The American view of Dutch Pensions – tickled!

Today’s financial Goldilocks moment—with strong equity returns and robust fixed income yields—creates favorable conditions for the Netherlands to complete its long-planned switch from traditional private defined benefit plans to ‘collective defined contribution.

‘You can almost call it a tontine,’ a Dutch pension consultant told Retirement Income Journal. (RIJ)


As of January 1, 2026, private defined benefit (DB) pensions in the Netherlands have begun converting to collective defined contribution (CDC) plans, as mandated by the Future of Pensions Act, enacted by the Dutch parliament in mid-2023.

An estimated 9.5 million individual pensioners with savings of €1.8 trillion are on the move. By January 1, 2028, all of the Netherlands’ employers, unions, insurers, and premium pension institutions must comply with the new rules.

CDC is a hybrid of 401(k) and DB. In the Dutch version of CDC, workers and employers make mandatory tax-deferred contributions (27% of pay; 18% from employers and 9% from employees) to collectively-managed funds.

Relative to DB fund managers, CDC managers have more latitude to invest in high-yield alternatives, like private credit. Some observers predict that CDC could deliver a 7% increase in retirement income pay­ments. The manager of the largest pension fund estim­ates the trans­ition could boost invest­ment in private equity and credit invest­ments by about five per­cent­age points—or €90bn—over the next five years.

While participants have “personal accounts,” and accumulations at retirement depend largely on contributions and performance of the collective fund over their lifetimes, the accumulations are not liquid and are paid out only as annuities starting at age 67. A rule that might allow 10% lump-sum distributions at retirement is still in limbo.

“Participants can see their returns and their costs online, but with the collective mandate they don’t control their own pots,”

Annette Mosman, CEO of APG, manager of the civil service pension plan ABP, the largest Dutch pension fund.

“There are 20 life-cycle groups [with age-appropriate asset allocations, target-date funds]. The normal retirement age is 67. When you reach age 55, most schemes will let you see what your benefit will be at 67, based on your current salary and assumed returns of 4% to 5%. Our target replacement rate is 70% of the average salary,”

she said.

“You could almost call it a tontine,”

Jorik van Zanden, a pension consultant at AF Advisors in Rotterdam, told RIJ. No government, corporation or insurer provides guarantees that participants will receive a fixed or rising income for as long as they live. Instead, the fund is managed for long-term sustainability. When participants change jobs, their savings follows them.

Dutch unions, employers and government started talking about DB pension reform some 15 years ago, when low interest rates were crippling plans’ ability to pay inflation-adjusted benefits. Today’s financial Goldilocks moment—with strong equity returns and robust fixed income yields—creates favorable conditions for the change. Workers’ accrued benefits in their old plans are credited to their new plans.

Each industry sector in the Netherlands designs its own pension plan and chooses among more than 100 fund managers. Participants in each plan pool their longevity risk; when participants die before retirement, their notional share of the assets remains in the plans.

Participants also share investment risk. Ten percent of contributions go into a “solidarity reserve.” With market appreciation, the reserve can grow to as much as 30% of the value of the fund. If losses at the fund level threaten to reduce the fund’s ability to meet targeted payout levels (70% of the average wage), the reserve makes up the difference.

“So, if I retire a day before a crash, there’s a possibility that the buffer will dampen the impact,” van Zanden said. It’s called a solidarity reserve, because, by funding a buffer fund, the young to some extent might be paying for the old. In the Netherlands, we prefer certainty to the possibility of higher income.”


“The reserve or buffer will be use when markets work against us, and makes sure that no groups see their benefits shortened,”

Mosman told RIJ. It’s worth noting that Dutch CDC entails a single fund into which money is contributed and invested and from which benefits are paid, rather than having two: a risky accumulation fund and a safe distribution fund.

The single-fund approach makes the “smoothing” mechanism possible, keeps all the money invested for potential “raises” in payout rates, but eliminates any chance of guaranteed lifetime income.

There are more than 100 pension funds in the Netherlands, with some €2 trillion under management. The three largest are ABP (for civil servants), PFZW (for the health and welfare sector), and PMT (for engineers and metal workers). They account for about two-thirds of total private pension savings. Dutch plans invest globally and have no obligation to buy Dutch government bonds or to support any particular Dutch industry sector, Mosman said.

