Are IGCs and Trustees worth it?

 

 

 

insurers

The best test of the value of an IGC or an occupational trust board is to imagine how things would work without one. Before 2015, insurers ran workplace pensions for multiple employers using the bald trust of a GPP operational interfaces that were what the employer saw. For bigger employers, insurers bespoke communications and can offer an employer specific default fund but no one acted purely for the member. The IGC was supposed to change that.

The occupational pension scheme now comes in two guises – single employer and multi-employer. Unlike a GPP, an occupational pension can provide defined benefits and will be able to provide semi-defined benefits under CDC.  The trustees do the same job whether they oversee a single or multi-employer scheme though the level of scrutiny they are under from regulators varies according to the level of guarantees in the benefit and whether the trust is set up by a single employer , or more commercially for multiple employers.

It’s my view that IGCs and Trustees are as effective as they have to be. If no-one takes any notice of them, they lapse into irrelevance – which is frankly what’s happened to most occupational DC trusts, some master trusts and even one or two IGCs.

I believe that without these fiduciaries, the workplace pensions we invest our money into , would be run for the benefit of anyone but members. Left to their own devices, consultants, platform providers and fund managers would so erode the value of our money that the money we have to purchase a pension at retirement – would be severely reduced.

Proof of this  is what happened before modern governance and regulatory supervision arrived.


The work I have done in 2019

Over the past three weeks, I have read, re-read and reported on the IGC reports produced by the providers of workplace pensions in the UK. These reports do not cover all the pensions we invest in, there is a substantial group of providers who do not have IGCs, it includes SJP (which has a mini- IGC) and many SIPPs that do not operate in the workplace. These products are supposedly “advised”, though the FCA is concerned that many of them have many participants who have lost or sacked their advisers and have very little protection from malfeasance.

I have read these reports with an eye to three things

  1. Engagement – is the report readable and is its tone engaging
  2. Value for Money – “is the report properly assessing the value you are getting for your money?”
  3. Effectiveness – does the report show the IGC robustly pressing for better for policyholders.

I have scored each factor red , green or amber and tried to remain consistent with the work I’ve done in previous years and can present my findings for the fourth time in the table below. I am happy to share the table with anyone who wants the spreadsheet – which includes URLs for every report still on the web. henry@agewage.com – (no firewall).

IGCs 2019 bright +.PNG

 

2019 trends

Transaction costs – a mixed picture

2019 was supposed to be the year when we saw how much we really paid for fund management- not just the fees to the managers, but the cost of the management itself.

In some reports we did. L&G showed that you can get cost data from external managers (though their report did give us the kitchen sink). Others managed to give us edited highlights which worked rather better. Fidelity showed a before and after table – which demonstrated how the Fidelity default reduced in cost after discovering last year that members were paying more in transaction costs than to the fund manager. Some reports gave up on getting these costs – which was disappointing. The most bizarre reports were those who discovered high transition charges but wouldn’t tell policyholders which funds had them!

ESG – a start but only a startESG

The reports all had something to say on ESG, but we have yet to see the fruits of this engagement. While some IGCs (L&G and Aviva in particular) have focussed on ESG in prior years, this year every report ticked the box  – and many only ticked the box.

I look forward to a time when we don’t have to talk of responsible investing as an alternative form of fund management but look at ESG as an integral part of the value managers bring. Only when ESG is part of the VFM assessment – will it be fully integrated.

Too many of the reports still talk of the risks of adopting ESG, not enough of the risk of ignoring it.

The wider context

The terms of reference for IGCs were set out in 2015, since then we have seen huge changes in the pension landscape.

One example is the extent to which DB rights have been exchanged for DC rights through CETVs. Very little of the billions transferred found its way into workplace pension. Part of the reason for this was that financial advisers prefer to use vertically integrated self invested personal pensions. Part of the reason has been a reluctance from employers and providers to promote the workplace pension over more expensive alternatives.

I am disappointed that IGCs have not extended their terms of reference to consider how these plans could be promoted to people transferring. This goes as much for master trusts as workplace GPPs.  There is a job to be done to compare the available workplace pension with the promoted advised solution and perhaps this is something the FCA will look into. It would be better if the IGCs (and occupational trustees) , got on the front foot.

Port talbot

Reactive or proactive?

The best IGCs are proactive, looking for new and better ways to assess value for money and improve outcomes. They look at best practice in communication.

But I sense most IGCs are more interested in meeting the requirements of the FCA, rather than going beyond.

It would be good to see IGCs looking at workplace pensions capacity to help people spend their pensions (rather than rely on transfers to specialist drawdown products, annuities or “cash-out” to bank accounts.

It would be interesting to hear the thoughts of IGCs on the opportunity and threats to their policyholder from CDC.

The FCA have said they are looking to extend the scope of IGCs to cover decumulation and non-workplace pensions, it would be good to see IGCs pushing to do more for policyholders and encouraging the FCA to give them greater responsibility.

 

In conclusion

It has been a great pleasure reading this year’s crop of IGC Chair Statements. During the year I’ve got to meet most of the Chairs and they know how keen I am to help continuous improvement of both the Statements and the work that goes on throughout the year.

To be relevant, IGCs have to be read. It is too much to be expected that the become general reading for policyholders, but there is no reason why IGCs shouldn’t be more in their faces.

Thanks for reading this, please promote the work of IGCs and interact with yours. They are the best way ordinary people have of improving value for money for their workplace pensions.

The same can be said of occupational trustees, who I hope to put under similar scrutiny in months to come.

IGCs 2019 bright

 

 

 

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Could pensions yet break state education?

teacher

The Teachers’ Pension Scheme is one of only eight guaranteed by the Government; provides additional benefits linked to salary; is inflation-proof to offer teachers a secure retirement; and offers the typical teacher around £7,000 in employer contributions every year.

This makes the scheme one of the most generous schemes on offer – in comparison, Work Place Pension rules require private sector employers to pay a minimum 3% contribution to an employee’s pension, which is around £900 a year for someone earning the same salary as a typical teacher.

The message is from Dominic Hinds, Education Secretary and represents an escalation in a longstanding argument over how we fund education in this country.

The mechanics of this are laid out in the same statement. If a school over-runs its pension budget (currently 0.05% of the total school grant) it can apply for for a top up calculated on a per pupil basis which will be paid from the £940 m set aside to meet extra pension costs anticipated for 2019/20.

