, treating its’ workforce correctly and governing transparently. As a start up ‘pen-tech’ our engagement with ESG will differ from that of most companies. As a company we engage with ESG on three levels:

  1. As employees and representatives of AgeWage
  2. AgeWage’s internal structure and policy towards ESG
  3. Our product

Giving value for money is a central principle for AgeWage. But we should see ‘value’ in more than just a transactional sense, it is also about the value that money holds to people socially and economically. Some of our users will be unaware that their pension is invested. As a result there will be a lot of people in default funds investing in companies that perhaps they might not want to be for social or environmental reasons. For some people this would be a valid reason to switch providers or funds and we should cater for these consumers. Valuing the values of our consumers should be a priority for AgeWage in a time where climate change and social issues are cared about more so than ever before.

AgeWage ESG values

I have come up with some main ESG values I believe we have at AgeWage that we can use going forward internally and externally:

  1. Providing value for your money
  2. Providing transparency for consumers through AgeWage and ESG score.
  3. Helping people make informed ethical and economic decisions – Helping people understand the value of your money.
    1. Giving an ESG score that helps them understand, assess and act.
    2. Helping people understand that good economic decisions and good ethical decisions are not mutually exclusive.





Providing value for money

Providing support to the 94% who can not or will not take financial advice

Helping people get value for their money is a KPI for AgeWage


Providing transparency for customers through AgeWage and ESG scores

We help consumers see the environmental impact their investment is having.

Consumers are able to assess the value for their money and the value of their money together.


Helping people make informed ethical and economic decisions

Consumers will be more aware of the environmental impact of their fund and will likely act accordingly

Consumers will become aware that ethical decisions are economically viable. People feel empowered by their pension.

AgeWage facilitates a growth in engagement, understanding and action from consumers.

AgeWage ESG approach

A consumer’s ESG user journey could look like this:

  1. Understand

Provide consumers with the information they need to understand where their money goes when they contribute to their pension. Giving a step by step guide that educates people on how their money ends up being invested and where it is invested.

Eventually we should aim to provide an AgeWage ESG score or comment that helps consumers understand whether their money has been invested responsibly or not.

  1. Assess

Once they have access to the information around how sustainable their pot is they can look at it alongside the AgeWage score. We can also ask them questions about how important ESG is to them so they can assess whether for example they would consider moving from a fund with a high AW score but low ESG score to a more sustainable fund.

We could guide the consumer to come up with their own plan for what they want from their fund from an ESG point of view by using a 1 to 5 importance scale (least important to most important). This would provide us with a score the consumer could work towards as an ‘ESG target’.

  1. Act

After assessing consumers will reach the end of the user journey which is ‘act’. We could present them with the various options they could take from an ESG point of view in order to meet the ‘ESG target’ they have set themselves in the ‘Assess’ section.

Reasons for the ESG approach

But why are we taking this ESG approach?

  1. We have to

The climate change of the last 200 years caused by humans is perhaps the greatest threat we have ever faced. Immediate action is required in order to prevent us exceeding the 2°C limit after which we will do irreversible damage to our planet.

There is more scientific consensus around climate change than almost any other scientific topic. The out of sight, out of mind argument simply won’t suffice. Although climate change will hit the ‘Global South’ hardest initially, all of us will be impacted in different ways.

Here are some stats that highlight the severity of the issue:

  • More greenhouse gases are in our atmosphere than any time in human history
  • Sea levels are rising at their fastest rate in 2,000 years.
  • An average of 21.5 million people a year have been displaced by climate change since 2008.
    • It is likely that these displacements will cause refugee crises and ‘climate wars’ in the future.
  • Global flooding could triple by 2030.
  1. Financial services need to

The last few years have seen a rapidly growing movement in financial service towards ESG policies. This movement for the most part has been driven by the realisation that climate change is economically disastrous. While it would be nice if the move was driven by a less economically pragmatic and more socially minded outlook, the ends may justify the means when it comes to climate change.

At AgeWage we will be undertaking an ESG approach because we want to rather than because we should do.  By providing ESG scores and targets we will be helping people: understand whether their pension is green, assess whether they want to make it greener, and act accordingly.

  1. There is a demand for it

The other reason we have seen a growth in ESG policies is because there has been increased demand for it. As the discourse behind climate change grows, there is a growing realisation that imminent action is necessary and therefore people are being a lot more mindful of their individual carbon footprints.

The irrepressible force of auto enrolled millennials are showing a desire for more socially minded pension investments:

  • Millennial investors are nearly twice as likely as non-millennials to invest in companies or funds that target specific social or environmental outcomes (EY 2017: 2).
  • 68% of 25-34 year olds say it is important that people use their money for the good of society and the wider world (PwC 2016).