Like many countries, the Netherlands has adopted a “three-legged” retirement security model. There’s a basic “first-pillar” pension (the “AOW”) that accrues at the rate of 2% a year for everyone who lives or works in the Netherlands. It is pegged to half the minimum wage. In 2025, the gross monthly payment was €1,580.92 for a retired single person and €1,081.50 for each member of a retired couple, excluding an 8.00% holiday allowance paid annually in May. For those with excess savings, there’s also a “third-pillar,” which resembles U.S.-style 401(k) plans.

For the Dutch, the British and American practice of swapping out a DB plan with a group annuity issued by an insurance company (via a pension risk transfer, or PRT) wasn’t an option, because retirement plans are designed at the industry-sector level, by management and labor, and not sponsored by single employers.

The American practice of closing a DB plan and offering a simple 401(k) wealth-accumulation plan to new employees wasn’t possible in the Netherlands either, where workers had grown accustomed to pensions.

“Each industry sector had a choice between a ‘flexible’ CDC variant and ‘collective/solidarity’ variant. The flexible variant is more like U.S. defined contribution. Most sectors chose solidarity, which surprised many of us. This variant is a good midway point between DC and DB,”

Mosman told RIJ.

“It allows the social partners in each plan—the unions, employers and the government—to choose the size of their solidarity reserve. Their actuaries have to demonstrate that the size of the buffer works for all of the age-cohorts in the plan. The reserve or buffer will be use when markets work against us, and makes sure that no groups see their benefits shortened.”

It’s hard to imagine American workers giving up the liquidity and self-directed investing aspects of 401(k) plans, and equally hard to imagine U.S. employers accepting mandatory contributions (on top of payroll taxes). Some U.S. 401(k) plan sponsors are embedding optional deferred annuities in their plans.

But most Americans, unaccustomed to thinking about their 401(k)s as retirement income vehicles, have yet to embrace such options. History suggests that it’s easier for workers to convert to a CDC plan if they’re coming from DB plans—where there was no liquidity—than if they’re coming from DC plans—where there was.

“Life-contingent savings and payments only work when they’re compulsory,”

Per Linnemann, a former chief actuary of Denmark, told RIJ.

 “It would not be attractive in the Anglo-Saxon countries and in Denmark, where you have a choice.

“It may be more appealing to combine income-drawdown with longevity-sharing and survivor benefits at a very old age, when they have the biggest impact,”

he said.

“By that time, the bulk of the savings will have been paid out as retirement income. This may mitigate participants’ loss aversion when facing the risk of losing a large proportion of their savings if they pass away early in retirement.”

Linnemann is describing, in effect, a program of systematic withdrawals from investments starting at retirement, coupled with a deferred income annuity starting at age 80 or later. Retiree with adequate savings can create such plans themselves, but they’d pay retail for the annuity.

Companies in the Netherlands that don’t belong to any existing sector can choose the flexible variant of the new system, which is like a 401(k), and doesn’t require mandatory contributions to a CDC pension—if they don’t belong to any sector that has a pension.

Booking.com, for instance, claimed that it was a tech company, not part of the Dutch travel sector.

“The new corporate models don’t want mandatory contributions. But that’s the strength of the system,”

Mosman told RIJ.

Last March, the Dutch Supreme Court rejected Booking’s claim and must participate in the travel sector CDC. The ruling forced the Amsterdam-based company to sign up for the scheme and make back payments dating from 1999, at an estimated cost of more than €400 million.

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My home is no longer my pension – London estate agents tell me!

It is a recurring theme that plays in my head from my days selling pensions to my peers back in the 1980s and 1990s (when it was my job).

“My house is my pension”

Those of us. many of us, who had purchased at up to 100% of the value of the property were sitting on equity that so outweighed the value of our personal pensions to make the comparison useless, we would have enough money from property to sell up or rent out of borrow against our property and what was the need of saving pounds a month into a pension pot?

What we did not expect is what many people have got, a maudlin market and in some cases, such as leaseholds in London, a falling market. The FT report the widespread incidence of people selling their flats at a loss.


Valentina Romei reports for the FT.  A higher proportion of homes in London were sold at a loss than any other region in England and Wales last year, according to a study, in the latest sign of weakness in the capital’s property market.

Hamptons’ analysis of Land Registry data shows that 14.8 per cent of London sellers sold for less in 2025 than they originally paid, above the national average of 8.7 per cent.