The details of who will get what and why are in a detailed response to the Government Consultation on this subject

In response to increasing employer contribution costs for the Teachers’ Pension Scheme from FY 2019-20, the Department for Education proposed to provide funding to state-funded schools and Further Education institutions, as defined below, as these institutions are most directly funded by Government grant(s). The Department also proposed that Independent Schools and Universities (and other organisations providing HE) obliged to offer TPS would not receive funding.

This is not money that has been magicked from thin air. As Andrew Young, formerly a Government Actuary points out, it’s money found from the public purse – follow the money and you’ll find that it comes from your purse.

We all want teachers to get proper pensions and if it costs a little more than expected then so be it. The £940m supplementary pot is a price most of us would pay.


But here it gets political

Although all teachers will continue to get a very good pension, so long as they are in the teacher’s pension scheme, not all teaching establishments will benefit from the supplementary fund. That £940m that is set aside will not be available to higher education teachers who are in the teachers scheme. Nor will it be available to teachers in the teachers scheme but in the private sector. They will have to fund the extra costs from their own resources and that means higher fees.

So those with kids at private schools and most students, will find their fees will go up as a result of the Government Actuary’s decision that the funding of the Teachers Pension Scheme must increase.

Which is all very political and very divisive and not at all explained.


The message to parents

If you are a hard working parent who is funding your kids school fees, you will probably be finding your own pension contributions uncomfortable.  You will look at the tax deduction from your payslip and wonder about the next five figure demand for fees in a couple of months time. You may ask whether the amount you are paying towards other people’s pensions is more than is being paid into your own.

Here’s an interesting analysis from Alastair McQueen which shows just how wide the gap is becoming between private and public pension expectations.


You may well be thinking that you are being asked to pay more than your fair share, that the value for money you are getting from your tax-spend is pretty thin and that the likely increase in your school fees to fund the increased cost of your child’s teachers pensions will be the straw that breaks the camel’s back.

Were you to say this to Dominic Hinds, I suspect he would look you in the face and say “tough”.

For years private schools have been under the treasury’s eye for their charitable status. They are politically vulnerable as they are considered divisive by those with left of centre views and unaffordable by the majority of those with right of centre views.

Although hugely popular with the mass-affluent, the Government knows full well that the higher the fees, the more exclusive the fee-payer feels. There is a seemingly endless tolerance to private school fee inflation which has outsripped all other types of infflation over the past twenty years.

The message to parents is to tighten your belts or return your children to the state system. As for higher education, the message is less clear. The cost of the University Superannuation Scheme has been a major cause of debate (and industrial action) over the past two years. The strain on employers offering higher education and pensions through the teachers pension scheme (rather than USS) looks likely to be another cause of instability.


Deliberately provocative?

Dominic Hinds’ statement looks deliberately provocative. By demonstrating that the imputed value of contributions to the Teacher’s Pension Scheme are more than ten times the minimum contributions needed to comply with the auto-enrolment regulations, Hinds is laying down the gauntlet to the private schools, to higher education and more generally to a private sector already bearing the brunt of public sector pension costs,

While this makes for a good sound-bite when talking to state schools , it is likely to inflame the larger debate over the “pensions apartheid” between the haves and the have nots.


If you are in the public sector you now have a protected pension scheme. If you are in the private sector or teaching in higher education , your employer’s pension costs are unprotected.

Your private school of HE employer may try to kick you out of the teacher’s pension scheme (though that will be difficult as indicated below). Or they may refuse you pay-rises , or they may pass on costs to parents and risk school fee tolerance snapping and parents withdrawing children.

These are the wider consequences of Damian Hinds’ statement. It strikes me that statement is cavalier, deliberately provocative and not fully thought through. “Interesting spin” indeed.


 What next for private schools?

In its consultation response , the Government holds out very little hope for the private sector

The Department therefore confirms the funding rationale set out in the consultation document and will not fund Independent Schools at this stage. However, by way of a potential mitigation to the risks identified, the Department will begin work to consider allowing Independent Schools to leave the scheme via phased withdrawal.

If you want to teach in the private sector, be prepared to lose future pension accrual  and join the swelling ranks of under pensioned professionals who rely on a DC plan and a contribution at your employer’s discretion.

If private school teachers get as agitated about this as University Staff, then the “phased withdrawal of private school employers from the Teacher’s scheme will be a very messy and disruptive business.

I think that many parents considering their children’s education , may well end up looking at the state system , which presents another set of problems for Damian Hinds, for a migration from private to state will impose a new set of funding challenges for his department.

The DOE are banking on parent’s fee escalation tolerance. The cynic in me suspects that they may yet be right.

This is a high risk game which I have likened earlier this week to the pension  game the Government is playing with the pension franchises.

The Government should tread softly, as it’s treading on its citizens dreams.

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From zero to hero – the Hargreaves Lansdown IGC report

Screenshot 2019-04-12 at 12.26.09

How Hargreaves clients see their workplace pensions.

Hargreaves Lansdown’s (HL) 2015 -16 IGC report was embarrassingly bad. I got cross that a successful funds platform didn’t put its back into independent governance. Hargreaves’ Vantage product (now HL Workplace Pension)  was at the time being widely promoted as a workplace pension for medium sized employers engaging with auto-enrolment. What made HL above the law?

Three reports later and the same team are producing a high quality report which provides insight not just into HL’s product, but into the people who invest into it.-

The chair’s statement is written in  a formal business language which is pitched at the experienced investor. HL’s clients are used to this style of communication, HL is not a populist organisation and while this tone might be considered over- formal in some reports (Royal London’s for instance), it is right in the context of the content presented.

As would be expected in a business conversation, the IGC does not admonish  HL where it feels it is failing (for instance in providing management information) but uses a  quiet censure in the style perfected by David Hare of Phoenix.

The effect is to draw us into the conversation and the governance process. It does so effectively. I am giving the report a green for its tone.


The Value for Money Assessment

The HL framework is set out clearly in this table. I think it a good model .

Screenshot 2019-04-12 at 11.14.50

I am not sure I agree with the colour of all the boxes but that is a matter of interpretation. HL is a highly commercial organisation which works on relatively high margins.

There is considerable debate about the charges being taken and I would have liked to see a more robust position than that adopted by the IGC

The IGC notes the platform charge is higher than many other workplace pension providers. However, members also benefit from HL’s considerable buying power, which enables the default and ABC funds to be offered at significant discounts to members.

The result is the overall charges (platform fee and fund charges together) are not out of line with the market and the IGC is content that both the default funds and the ABC funds offer good value for money.

The real issue is whether the entire proposition represents value for money and the IGC continues to keep all dimensions of the offering under close review. At present the IGC is happy to confirm the services provided within the platform fee do represent good value for members.