ESG is an incredibly important concept that hopefully everyone at AgeWage is behind. Providing the AgeWage score will undoubtedly have social benefit for many consumers as we give financial information to those who might not have otherwise got it. But we can go one step further by providing an ESG score as we will be showing consumers what value they got for their money (AW score) and what is the value of their money (ESG score).

agewage vfm

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UK – OK! Disclosure battle won – now let’s win the peace.

jap soldier 2
The PPI have produced a really excellent paper “Charges, returns and transparency in DC – what can we learn from other countries?”

The report, sponsored by Which? explores UK charges for pension schemes against those in the US, Australia, the Netherlands and Sweden.

It’s not headline grabbing stuff – but it is good to hear a Dutch pension expert praise the system of cost disclosure developed by the IDWG.  The Dutch of course got there first, but they are now acknowledging that we are using second mover advantage to learn from their mistakes. Jacqueline Lommen  explicitly linked recent work on both cost disclosure and collective DC as examples of the progress Britain is making. This may not yet be reflected in popular sentiment, but (at least in some areas) Britain is getting back on its feet.

Winning the peace

From the table above, we can see one of the difficulties with the omni charge AMC that has been the standard way of disclosing costs to savers in the UK.

Individuals get a rough idea of what they are paying from the AMC (rough because it doesn’t include transaction costs) but they’ve no idea what the omni charge AMC is paying for. Enlightened providers, such as L&G have followed the European and American models and split admin and investment costs.

In the UK – this has been seen a dangerous disclosure, NEST tell us that they cannot tell us what they are paying for outsourced fund management because they have put themselves under a voluntary NDA not to.

I have has numerous conversations with People’s Pension about how much of the 50bps they charge members goes to pay State Street (their fund managers), how much meets People’s running costs and how much is kept back by B&CE to recover the costs of setting up People’s pension nearly 10 years ago.

Since I haven’t had an answer, I am guessing that the split for People’s is 2-15- 33. If People’s want to come clean with the real numbers – I’ll be happy to publish them.

Winning the peace means building on the disclosures we have and pressing home the advantage. Not everyone will want to know what People’s or NEST are paying away to external service providers, what they are holding back to recover costs and what their internal running costs are – but people like me will keep asking. Sooner or later we will be able to benchmark the efficiency of these organisations and rate them for the sustainability of their propositions.

That’s one of the peace dividends!

How much do we pay to spend a penny?

So far, we have focussed on getting people a good deal on their savings, but have done little to disclose what people are paying in the spending phase of their DC pension.

This is worrying as many of us will need to spend our retirement pot over as many years as we saved and – while we were fully aware while we were saving – we are likely to become more vulnerable as we grow older – and mentally tired.

The idea that we pay to spend our pennies is not one that occurs to most people, but we do. There is no charge cap on that spending either and the costs of getting our money are far from easy to understand.

Without the data, it is hard for me to write with authority on this. It would be great if PPI could follow up with a similar report telling us the international comparisons between the cost of our drawdown system and the costs people pay to spend a pension penny in Sweden, USA and the Netherlands.

Not much chance of peace this morning!

I am going to make my way down to Westminster this morning, to witness the spectacle of Frank Field interrogating Colin Meech and Jonathan Lipkin at the Work and Pensions Select Committee.jap soldier

It’s likely to be a lively affair. Colin is like the Japanese soldier who will still be fighting his war- many years after the rest of us went home. Jonathan will be there to provide him with a target!

Frank will have to go some to beat the outstanding chairmanship of Laurie Edmans and the brilliance of both panel and audience in the debate that followed. Thanks to Lawrence Churchill in particular – whose insights partly inspired this blog. I cannot say more as we were under the beastly Chatham House rule.

I am however able to post this slide which shows just how far we have come since the bad old days.

and I can remember – though not repeat the brilliance of one of the best civil servants I have ever met.


Posted in advice gap, Dashboard, dc pensions, pensions | Tagged , , , , , | Leave a comment

Lord share their data – but not yet!

botticelli-augustine (1)

Augustine’s wayward prayer – “Lord, make me holy – but not yet”, sprung to mind as I sat with the dashboardistas in Parliament yesterday.

The Government’s “Pensions Dashboards – working together for the consumer” is a pretty vague document which limps over the line – six months late – and with little for the consumer in the next five years.

What the consumer will get is pretty much what the DWP and the pensions industry wanted. There will be multiple dashboards – but not yet.

“The evidence would suggest that starting with a single, non-commercial dashboard, hosted by the SFGB, is likely to reduce the potential for confusion and help to establish consumer trust”(this statement – 205 – appears in bold in the printed document but not so – in the digital version)

Since the Single Financial Guidance Body has yet to start its work, I am not sure what the evidence is for the efficacy of a single, non-commercial dashboard. It’s true that in Australia, dashboard is a euphemism for a marketing device and it’s also true that European dashboards have been centralised and successful. But there is no evidence at all that a dashboard will work in the UK because it is non-commercial – or single.