It is happening in my block where people at flat-holder meetings say they are not selling because they can’t cover their mortgage or because it leaves so little equity that there is insufficient to make the move to anywhere they like (they live in a lovely place in the City of London).

But one person said to me that she had hoped that she could sell her home to give her cash in retirement to “bump up” here meagre retirement savings and I suspect that more in the room were of the view that the place in the City might be worth some release of equity. The harsh reality of the situation came over us when we found we were all in the same boat.

Of course it is worse for leaseholders, caught in the grasp of freeholders with ground rents and service charges making it feel like renting (even when on 90 year leases).

Aneisha Beveridge, head of research at Hamptons, said:

“In London, upward house price growth is no longer the one-way bet it once seemed.

In some cases, even owners who bought a decade ago still face getting back less than they paid, something that would have been almost unthinkable in the heady days of 2015,”

she added.

This is the picture that Hampton have found from their research.

There are very few “flat for sale” signs up in my part of the City. Many of us are waiting for some news from the Government to get our neck out of the noose that freeholders have it in. But it is more than just the leaseholder problems, the fact is that property in London and the posh areas around it, is no longer a deliverer of pensions through the owning of property.

I’m sorry but that fool you remember coming to your door with a fact-find and an application for a personal pension may have had to be right at some point, It took many years for the euphoria of property ownership to turn to ennui but it has.

My property will not be my pension and never should have been thought of being. Pensions are the sensible way forward, boring as their progression may seem. We in London are just learning how it feels in other parts of the country!

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Why it’s easier for bankers to do private credit – but is it better for the rest of us?

Doubt has been shed on the objectivity of the discussions in the House of Lords. They’ve been carried on by former partners of City Solicitors. 

My correspondents Tim Simpson and Byron McKeeby have been going at each other over selective discussing and selective reporting (in the case of Citywire)

If we are interested in private credit, and I think we ought to be, it’s worth getting to the bottom of what these lawyers said in the House of Lords discussions , complete rather than selective. Here’s Byron in conversation with Tim ..they’ve been arguing over an incomplete account from this Citywire.

As for Citywire’s selective reporting of the report, that’s why I posted a link to the whole report, which if it’s so relevant is either worth reading in its entirety, or not.

I leave interested parties to draw their own conclusions to these particular exchanges in oral evidence to the Committee, which seem the basis for Citywire’s selective reporting:

Here is what he posted

We may agree to disagree whether the Lords, and this particular Committee, is worth retaining, Tim.

See what you think, if this is a compromised committee, then I’m not sure what a good one is.


Lords Committee:

“During the oral evidence session with the Committee, HM Treasury did not reassure us that it has a firm grasp on the emerging issues related to private markets and their potential impact on financial stability. (Paragraph/Question 181)”

Relevant Witnesses were Lucy Rigby KC MP, Economic Secretary to the Treasury and City Minister; Lowri Khan CB CBE, Director of Financial Stability, HM Treasury; and Daniel Rusbridge, Deputy Director for Personal Finances and Funds, HM Treasury.


Lord Grabiner (Lords Committee): I have a couple of points that I would like to ask you about. First of all, arising out of Lord Sharkey’s question, in terms of what I would call plan B, which is in anticipation of another horrible GFC on a worst-case scenario, can we assume that there is a continuing dialogue between the Treasury and the regulators, and that you are not exclusively reliant upon the regulators to blow the whistle or let the red lights flash in the event of an anticipated similar catastrophe?

Lucy Rigby (HMT): As to the first point, you can certainly assume that there is a continuous dialogue, which is, I hope, entirely as you would expect. As the Treasury, we have a role in overseeing things. That is clearly not in the supervisory and granular way that the regulators do, but we would consider ourselves to have an important role in the process, and I say that as to financial stability more broadly.

Lord Grabiner: I hope so.

Lowri Khan: If I can add briefly to that, there are various formal ways in which we have a role, and there are more informal ways in which we have an ongoing dialogue. In particular, the Financial Policy Committee has a Treasury member. They are a non-voting member, but that means that we are present at all the meetings of the Financial Policy Committee and very much in the swim of those deliberations.

We are also present in the global Financial Stability Board as well. We do not just leave it to the Bank and the regulators in those fora. We spend a lot of time on cross-authority dialogue with the Bank, the FCA and the PRA. That is a daily matter. It is not a quarterly meeting for a catch-up. In that engagement, we focus particularly on some of the specific risks as well as on potential policy matters that might be pursued.