When phrases like “not out of line with” creep into reports , it is usually because there is a degree of nervousness about the statement. Similarly the rather strained formulation “the IGC is content that” suggests that the usually assured tone is being tested to the limit.

Of course there is scope for pushback on fees but this would be highly contentious (as HL are holding the thin blue line on over £85bn of which workplace is a very small part.

I am genuinely sorry that the IGC aren’t pushing back on HL and platform charges for workplace which are , in my opinion, too high. Put another way, if the IGC is not pushing on charges – who is? The HL juggernaut rushes on unimpeded and those in the cab are worried about what happens when they apply the break?

I like the Value for Money Assessment framework but I would like the HL IGC to be a lot tougher in its interpretation of what constitutes value for money. I will give the VFM assessment an amber and suggest that the management and shareholders of HL aren’t given quite such an easy ride next year!

From the results of its “member” survey – I suspect that the IGC know that many of its members agree with me!

Screenshot 2019-04-12 at 12.23.48

From the setting of previous charts (see top) we should read the right hand wheel as relating to 2017 rather than 2018  (a deterioration of sentiment)


Effective?

One of the problems with the inscrutable style of this report is working out where the IGC has been at work.

Screenshot 2019-04-12 at 12.12.50.png

Following through on each of these references suggests that there is a reasonable dialogue between IGC and HL.

The report sensibly allows us to review the areas where it was focussing last year – right at the start – as we would read the minutes of a previous meeting.

It also allows us to view the areas where it will focus next year (next steps).

Screenshot 2019-04-12 at 12.13.29.png

So I feel comfortable that the day to day business of the IGC is going ahead as it should

And I’m extremely encouraged by the way that the IGC is going beyond BAU to get to grips with the issues of members

Screenshot 2019-04-12 at 12.18.50.png

It’s great to see the numbers of respondents to this survey increasing and for HL to now be sending this to 50,000 policyholders.

This is effective work for the IGC to be doing and I urge anyone who wants to know where to develop their workplace proposition to read what follows.

I am extremely impressed with the work that the HL IGC is doing in this area and give it a green for being effective in helping HL and others understand what should be done going forward.

The report gets a green for being effective


In conclusion

This is a very good report and does both the IGC and HL credit.

I would warn against complacency, the two wheels that look at investor sentiment towards their HL Workplace Pension Value for Money suggests that it decreased markedly in 2018. This may just be because the markets did not do as hoped or it may indicate a more fundamental issue with cost – return – service.

In any event, the IGC can only be faulted for not pushing back on HL over the cost of its plan (which is as the IGC confirm – “toppy”).

I hope that in 2018-19, the IGC will keep pushing for members and keep up this very good work.

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ReAssuring us through its IGC?

reassure1

Purposefully understated image

A word on padding

The first thing you notice about the ReAssure IGC report is stock images. Page one and two are entirely devoted to them, page three and four have one, page five has five and page six is another stock image.   In its first six pages, the report contains a short message from the chair , a few highlights and a table of contents. . The final two pages of the report are stock photos meaning that around a fifth of a short report is expensive to print and tedious to skip over photography.  I hate to say it – but the overdose of images seems to me “padding”. Having just read the Virgin Money IGC statement (which has no photos, I would suggest to Chair Zahir Fazal that next year less (photos) is more! This includes the three identical  photos of Zahir in the report.


Tone of the report

Moving on!

The report is well written, and having met the Chair recently, it sounds like his voice that we are hearing. His chair statement sets out the big issues for members – are funds being invested responsibly, are my policy charges coming down and how can my provider help me get a pension.

I like the way the report gives clear examples of how ReAssure is cleaning up the mess left by decades of neglect on some back books.

The tone is direct and speaks to policyholder’s outcomes. This is exactly what the IGC should be saying, encouraging policyholders to pay attention and take heart.

The IGC clearly thinks that ReAssure could try harder to get policyholders to get a grip on their affairs and it isn’t afraid to mention that other options than ReAssure are available.

It’s a difficult balance between promoting your provider as a way of sorting problems out without being seen to be in the provider’s pocket. Many  of the 51 books that ReAssure looks after have been badly invested, over charged and would show very poorly in terms of outcomes (relative to a benchmark). But this is not a reason for the IGC not to promote upgrading to better Reassure options and I’m pleased to see that this is what the IGC are suggesting.

I like the tone of this report and give it a green, the 85,000 L&G policyholders who will be coming under the ReAssure IGC next year will benefit from a smooth transition into a smoothly operated governance framework.


Value for Money Assessment

The VFM Assessment is published in the report’s conclusion , which means we have to wade through quite a lot of analysis to get there. When we get there , there are the now usual series of dials that point to a mixture of green and amber ratings with no big surprises.

I am not particularly satisfied with this approach as I’m not at all sure the IGC has really done the work needed to opine as it does. The investment section in particular lacks much punch as evidenced by this case study

Screenshot 2019-04-12 at 06.53.46.png

The reader gets the snapshot but is left wondering how he or she compares to Simon. People do want to know how they are doing but unless you are in a small group of funds (of the many offered by ReAssure, you won’t get much from this report.

The section on transaction costs , simply looks at the funds that are internally managed and under control.

Screenshot 2019-04-12 at 07.02.18.png

These numbers have already been quoted (in £sd terms) in the Chair’s statement, but they present only a small part of the picture. I know, because I had a General Portfolio policy that my fund managers had high transaction charges and the IGC is not picking up on the many like me who are suffering! I am not comforted by the report’s explanation for not giving us a full picture of what is going on

I think it’s fair to say that External Fund Managers have been going through a bedding in period during 2019, as they get to grips with using the FCA’s new ‘Slippage Cost’ calculation.

IGCs should be being a lot tougher on providers and their external managers than that.

Member engagement , administration and other soft-factors are explored at some length in the report but to no great effect.  There are frequent expressions of disappointment that members aren’t responding to the questions being put to them (including whether they know what their IGC is). The fact is that most of the issues that members are being asked about are what members are supposed to be bothered with. The reality is that most members are bothered about their money, when they can get it and how it’s done since it was given to ReAssure and that is not what they are getting from this Value for Money Assessment.

I’ll give the VFM assessment an amber – because it is “me too” and inconclusive. The IGC should get a sharper focus – that focus must be outcome based.


Effective?

Clearly ReAssure is working, it’s getting to grips with legacy pensions and offering members a better future. As such it is a hugely important organisation and its IGC has a very important part to play in improving member outcomes.