Indeed – the Government’s attempts to make pension guidance digital to date – through the Money Advice Service – have been singularly unsuccessful.

The SFGB may be better, they have an influx of good blood from the highly successful TPAS and a new leader – John Govett  who see’s his purpose as to “help people transform their own lives”

John was at yesterday’s event. He told the audience he was keen to get on with it. I wish him good luck, the impact of the transition to SFGB has so far been to keep project dashboard waiting for the best part of the year – while we await his and his Chair’s arrival.

I say this in the absence of any other excuse for the appalling delays in delivering this digital project.

Giving the SFGB first shot at a dashboard is like opening a motorway with a convoy of tractors.

Confusion over open standards

There was throughout the meeting, a confusion by the extent to which Government could adopt the open standards (the pensions equivalent of the CMA9) that could give us “open pensions”.

There are sections of the document which show the same confusion. P198 states (in bold in the paper copy)

In order to harness innovation and maximise consumer engagement, an open standards approach that allows for multiple dashboards is the right way forward.

but it doesn’t have the courage of its convictions (P209)

While the department recognises the commercial opportunities created by multiple dashboards, it believes that there should be a single Pension Finder Service which is run on a non-profit basis and with strong governance.

Lord share my data – but not yet!

Governance overload

While the CMA got banks to share data through a system of APIs, the DWP has decided that pensions are too hard for that and resorts to “industry positions”.

In a section entitled “a dashboard section for everyone” there are paragraph after paragraph warning against individuals having direct access to their own data.

Again there are contradictions everywhere . In P195 we read (again in bold)

“It is important that for consumers, the provision of their basic information is free to access”

but consumers – especially those with low levels of financial literacy are not to be given access to information without the provision of that information being regulated and it coming with a dollop of guidance – if not full financial advice.

The result of all this uncertainty at the policy end is this ridiculously unwieldy governance structure which will atrophy open pensions into a monolithic bureaucracy that will MAS look agile.

dashboard governance model

And what will all this cost?

We were promised a feasibility study, but this study has no numbers. There is no attaching cost forecast, no financial justification – nothing to tell us what the cost of all this bureaucracy will be.

The Government is making great play of the £5m the Treasury has given the DWP to provide a hyperlink to the existing state pension forecast service. But finding the £20bn that has gone missing, displaying up to 50m abandoned pots and regulating the whole process as outlined in the paper is going to be a mammoth undertaking.

The cost of all this will – other than the £5m fall on the pensions industry through increased levies.

Dashboard cost model

These levies are unlikely to be paid out of margin, they will be passed on to consumers through higher charges. Another example of pensions abhorring a vacuum. Where costs are likely to fall – let’s find a new way to weigh our pension saving down with added cost.

Industry reaction

I am not sure how to best describe the feeling within the room. It was split between relief from the politicians and civil servants in the room that they had got something over the line and got people like me off their back, the PLSA, ABI , Which all of whom seem to think that what we have is a good outcome, and me, Romi Savova and Ian Mckenna, who see this as a hopeless waste of time and money – an opportunity wasted.

Thankfully there was at least one journalist in the room who was prepared to call the Emperor’s new clothes.

My conclusion

People have been given an expectation that they will be able to find their pensions and see their pension income and pots in one place. People will not want to wait for the SFGB to organise itself to deliver something in 2019.

In answer to question VI and  VII of the consultation, I very much doubt that most people would wait another five years to see the majority of their data in one place.

Question VI

Our expectation is that schemes such as Master Trusts will be able to supply data from 2019/20. Is this achievable? Are other scheme types in a position to supply data in this timeframe?

Question VII

Do you agree that 3-4 years from the introduction of the first public facing dashboards is a reasonable timeframe for the majority of eligible schemes to be supplying their data to dashboards?

My question to the Minister was this.

“When I went to the first public meeting on the Dashboard, I was 54. I am not 57. Should I be waiting till I am 62 to see my data in one place?”

In a year when we have seen the successful implementation of open banking and Faster Payments, when HMRC continues to roll out Real Time Information and is demanding we make tax digital, pensions are moving at a snail’s pace.

The ABI, PLSA and Which will be embedded into the delivery function of a dashboard. The DPW will Chair its steering group. To all intents and purposes – nothing has changed. The State is in no position to facilitate delivery – as has been proved by the last three wasted years.

Now yet another Governmental Body has been placed between people and their data, the SFGB.

Bureaucracy is killing the dashboard and with it people’s hopes to get their pensions back.

I cannot support this approach to the governance and the delivery of the dashboard. It will cost people more than it delivers, it is unwieldy, unimaginative and deeply patronising to ordinary people.

People deserve their data now – not to the timetable of the pensions industry and Government.