Lord Grabiner: That is very good. It is good to know. My other point was touched on by Lord Eatwell, and this will be very close to the Minister’s background as a competition lawyer. We have been told that bank lending through private credit only requires the individual bank to hold 20% of the risk-weighted capital, whereas, if banks lend directly to a company, they have to hold 100% of that capital. I am just an ignorant lawyer, really, but you are a competition lawyer, and you probably know the answer to this question. What is the justification for that discrepancy?

Lucy Rigby: Across the board, there is an acknowledgement that the banking sector as a whole is competitive, which is to the benefit of the wider economy. As to the stipulation that you are pointing to, Lord Grabiner, your suggestion is that it creates an uneven playing field. Is that right?

Lord Grabiner: It encourages banks that want more flexibility on their lending book to lend to the private market. They will be discouraged from lending because they would have to hold so much more capital to justify the loan. What I do not understand is why there is that discrepancy in the first place. There may be some economic explanation, but I am not quite sure what it is. Do you know?

Lucy Rigby: It is right to say that capital requirements right across the board—as you know, there are different requirements that apply to different levels of the stack—are put in place with a view to the size of specific banks and their specific lending activity. You will know that the FPC is reviewing capital requirements, and that review comes on the back of reforms that have been made recently, including to MREL [Minimum Requirement for Own Funds and Eligible Liabilities]. Because of the FPC review and reforms that have been made, there is an impetus for making sure that the banking sector is as competitive as possible, and we recognise that capital requirements are a piece of that.

Lord Grabiner: Finally, if that split of 20% and 100% is accurate, is that a source of concern to the Treasury? Does it give you concern because of the lack of knowledge about what is going on there in terms of potential exposure and potential risk?

Lucy Rigby: Lord Grabiner, I am going to turn to my officials on that. It is not something that has been raised with me in this context.

Lowri Khan: I cannot comment in detail on the specific capital that is held against specific investments.

The Chair: Why can you not comment on it?

Lowri Khan: I am not aware of the specifics. It will be context-specific.

Lord Grabiner: It is a pretty basic point, is it not? You must have thought about this. I hope somebody has thought about it.

Lowri Khan: Yes, indeed. To be clear, the way that risk weightings are applied generally to bank lending is an active area of consideration. There is ongoing work, for example, in the context of the PRA, thinking about how internal models can be made more accessible to smaller banks in particular, so it is definitely an active area.

Byron McKeeby: My question is slightly different. Should we be concerned about the fact that a lot of money is going from banks into what we call private credit? We do not have any visibility of what is going on in that marketplace. At the moment, banks are, presumably, also encouraged to lend more to that marketplace because of the much better risk weighting commitment that the individual bank is confronted with in respect of that lending profile.

Lowri Khan: That is understood. Clearly, we would be concerned if there was anything very distortionary going on.

Lord Grabiner: But you do not know that, or do you?

Lowri Khan: There are several dimensions to this. One is what it means for the safety and soundness of banks. A lot of work is being done in the context of the regular bank stress testing that goes on to ensure that those exposures are being managed.

Lord Grabiner: That goes to the position of the individual bank.

Lowri Khan: Yes, indeed.

Lord Grabiner: The bank is being stress-tested in terms of what its book looks like and, if things go wrong, what is going to happen to the book. What about what is going on outside in terms of the borrowing in that private marketplace?

Lowri Khan: You are right that the stress testing looks at it from the bank’s perspective, but it does consider the bank’s ability to manage its exposures. There has been particular work by the PRA to try to think about how well individual firms are managing their exposures in the round.

Thanks to Byron for alerting us to this dialogue. It suggests to me that private credit may not have quite the credibility we thought of it.

Following on from inquiries from the FT and Reuters , I am going to stay clear of lines of private credit drifting my way on my pensions.

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Occupational Pension Schemes (from an Employer’s perspective).

This article is from Peter Cameron-Brown, a trustee of an active defined benefit pension scheme. It’s audience is primarily experts though it is sufficiently well written to be understood by someone like me. I recommend it to you.