The IGC has a new member this year who appears younger and is certainly female – both needed in a very undiverse world. I’d like to see an injection of energy into the IGC’s work, especially its work on funds.

As mentioned above, I think there is more that the IGC could and should be doing on fund governance, it should be actively involved in making sure ReAssure are rationalising funds – removing the bad ones and signposting those that are doing their job. There is a lot that can be done by the IGC to ensure that ReAssure’s ESG policies are reflected in what policyholders invest in.

If ESG is to take root within defaults, it is not enough for IGCs to watch and comment, they must not be doing things for regulatory reasons but because they believe in responsible and sustainable investments and I simply didn’t think this report showed this IGC as believing this strongly enough.

Finally , I am not convinced that ReAssure’s customer service is operating quite as well as the IGC thinks it is. I checked out Trust Pilot on ReAssure and its rating – based on recent customer reviews is not that great

Screenshot 2019-04-12 at 07.30.28.png

 

I am – more on the basis of the investment section , than any other – giving this report an amber for its effectiveness. 


In conclusion

Compared to its principal rival – the Phoenix IGC but also to the Zurich IGC , this report felt a little dull , a little too padded and lacking in fire.  That said it is still a good enough report and I am sure that this Committee have it within them to improve further.

I’d really like it to focus on costs and funds as it is in ReAssure’s interest to focus on the rest. The hard part next year will be to clean up the vast array of failing funds and to focus on why those funds that underperform do so.

I hope that those findings will replace the stock photos – next year!

 

 

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Virgin Money’s stakeholder is in special measures – put the IGC in charge.

Sid Vicious didn’t last long at Virgin when the Sex Pistols flirted with the record label. His relationship was as stormy as the Virgin Money’s IGC is with Virgin Money. Things are vicious once again , even if the Pistols and this IGC go about things in different ways!

Last year the Virgin Money IGC became the first to publicly escalate an issue to the FCA and the problem still isn’t fixed.  In a strongly worded statement , VM’s chair, Sir David Chapman has this to say

There is ongoing frustration at the lack of progress being made on how the default strategy is invested. This is from this year’s IGC Chair Statement

You may recall that last year the IGC had found it necessary to involve the Financial Conduct Authority (FCA), the regulator responsible for overseeing stakeholder pension schemes.

We expressed our views regarding the difference of opinion between ourselves and the Provider about the suitability of the scheme’s default strategy. While we were also concerned about fund costs and fund performance the default strategy was our main area of contention.

After several further communications with the FCA, a series of meetings took place between the Provider and the regulator, initially without the knowledge of the IGC, and these continue. To date there has been no definitive outcome. The IGC is in dialogue with the FCA on the matter and both parties are aware of the urgency of the situation and the need for a speedy resolution to our concerns.

Things aren’t getting easier for Sir David as VM embark on a joint venture with Aberdeen Standard which will see the workplace default find itself in a new fund structure. But delays in the JV have been created by the sale of VM to Clydesdale Bank. So the new default doesn’t look like hitting the ground this decade.

As you will have gathered , the VM IGC doesn’t pull its punches and its written in a tone that both engages and enrages. It is the most campaigning of any IGC report and none the worse for that. While others sit on the sideline and moan or – worse – justify bad practice – the VM IGC gets stuck in  – it gets a green for the power of its prose and the good humour which it just about manages to maintain.


Value for Money

VM’s IGC hasn’t a  complicated job, it looks after one product – the Virgin Stakeholder plan in which there are around 20,000 remaining savers.

The Value for Money assessment is a fairly standard affair (apart from it calling its product provider for its failings).

Screenshot 2019-04-11 at 17.45.00.png

Costs have fallen , servicing’s fine , funds aren’t great and the default strategy is a mess.

Every policyholder gets a hard copy of this statement through their letterbox. It is the best circulated IGC per capita of any.

It’s a limited value for money assessment but, for all that – it is doing what it says. It gets a green for its statement,


How effective is the VM IGC?

I am sure Sir David and his team would answer “not as effective as we’d like to be”. The outcomes of years of neglect of the investment default of the VM Stakeholder Plan do not make for pretty reading

Screenshot 2019-04-12 at 05.45.33.png

To sport a racing term – VM is whipping the others in. The fund is still invested in accumulation in UK equities, gets none of the benefits of diversification accross other markets and (net of fees) is underforming more than gross of fees – the fees are still too high despite them falling slightly over the year.

Things get even worse in the period coming up to retirement where the plan still anticipates the average saver annuitising and is therefore investing them into funds that invest in gilts and bonds.

Screenshot 2019-04-12 at 05.51.02.png

Following the IGC’s  referral to the FCA, Virgin Money started a conversation over this with the FCA (unbeknown to the IGC it seems). Just where these conversations led isn’t clear. Certainly no remedial action has been taken to diversify or realign pre-retirement allocations to reflect the use of pension freedoms.

A charge on the IGC for being ineffective is unfair, if a charge is to be made it it to Virgin Money and the FCA. While talks continue, member outcomes continue to deteriorate

Nevertheless, so long as this sorry state of affairs continues, I’ll have to call th VM IGC less than effective, though that appears to be a systemic problem with IGCs capacity to deal with a reluctant and insouciant provider. I give the report an amber for effectiveness, (but it would get a deep green for effort)


Not a problem with this IGC , but a problem for IGCs

Virgin Money is not the only product proposition that is underperforming, within the portfolios of many large insurers there are pockets of poor performance and high outcomes. The workplace book of Old Mutual is all pretty much failing its policyholders.

But Virgin Money’s IGC is the only IGC that has publicly whistle blown on its provider and I’m sorry to see so little impact of that bold move over the year. Recently I wrote of the FCA’s complaint that not enough of its stakeholders were blowing the whistle, the response on social media was immediate and forceful.

IFAs tell me that whistle blowing doesn’t work. The VM IGC is inferring this and so long as the FCA continues to fund its entire whistleblowing team at less than the salary of its CEO, it will continue to skate on thin ice – when criticising others.

The message to the FCA  is clear, the VM IGC has called the problem , now act to put things right. Virgin Money should be in “special measures”, why not put the IGC in charge? 

 

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The Government’s pension stealth tax

virgin stagecoach.jpg

What are we to make of the disenfranchisement of Stagecoach from rail contracts?

I am extremely concerned by this statement , reported in the Financial Times

 Stagecoach said its recent bids had been non-compliant “principally in respect of pensions risk”. Mr Griffiths and others in the industry said the Pensions Regulator had been suggesting train operators would need to make increased contributions to the railway pension scheme in case the government did not fully fund it. Stagecoach said the gap could be £5bn to £6bn across the sector.