Posted in customer service, Dashboard, pensions | Tagged , , , , , | 2 Comments

Why there’s no snow on my blog this year

snow on the blog

For the past 10 years there has been snow falling on my blog. This year none has appeared. People need to know it’s Christmas coming – the advent of snow on is important.

This is the message I’ve got from the good people of WordPress!

I’ve checked on the snow effect, and although this is a feature we no longer have, you can use a plugin like

Since an upgrade to the Business plan is required to be able to install plugins, I can offer you a discount on the Business plan which will reduce the price of an annual subscription. The discount is 17% off which is about two months worth.

Bah humbug!

I already pay WordPress a lot to publish articles that aren’t full of adverts, contain video and do lots of good stuff.

It seems that the package that I bought, which included Christmas snow, just got a lot less festive!


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Could “Dashboard-Day” be here at last?

Today’s a big day out for the dashboard-istas!

Dashboard event.PNG

Over the weekend , Theresa May linked herself to the pensions dashboard using the Daily Mail to pin her colours to the mast.

It is clear that the Pensions Dashboard is going to happen – the question is whether it will provide us with open pensions or be the love-child of  pension- industry in-breeding.

A social start

It is encouraging that DWP are organising this using social media site “Eventbrite”. It suggests that whatever comes out of this morning, will at least have been launched using social tools. That it’s a private pensions event may smack of Sir Humphrey but the registration process got things off in the right direction. That I was invited  is another step in the right direction.

I will be scooting (or Boris-Biking) back from Portcullis House to Bank for a slightly delayed Pension Play Pen lunch (we shall kick off at 1pm subject to me finding a rack for the beast). Details here  Please join me for lunch if you want to get a first hand recounting of whatever in the meeting, I’m able to talk about!

Why we need open pensions.

If you read yesterday’s blog, you’ll know that the concept of the Dashboard put forward by Frank Field in his letter to Guy Opperman is the opposite of “open pensions”.

The demands for compulsory data clearance, a Government led governance body, regulatory permissions to run dashboards and worst of all a single pension finder service will be resisted – at least by me – and by all those who want to see open pensions.

We call on the Government to consider data and cash transmission between pensions as the way they did banking in 2016/17.


The system advocated by the ABI and others that seems so successfully to have lobbied the W&P Select Committee would decrease competition leading to higher prices for the consumer. We would pay dearly for a single pension finder monopoly – whoever it was given to.

If we are in any doubt as to what the lobby was, we need only read this article in Corporate Adviser. The demands come from the people at the front of the queue for the monopoly.

The cowardly justification for the atrophication of open pensions into what these people want is fear of scamming. Those who claim to be anti-scamming are quite happy to see its continuation – albeit in offshore havens such as the Isle of Man. If you don’t know what I’ m talking about , read Angie Brooks’ excellent new blog “Long Term Savings Pig” which names the names.

We heard precisely the same scare stories from the retail banks prior to the introduction of the CMA9. We were told that open banking would be a scammers charter, a year on and most of those spreading that message are trying to buy-up the challenger banks.


If they aren’t careful, the Starlings and Monzos and Revoluts will end up eating them.

The Queen of Open Pensions will be there.

I’m very pleased to find out that Romi Samova, the Queen Bee – will also be at the “private pension meeting”. Like me, she has no interest in keeping open pensions private, no interest in closed room roundtables and no time for procrastination.

Like me, she is shocked by the delays that have precluded firms like hers from developing the tools to help people find the £20bn in lost pensions.

Like me, she is anxious that the pot-proliferation that could see (using the DWP’s own estimates) 50 million abandoned pots by 2050.

Like me, she wants to see genuine support for the 94% of us not taking financial advice. What she is doing with her Bee-Keepers is a model for that kind of genuine support.

The exclusion of Romi Samova from the Round Table held for the Work and Pensions Select Committee is a crime against the entrepreneur, a spoke in the hub of innovation and an affront to the consumerism that Romi stands for.

Not a time to hold back

When people hear about the scale of the problem, they are shocked. Shortly before the meeting this morning, I will be on BBC radio explaining to the good people of Hereford and Worcester how it came about that one of their listeners lost his or her pension. When I quoted the PPI estimate that there is not one lost pension but £20bn of them, the program producer nearly fell off her chair!

I will not press the negative, I will point to the future and hopefully a brighter future for those of us baffled by the pension system.

To get open pensions, we need open practices. We need open meeting not closed round-tables, we need a proper consultation- as promised by Amber Rudd at the TISA conference but two weeks ago.

Most of all we need a Government not pledged to the lobby of those who want to keep pensions closed. I trust that in Guy Opperman and Amber Rudd – we have two  politicians with the consumer – not the pensions industry – in mind.


Have a dashboard Christmas!

12 days of dashboard

Posted in age wage, Dashboard, pensions | Tagged , , , | 2 Comments