 


Options with an existing Defined Benefit Pension Scheme

I am concerned that Employers with an existing Defined Benefit pension scheme, whether closed or open to accrual, are not being fully advised on the implications of the various alternatives open to them.  I consider that there is too much attention paid to a commercial insurance product “end game” for a DB pension scheme without adequate consideration of the future pension scheme arrangements and hence employment costs and future profitability of the sponsoring employer.

There appear to be six alternatives a Company should consider and weigh up the alternatives of each, and if material necessary taking external advice, before making any irrevocable decisions.  There may even be others which have not yet been widely considered, such as sharing sponsorship of the Pension Scheme with another organisation, such as an asset manager.  I have not included them in the analysis.  To me the current alternatives appear to be:

  1. The company receives a taxable cash refund using a DB Pension Scheme past service “surplus”.
  2. The DB Pension Scheme runs on/out while the Company pays DC contributions in respect of its current employees.
  3. Using the “surplus” to pay DC contributions into a Master trust or a Group Personal Pension Plan.
  4. Using the “surplus” to pay contributions into a whole life CDC Scheme.
  5. Transferring Funds from a Pooled DB Fund to Individual DC Pots within the same Pension Trust Fund.
  6. Reopening or maintaining DB accrual within the same Pension Fund.

In the following article I set out my thoughts on the issues with each of these which an employer should consider when considering all the options available.  I am aware that not everyone will agree with all my points, and indeed I may have missed points others consider to be important.  I would welcome this feedback.

I have also discussed the alternatives available where there is a past service “surplus” reported in the pension scheme, but the same points apply when there is a deficit reported.  The key message is that at all stages all alternative courses of action should be considered against the current and future profitability and competitive position of the employer by including in the overall consideration alternative scenarios for current and future pension provision for its current and future workforce.

Where appropriate, I have repeated the same points across the alternatives.

Peter Cameron Brown BA(Econ) LlB FCA


1.    The company receives a cash refund using a DB Pension Scheme past service “Surplus” and pays DC contributions in respect of its current employees.

  1. Loss of Assets to a Tax Charge: The pension scheme has to deduct 25% tax on the amount refunded to the company.
  2. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree an “equitable” distribution of the surplus between the company and its previous employees who are pensioners or have deferred benefits in the pension scheme; and determine the amount of surplus to be retained as a reserve in the pension scheme fund. These decisions are Trustee decisions over which the Company has no control.
  3. Effect on the Company’s Assets and Balance Sheet: Although increasing company cash by the net amount received, the company’s balance sheet and distributable reserves are reduced by

the loss to tax on the refund[1], plus

the reduction in the pension scheme asset from cash distributions to previous employees retaining benefits in the Scheme, and

the increased estimated valuation  cost of the enhanced future pension benefits of previous employees.

  1. Effect on Future Years’ Profitability: Future years’ profit and loss accounts will reflect the loss of the interest on full reduction in the pension scheme asset arising from the refund, the tax on it, and the benefit enhancements to the scheme members. The pension fund also loses the future investment return on the cash refunded to the company or paid out to the members.
    1. Administration Costs Incurred: The Company has to bear the future administration costs of the pension scheme, either by contribution or out of residual surplus. NB: these costs are capitalised and effectively prepaid as a lump sum in a buy-out bulk annuity transactions.
    2. Future freedoms: It is appropriate for the company to consider whether it wishes the pension scheme surplus to be refunded now or for it to remain invested by the pension scheme for possible alternative future uses for its benefit.
    3. On going Pension and Employment Costs: The Company’s DC contributions continue to be a cash outflow and a Profit and Loss charge.
    4. Future Risks: While at present the DC contributions may appear to be a fixed cost, the company has to consider the likelihood of future legislative changes and employment practices and whether they are likely to increase the cost to the company. Possible increases are likely to come from increased Government and employees, or their representatives, attention to the adequacy of pensions provided from DC pots – Pensions UK is lobbying for a minimum of 12% annual contributions and the Australian “Super” system, often cited as a good example, already mandates a 12% employer contribution.  An employer may also wish to reflect on the possibility of a loss of or restriction on the tax reliefs available, e.g., from the 2025 Budget proposed future restriction on NI relief on salary sacrifice arrangements.
    5. Employment Contract Restrictions: As part of the employment contract, DC contributions once set cannot be reduced without a formal renegotiation of the employment terms of current employees.
    6. Benefit Efficiency: For a targeted level of annual pension benefit, the combined contributions required from employers and employees is likely to be something like 50% more with DC than those required with a CDC or DB arrangement.
    7. Employee and Member Considerations: Cash payments to the DB scheme members in excess of benefits available to them under the Deed at time of service are treated when received as unauthorised payments and are currently taxed at 55%, but following the 2025 Budget proposals will be taxed at the Employee’s marginal rate, as at present applies to any discretionary benefits paid under the terms of the Deed. Enhancements to deferred benefits will count against the current year’s Annual Allowance and could trigger an Annual Allowance (tax) Charge on the Member.