This should be read together with a second statement to be found in the FT report.

 Franchise tenders expected the winner to bear “full long-term funding risk” for pensions, Stagecoach said, which it declined to. While other bidders accepted this condition, Mr Griffiths said the gap “could be very significant over the long term, that was why it was an unacceptable risk and chance to expose our shareholders to”.

On the face of it, Stagecoach are refusing to take a risk transfer from Government to the private sector of obligations to the Railways Pension Fund.

I can quite understand why Griffiths and his partner Richard Branson are crying foul. The Government are moving the goalposts – or rather making the franchisees profit-goals a whole lot smaller. That’s not fair on shareholders and it won’t be fair on passengers, who will get the pass on.

Subsequently the FT have published a second article that hints that t pension clauses in franchisee tender documents is at the Pensions Regulator’s instigation aimed  to protect the PPF from another Carillion and members of the Railway Pension Fund from a weakened covenant.

The article also points out that no-one knows the current state of the Railway Pension Fund’s funding. I was struck by one reader’s comment

Unless the client (franchisee) is is able to separate out controllable risks and ring-fence and pool those, such as pensions, that are uncontrollable they’ll end up awarding contracts to the most cavalier or those with the deepest pockets rather than those best placed to deliver the service.

One  question is why other bidders are prepared to take this risk, another is why members of pension funds which previously had a gilt-edged covenant should be asked to accept a covenant from a rail franchisee in the first place.

A job on the railways came with a state backed pension which was understood by everyone. This point is well made by Mick Cash, general secretary of the RMT railway workers’ union, who warned that his members’ pensions

“are not there to be used as bargaining chips in a row between the train companies and the government”.


Same with schools and universities

Having allowed membership of the teacher’s pension scheme on benign contribution terms, Government is now turning up the heat by requiring schools and universities to pay a whole lot more to participate in the teacher’s pension scheme. For those footing the bill today, it’s a stealth tax on students and parents tomorrow.

This is fine so long as this was always baked into assumptions but it wasn’t and the increased costs are not budgeted for and will become a stealth tax paid by students and parents.

Sympathy for those enjoying higher and private education may be less than for railway workers but the same issue applies. The Government is the insurer of last resort for millions of pensions and the deal between the pensioner and the Government is based on there being a state promise backing the retirement promise.

I don’t get the policy statement that backs up this change in the Treasury’s pension strategy. I don’t see any of these changes in the way the private sector is being to take on public sector pension obligations as a matter of public debate.

I have no particular candle to burn for Stagecoach, other rail franchisees , private schools or universities, but I don’t see why people’s pensions and livelihoods can be put at risk so that the public purse is protected from making good on public pension promises.

Stop me if I am missing something, but I sense that there is something not quite right in all this . I feel like Martin Freeman

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Fidelity’s IGC-the bland leading the blind

Fidelity

The general reader is introduced to the 2019 IGC report with a statement from Fidelity

An IGC is an Independent Governance Committee whose purpose is to represent the interests of policyholders (including active and deferred members) in the company’s relevant schemes.

“Policyholder- member (active and deferred), company, relevant”… in one sentence the ordinary reader has been presented with a bunch of concepts, none of which are explained, many of which remain mysterious even to me. What company – how relevant – what schemes?

We are then told that the key duty of the IGC is to “report to the FIL Life Board”. The ambiguity in “report” going unexplained though most readers will assume the IGC is part of Fidelity’s board structure rather than independent of it.

This from one of the world’s premier consumer facing financial services brands.

Fidelity’s book of workplace pensions is sponsored by some of Britain’s leading companies who maintain a paternalistic attitude to their employees’ retirement.  Funding levels on Fidelity policies are well above AE minima and as many of their “schemes”, were established to replace DB, the funding level reflects historic contribution levels to provide guaranteed inflation linked pensions.

For Fidelity, DC is still thought of as a DB replacement, hence the confusion over language and the ambiguity over the IGC’s purpose.


Tone of the IGC

The  IGC Chair statement repeats this confusion . It still talks of “deferred members” as people who’ve left employment as if all workplace pensions are trust-based (most of Fidelity’s aren’t).

The IGC is here for people in Fidelity GPPs where people have individual contracts  with Fidelity. The schemes are reported on by trustees who produce their own VFM assessments.

This may account for some very confusing messaging in the early part of the report. The first half of the report deals with guidance to members as to what to do.

The “rules of thumb” that appear at the front of the report appear to have been dropped in from another context.  I was left asking 7x what? , 13% of what? Why 35%?

Screenshot 2019-04-10 at 13.29.46

If this document is trying to help savers, it needs to be a lot more precise.

Kim Nash has been chair since 2015 and the Fidelity IGC is now a stable and experienced unit. This shows in the report’s  assured tone and consistency but the content looks like it’s been cut from elsewhere and de-contextualised.

These infelicities  are unfortunate but particularly unfortunate as they precede the first section of the report that focuses entirely on communications.

It is not until page 11 of a  page report that we get away from the “customer experience” and move on to value and money.

The placid contented tone of the report is appropriate for a customer base who by and large will do very well out of pensions. But I think the messaging is lazy and this suggests a complacency which – even for well heeled Fidelity customers – is misplaced.

I’d like to see future reports be clearer to members that the IGC is not an independent trustee and that it negotiates with rather than reports to the “FIL Board”. I give the tone an amber – despite the report being well crafted.


VFM -Bland leading the blind

Screenshot 2019-04-10 at 15.55.06.png

When people carry banners, they usually have something to say. The Fidelity report ends up saying very little, in a very nice way. See picture above.

There is a lack of bite about the VFM assessment, it’s  hard to engage with a report that seems semi-detached from the matter in hand.

This is the problem when IGCs are too corporately aligned, they really give themselves no space to speak their minds.

Last year, I commented on the extremely high transaction costs in the  Fidelity default fund strategy. Last year’s IGC report did not pick up on this but I’m glad to see that Fidelity have changed the strategy to that the transaction costs paid by those who make no choice, is relatively low cost.

Screenshot 2019-04-10 at 18.03.45

It will be interesting to see whether the revised strategy will deliver as much value as before, my suspicion is that it will.

I would like the VFM assessment to be telling us what value members were getting for the 0.39% transaction costs they were paying but the report is silent on fund performance.

For all the talk of participating in  benchmarking surveys, the only information given to policyholders is this table.

Screenshot 2019-04-11 at 06.44.44.png

Not only are the returns gross of the overt charges (see below) but they have no context – we simply aren’t being told what value policyholders are getting for all that money they are paying.