Conclusions

Although there is an asset transfer from the pension fund to the company, the company cannot control the outcome and there are considerable leakage to taxes and also adverse effects on reported company strength and profitability.  The company is also committed to making future contributions into the DC pots of its current and future employees in accordance with employment terms and future legislative requirements. Members receiving enhanced benefits may suffer significant tax charges.


2.    The Pension Scheme runs on/out while the Company pays DC contributions in respect of its current employees

  1. Option considered: This is effectively a deferral of the cash refund option but the deferral of the reduction in the pension scheme asset allows the investment return on the scheme assets and the actual pension scheme experience to increase the assets available for ultimate refund.
  2. Loss of Assets to a Tax Charge: The loss to tax is deferred until the ultimate refund.
  3. Effect on the Company’s Assets and Balance Sheet: The Company’s Balance Sheet and distributable reserves reflect an increasing pension scheme asset. That asset being itself enhanced by investment returns in excess of the (low dependency) valuation assumptions and also actual pension scheme experience against valuation (mortality) assumptions.  The company may reasonably assume that in combination these are more likely to be positive than negative to the net asset value; and even if negative the effect is spread into the indefinite future.
  4. Effect on Future Years’ Profitability: The company retains a profit and loss credit on the total net assets of the Pension Scheme, while the company’s DC contributions continue to be a cash outflow and a Profit and Loss charge.
  5. Future Risks: While the present DC contributions may appear to be a fixed cost, the Company has to consider the likelihood of future legislative changes and employment practices and whether they are likely to increase the cost to the Company. Possible increases are likely to come from increased attention to the adequacy of pensions provided from DC pots – Pensions UK is lobbying for a minimum of 12% annual contributions and the Australian “Super” system, often cited as a good example, already mandates a 12% employer contribution.  An employer may also wish to reflect on the possibility of a loss of or restriction on the tax reliefs available, e.g., from the 2025 Budget proposed future restriction on NI relief of salary sacrifice arrangements.
  6. Employment Contract Restrictions: As part of the employment contract DC contributions once set cannot be reduced without a formal renegotiation of the employment terms of current employees.
  7. Benefit Efficiency: For a targeted level of annual pension benefit, the combined contributions required from employers and employees is likely to be something like 50% more with DC than those required with a CDC or DB arrangement.
  8. Timing of benefit sharing with Past Employees: The pension scheme Trustees are not required to consider the equitable distribution of a surplus between the company and the reducing cohort of past employees retaining benefits in the pension scheme until the time of the ultimate refund.
  9. Administration Costs Incurred: The Company has to bear the future administration costs of the pension scheme, either by contribution or out of residual surplus. NB: these costs are capitalised and effectively prepaid as a lump sum in a buy-out bulk annuity transactions (the capitalised cost should diminish over time in a closed scheme).
  10. Future freedoms: The company retains the flexibility to pursue other options, including the reopening of DB accrual within the same scheme (option 6 below), at any time in the future.

Conclusions

Although there is loss of a short term cash transfer to the company, the company is likely to benefit over the long term from the deferral of tax and the investment return on the pension scheme assets.  The company is able to control the timing of the Trustees’ consideration of the split of pension scheme surplus between a refund to the company and the enhancement to benefits of past employees.  Flexibility to switch to an alternative option in a possibly significantly changed future environment is retained.  However the Company is still subject to the restrictions associated with its contractual DC contributions and the transfer of assets out of the company’s domain, which includes the pension scheme, into the individual DC pots of its then current employees.