No sooner have we started talking about investment and costs than we move on to talking about Fidelity’s future plans for web and phone apps.

There really is no proper discussion of  VFM in this report and the reader will be left wondering whether they really can leave Fidelity to it.

Bland assurances from an IGC are not enough. The VFM assessment in this report is simply not there, what is there is a report on engagement tools. For its lack of disclosed analysis of what is actually happening in Fidelity funds, I give the VFM assessment an amber. That number could have been a red other than the IGCs previous reports lead me to believe that a more thorough analysis has been carried out

Simple and transparent? Or simply ineffective?

The IGC believes that Fidelity’s fund charges are simple and transparent in structure, as all explicit costs are included within the ‘Total Expense Ratio’, quoted to you in the Investment Choices Guide and the Fund Factsheets. Fidelity’s fund charges cover the cost of investing your money as well as administration and communication services provided by Fidelity. All charge cap requirements have been met over the year.

This is not simple or transparent. The total cost of owning a Fidelity fund is the Total Expense Ratio  plus the transaction costs. The transaction costs are still weigh above industry norms – despite having fallen from last year’s analysis.

It is quite likely that some customers last year – paid more than the charge cap in terms of total cost of ownership. We will not know because the report glosses all this over.

Once more the reader is frustrated as they simply can’t get engaged with the real issues. Once again I feel that Kim Nash and her team know a lot more than they are disclosing in this report and for its lack of disclosure , I cannot award the report a green so I report it an amber.

As elsewhere, I feel confused and frustrated , concerned that the IGC is acting as a benevolent paternalist rather than the policyholder’s advocate.


Fidelity IGC needs to be clearer as do Fidelity

I have seen a benevolent seeming life company go wrong, it was called Equitable Life. It went wrong because it was trusted too much and allowed to get away with it. I don’t think that Fidelity is an Equitable Life but I do think they are allowed to get away with too much by the IGC.

The confusion between members and policyholders, the lack of precision in the rules of thumb, the failure to engage with high transaction costs, the lack of context in the analysis of performance – all add up to a lack of scrutiny,

The remarks from Fidelity quoted at the top of this report, suggest that Fidelity don’t really understand why they have an IGC. That is a very dangerous state of affairs and I hope that Fidelity and their IGC pick up on this.

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Zurich’s IGC – keeping Zurich honest.

zurich

Zurich ‘s IGC Chair’s statement is out ; it’s punchy. It’s chair, Anna Bradley has a much wider sphere of influence than just pensions and it shows. This is from her opening remarks

…you have told us that service standards for pensions should be as good as those in other sectors. So, we have asked Zurich to give us better information about how they compare with other similar companies, and other sectors. This will allow us to agree service standards for the future which are likely to be more challenging.

For the first two decades of this century, Zurich was a progressive provider of corporate pension services  to employers and trustees. It has recently dispensed with this business to Scottish Widows leaving it with a legacy of lacklustre workplace arrangements set up by Eagle Star and occasionally – Allied Dunbar.

Zurich is neither dedicated to pensions legacy (see Phoenix and ReAssure) nor actively marketing its services. The job of the IGC is particularly important in keeping pensions relevant to an organisation more interested in other financial services.

This report shows that the IGC feels it is up to the task.


The right tone of voice

The work of Laurie Edmans in listening to Zurich’s savers and addressing their issues, continues under Anna Bradley. Indeed Laurie remains on the Committee.

The report reads, as other successful reports have done, like a newsletter. But it is a stern report which makes no friend of Zurich, it keeps a proper distance. In the light of some of the issues it has  with its provider, this is no bad thing.

There is a precision in the language that makes for short sentences and clear statements that people can understand. Knowing Anna Bradley a little, I suspect that this is from her own pen.

I really enjoyed reading the report and give it a green for its tone of voice


Value for Money Assessment

The criteria chosen to assess value for money are not the criteria I would have chosen. The problem stems from the early days of the IGC when the answers received on “what matters” may have been distorted by some odd framing. Here is the assessment framework

Screenshot 2019-04-10 at 06.08.30.png

The assessment for the modern book is similar – though service levels are assessed lower (something noted in the Scottish Widows report – which analysed the same issue).

The modern book scores a green on Zurich’s competitor comparison while the old book (which need not compete) is neither good nor bad.

In both the modern and the illustrated older book, members are not being properly engaged or supported.

My worry is that the value for money assessment is overly reliant on performance against industry benchmarks rather than the reasonable expectations of savers.

The difficulty with benchmarking is highlighted by the report

It has been more difficult to come to firm conclusions on whether Zurich is reasonably in line with the rest of the market for older-style pensions. We had hoped to have industry benchmarking data available to use for this report. However, discussions between pension providers have been slowed down because of the very broad range of older-style pensions.

The one thing that older style pensions have in common is that they all produce similar outcomes – typically a capital sum based on money in, investment performance (net of charges) and time invested.

Zurich may be “compliant” , “efficient” and “competitive” with others, but these are values that make the pension book valuable to shareholders. These aren’t relevant measures for savers who are interested in good outcomes.

Neither its assessment of modern or older pensions suggests that Zurich is really providing value for money right now and – despite introducing the “green star” for “going beyond”, the IGC finds no opportunity to use it.

The IGC is not pulling its punches in its assessment and that is proper.

But I am not convinced that the Zurich approach properly focusses and measure good outcomes, nor am I sure that Zurich’s legacy book is giving many members good outcomes. So I am giving this report an amber for it’s value for money assessment. 


Is the statement showing the IGC as effective?

While Zurich regarded workplace pensions as what they did, the IGC was extremely relevant. The danger is that it now becomes less relevant and the years ahead are going to be more challenging for the IGC.

Bradley is showing she takes her role very seriously and I have confidence that she will keep UK Zurich’s attention, at least while it is being run by Jim Sykes. The worry is that if the UK management changes, the task will become more difficult.

So the decision of the IGC to focus on the efficiency of the older pension books is sensible.

During the year we have agreed five broad types of indicator that we think are important for this principle:

(1) Profitability;

(2) Direct salary costs;

(3) Direct servicing costs;

(4) Indirect costs;

(5) Investment in technology and systems.

This is the first time I have seen an IGC acting as a management consultant to the provider. It suggests that the IGC recognises that the biggest risk to savers is that they are abandoned by a shareholder who not only deems the IGC irrelevant – but equally policyholder outcomes.

While I don’t think that Zurich’s efficiency should form part of the VFM assessment, I do think the IGC can be most effectively employed providing help to Zurich on how to manage its legacy business for the good of its savers.

On a less positive note, the report does not properly address concerns about the true cost of Zurich funds, referring those interested to a link which takes us to another link which takes us to big spreadsheet in tiny fonts which is frankly a world away from engaging

I don’t get the impression that the IGC is bothered. It should be. While it has a limited resource, it needs to get information presented to it better and to present the information to savers better than this.

The IGC reviewed transaction cost data provided by Zurich for all funds in July 2018. We noted some significant differences between funds and challenged Zurich on the way they would use this data to better assess these costs to the benefit of members…. the IGC is satisfied with Zurich’s progress in relation to transaction costs.

I prefer the statement

The IGC specifically encouraged Zurich to focus on two areas this year: Transaction costs and Environmental, Social and Governance (ESG) Policy

More needs to be done by both Zurich and its IGC on these important aspects of Value and Money.

Despite being weak on its analysis of outcomes , of investments and investment costs, I see the Zurich IGC as an effective champion of its savers interests and give it a green


In conclusion

This is a punchy, aggressive report which I like. I think the IGC needs to be more outcomes focussed and review the components of its VFM assessment. It needs to be more focussed too on what is going on within the fund range managed by Zurich (see immediately above).

The report could also do with a bit of smartening up, the stock images are too big, the tables too small and overall production values aren’t what I’d expect from a wealthy insurer.

But if we get an effective IGC in 2019-20, as I suspect we will – these will be minor criticisms. The big task for the IGC is to keep pensions relevant, not just to savers, but to Zurich.

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Royal London IGC – the regal treatment!

 

The 2019 IGC report – a good read

I haven’t given much thought to IGC production values, but they’re the first thing you notice when you scroll through the Royal London IGC report. Someone has spent some time and money making this document look and read well.

The product of new Chair Peter Dorward, but the chatty easy style of the IGCs 59 pages is a world away from most of the reports I’ve read this year. You should be able to access the report  here  (moan to me at henry@agewage.com  if you can’t and I’ll send you the PDF)

Here’s the summary page (notably not an “executive summary”)

Screenshot 2019-04-08 at 14.12.58.png

Other IGCs take note – the bar has just been raised.


Royal London – more now than a work in process

Royal London is an unlikely success story, a rag tail and doggie bag of unloved and unwanted life companies, it has grown to be the favourite life company of advisers and an increasingly recognisable brand due to its advertising and sponsorship. It has a charismatic CEO in Phil Loney (leaving this summer) and a pensions policy team that includes Sir Steve Webb. I own to being a convert and in case anyone thinks I’m not owning up to it, Phil and I get on very well.

Which is odd, because in years gone by I have been critical of Royal London’s behaviours. It didn’t offer itself to the general public as a workplace pension provider , insisting people came to it through a financial adviser, it has some amazingly bad legacy pensions on its books and its IGC reports read like marketing documents!


A moan about tone.

I’m afraid to say that whatever’s in the water drunk by Phil Green , is still there!

This is the first heading of the report

Screenshot 2019-04-08 at 14.26.46.png

Who wrote that? Was it the Royal London marketing department? Anyone who comes to the report looking for independent governance is immediately on their guard!

This headline is in keeping with the general tone which is loaded to promote the Royal London proposition

In this paragraph I have highlighted the words that are loaded to promote a favourable impression of Royal London

Royal London continues to make changes to how it manages your pension and how it communicates with you. We reviewed the following enhancements made for workplace customers:

o Introduction of a new annual statement for Retirement Solutions workplace customers

o Communications related to an increase in required minimum contribution levels (known as phasing).

o Developments in the communications and support provided in the years nearing retirement.

o Communications explaining changes to workplace customers’ default investment.

o Changes to employer microsites to provide a better customer experience.

o New services introduced to support advisers review the quality and service being provided to workplace pension customers of Royal London and other pension scheme providers.

It’s one way traffic and its relentless throughout the statement. It’s wearing and it’s boring and can someone please bring a little balance in here!

Although this is a very well written report I am not happy with its tone, I am tempted to give it an amber because it  doesn’t sound “independent”.  But I won’t – I’ll give it a green – because this is the best written report I’ve read this year (and there have been some good ones),


Value for money

Has the Royal London IGC done all it can to report effectively on the value for money that savers are getting?

The short answer is “yes”.  In line with the chatty “newsletter” style of the report, the VFM assessment starts by asking Royal London savers what they think of being in a Royal London workplace pension. This was done through YouGov who asked questions of savers with other workplace pensions. Here are the results.

RL VFM.PNG

The purple bars are Royal London’s the others are anonymous.

While we have to rely on YouGov and Royal London’s integrity that these are peer to peer comparisons. My experience of working with Royal London customers is that they are better informed because they are better advised and this is a vindication of Royal London’s insistence on advice being part of the employer’s selection process.

In a world where there is little engagement, Royal London employers and their auto-enrolled staff are likely to be better informed and so more likely to get value for their money.

This type of VFM assessment is fine, so long as it is backed up by quantitative research on whether VFM is actually being delivered in terms of outcomes ( as well as perception).

This is where the Royal London IGC report works best. When it moves away from soft values , it demonstrates a proper understanding of what makes for good outcomes.

RL VFM 2.PNG

Many of these measures are very specific to an advised proposition – “appropriate investment returns”, for instance. Not many workplace pensions can expect to see customer’s expectations of returns relative to risk, but this is what Royal London aspires to get.

In a world where standards of engagement are low, the mere aspiration to have this level of engagement (if only as a result of advice to employers) is encouraging, but it is also limiting.

There is only so much of these kind of employers, the Royal London strategy of selecting to work with IFAs is not “mass-market” as say NEST or NOW or Smart or People’s Pension is mass market.

The IGC report doesn’t really focus on this.  It has to be said that Royal London’s strategy is underwritten by employers choosing to take advice and this self-selection enables these ambitious VFM measures to be relevant.

The bulk of the report deals with how the IGC sees Royal London performing against these measures and there are some really good sections which engage the reader in the issues behind ESG and responsible investment.

I encourage anyone with an interest in workplace pensions to read the central sections of the Royal London IGC report , to understand what can be done. I have no problem giving the VFM assessment a green


How effective is the IGC?

As mentioned before, the report in tone , is biased towards the provider.  It leads us to wonder how hard the IGC is pushing back on the provider to get members a better deal.

Royal London’s relationship with it’s IGC is clearly very strong. The reporting in this report bears out the IGCs claims to getting what they want from Royal London and I am impressed by the granularity of the analysis of transaction costs , performance (relative to competitors and relative to expectations set by Royal London to it customers.

The impression in the detailed sections of the report is that the relationship between IGC and provider has matured over time (I have in the past been critical of the IGC for not showing the granularity and I’m very impressed that even in the most detailed sections, the report stays focussed on explaining what things mean in a way that savers can understand.

There are areas that I would like to see more engagement with. Royal London has taken in a huge amount of new money from DB transfers (as evidenced in its reports). I have no issue with this, this is an adviser matter. However, most of the new money has not gone into Royal London’s workplace pensions but into its SIPP and I wonder whether this is always in the best interests of customers who typically pay more for self-investment .

I’d like the IGC to look into this next year and push hard to Royal London to understand what drives the decision on which product to transfer into and whether the workplace pensions that Royal London offer could be better used.

If ,as seems likely, the scope of IGCs is extended to deal with non-workplace pensions and into the drawdown phase of a personal pension , then this is an area where the Royal London IGC could prove really useful.

Although it means giving Royal London three greens for this report , I am going to give the IGC a green for being effective.


Conclusion

There can be no better barometer of an insurer’s commitment to workplace pensions than its IGC report.

This report does Royal London credit (though it shouldn’t shout its sponsor’s praises so loud).

It’s bursting with good information which advisers, employers and savers can get stuck into.

I am really pleased that in his first year as Chair, I can give Peter Dorland’s report a clean bill of health and congratulate him on a first rate Chair’s Statement.

 

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This new year – let’s know what pensions cost.

 

It’s a new financial year – let’s make sure it’s a good and honest one!

Last week saw every man (and his dog) involved in discussions over what we should see and how we should see about pension charges.

The Pensions Minister and the Treasury Minister John Glen were called in front of the Work and Pensions Committee to explain what Government were doing. It was a pretty unedifying spectacle likened by one who was there to an FA cup qualifying round played on a muddy pitch to a goalless drawer.

You can watch proceedings via this link but too many questions were half-formed and answered by the wrong people. BREXIT was playing out in the back-ground and this session seemed a sideshow.


Charges and the dashboard (mudslide pt 1)

The following day , said Pensions Minister – Guy Opperman announced the consultation response on Pensions Dashboard, to a flat reaction from a weary “industry”.  Those who campaign for full transparency groaned

The DWP and others have done research  which suggested that members had no idea they were paying anything for their pensions. To now mandate that costs are a dial on  the dashboard – rather than on a link say to a provider website- carries a little too much risk.

To get where we are today took a series of consultations in 2017-18 and the resulting disclosures  have not yet been fully rolled out. The last schemes report charges and costs in November of this year. So I’d expect the Government prefer to let the market settle for a couple of years before  mandating inclusion of costs in in the dashboard.

The pitch is not so much waterlogged but buried by a mudslide of timidity.


The new 2 page simpler pensions statement (mudslide pt 2)

I also gather  that talks between those developing a simplified pensions statement (Ruston Smith/Quietroom with the support of the Transparency Task Force) are in ongoing discussions with the DWP about including the cost of what we buy on the shopping till (well Ruston does run Tesco’s pension scheme)

On the face of it, this idea is likely to be buried by the same mudslide , at least if the demand is for compulsory cost disclosure on the statement

That said, were insurers and trusts  to voluntarily choose to  include their costs on pensions statements, I doubt the DWP would  have a problem.

I suspect that  we’ll en up with  two versions of the Smith/Quietroom statement, one with and one without charges information.  It will be interesting to see whether the ABI and PLSA endorse one or other or both.


2019 IGC chair statements

I said last week was a busy week for cost disclosure, so far I’ve analysed  chair statements (with promises of several more which have yet to reach me)

Phoenix kicked off the reporting season with an accomplished statement on what we pay; report here

Scottish Widows have done a great job of disclosing what they can get from fund managers; report  here

Aviva have also reported well; report here

Standard Life has reported expertly (if a little dismally); report here

L&G has thrown the kitchen sink at policyholders; report here

Aegon has given some shocking numbers without naming names ; report here

While Old Mutual has decided to kick the can down the road another year; report here

There are  three themes coming out of the report.

  1.  Despite our being a year and a quarter since the launch of MIFID II, providers are still having problem getting complete information to their IGCs
  2. The MIFID methodology for capturing hidden costs is biting. “Slippage” is working- though occasionally throwing up anomalies like “positive slippage”
  3. There are some outliers in terms of undiscovered costs that make cost disclosure very important,

Help is at hand

In response to industry demand (or possibly a kick up the jacksee from the CMA, Aon has helped Chris Sier set up ClearGlass ( a sister company to AgeWage) which is helping fiduciaries needing to meet DWP or FCA requirements to disclose costs as part of VFM reporting. ClearGlass are – as you’d expect from Dr Sier, using the approach developed by the FCA’s Institutional Disclosure Working Group (IDWG)

Novarca continues to offer this help , together with consultancy services designed to dig deeper and to help fiduciaries reduce costs (where mandates allow).

There are other players in the market, including custodian KAS bank, offering expertise.


How things look in the first week of a new financial year.

It’s been 7 years that Alan and Gina Miller launched their True and Fair campaign, my first exposure to the concept of “hidden charges”

It’s been 6 years since I first started working with Novarca on charges. Novarca provided an important report to the FCA which led to the FCA consultations that led to the setting up of the IDWG.

And it’s been 4 years since Chris Sier and Con Keating encouraged Andy Agethangelou to set up the Transparency Task Force

In 2014  we had an OFT report demanding better disclosure and leading to the formation of IGCs. In 2017-18, the CMA demanded more from investment consultants, Over the period we’ve had various FCA consultations and working groups demanding better disclosure.  And we’ve had an ongoing legislative program from the DWP legislating for cost transparency.

Progress is painfully slow – but progress there is.

In parallel we have had MIFID and PRIIPS legislation from Europe telling us what should be disclosed  and how.

In 7 years, we haven’t moved a long way. We are still in fear of giving people too much reality and financial till receipts still don’t tell us what we’ve paid for our goods. Our pensions dashboard won’t tell us how much fuel we’re burning and  some IGCs are still not disclosing to the few people who read them, what is really going on.

Progress is painfully slow, but progress there is. This blog will continue to push for a True and Fair , transparent cost disclosure . AgeWage is committed to delivering better information to people on which to make their minds up. We will support dashboards and statements that tell people how it is, not how the marketing departments want us to see things. We’ll keep pushing Government to keep mud off the road.

new tax year

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