 

3.    Using the surplus to pay DC contributions into a Master trust or GPP:

  1. Loss of Assets to a Tax Charge: The pension scheme has to deduct 25% tax on the payments into employees’ DC pension pots as under present legislation and accounting rules they are treated as a refund to the employer from the pooled fund.
  2. Effect on Profitability: The company has to report the full cost of the company’s DC contributions funded in this way as a pension scheme cost in the Profit and Loss in the same way as if it had paid them in cash.
  3. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree an “equitable” distribution of the surplus between the company to be used in this way and its previous employees who are pensioners or have deferred benefits in the pension scheme; and the amount to be retained as a reserve in the pooled pension scheme fund. These decisions are Trustee decisions over which the Company has no control.
  4. Effect on the Company’s Assets and Balance Sheet: Although increasing company cash by the net amount received, the company’s balance sheet and distributable reserves are reduced by

the loss to tax on the refund[2], plus

the reduction in the pension scheme asset from cash distributions to previous employees retaining benefits in the Scheme, and

the increased estimated valuation  cost of the enhanced future pension benefits of previous employees.

  1. Effect on Future Years’ Profitability: Future years’ profit and loss accounts will reflect the loss of the interest on full reduction in the pension scheme asset from the DC contributions paid, the tax on them, plus the benefits enhancements to the DB scheme members.
  2. Administration Costs Incurred: The company has to bear the future administration costs of the DB pension scheme, by contribution, or out of residual surplus, or by the capitalised cost in a buy-out transaction.
  3. Benefit Efficiency: For a targeted level of annual pension benefit, the combined contributions required from employers and employees is likely to be something like 50% more with DC than those required with a CDC or DB arrangement.
  4. Future Risks: While at present the DC contributions may appear to be a fixed cost, the company has to consider the likelihood of future legislative changes and whether they are likely to increase the cost to the company. Possible increases are likely to come from increased attention to the adequacy of pensions provided from DC pots – Pensions UK is lobbying for a minimum of 12% annual contributions and the Australian “Super” system often cited as a good example already mandates a 12% employer contribution.  An employer may also wish to reflect on the possibility of a loss or restriction on the tax reliefs available, e.g., from the 2025 Budget proposed future restriction on NI relief of salary sacrifice arrangements.
  5. Employment Contract Restrictions: As part of the employment contract DC contributions once set cannot be reduced without a formal renegotiation of the employment terms of current employees.
  6. Employee and Member Considerations: Cash payments to the DB scheme pensioners in excess of benefits available to them under the Deed at time of service are treated when received as unauthorised payments and are currently taxed at 55% but following the 2025 Budget proposals will be taxed at the Employee’s marginal rate, as at present applies to any discretionary benefits paid under the terms of the Deed. Enhancements to deferred benefits will count against the current year’s Annual Allowance and could trigger an Annual Allowance (tax) Charge on the Member.

Conclusions

Although there is a short term cash flow benefit to the company, the company cannot control the outcome and there are considerable losses to taxes and also adverse effects on reported company strength and profitability.  Over the longer term, the company is left with a fixed or increased cash outflow and Profit and Loss charge in the form of DC contributions. It is also highly inefficient in terms of the improvement in the DC members’ benefits for the amount of surplus being given up.

 


4.    Using the surplus to pay contributions into a whole life CDC Scheme:

  1. Loss of Assets to a Tax Charge: The pension scheme has to deduct 25% tax on the payments into the CDC Scheme as (at present) they are treated as a refund to the employer.
  2. Effect on Profitability: The Company has to report the full cost of the company’s CDC contributions funded in this way as a pension scheme cost in the Profit and Loss in the same way as if it had paid them in cash.
  3. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree an “equitable” distribution of the surplus between the company and its previous employees who are pensioners or have deferred benefits in the pension scheme and the amount to be retained as a reserve in the pension scheme fund. This is entirely outwith the company’s control.
  4. Effect on the Company’s Assets and Balance Sheet: Although increasing company cash by the net amount received, the company’s balance sheet and distributable reserves are reduced by

the loss to tax on the refund[3], plus

the reduction in the pension scheme asset from cash distributions to previous employees retaining benefits in the Scheme, and

the increased estimated valuation  cost of the enhanced future pension benefits of previous employees.

  1. Effect on Future Years’ Profitability: Future years’ profit and loss accounts will reflect the loss of the interest on full reduction in the pension scheme asset from the CDC contributions paid, the tax on them, plus the benefit enhancements to the DB scheme members. The rate of employer contributions is a key design feature of the CDC scheme and are contractually fixed, but subject to any over-riding legislation.
  2. Administration Costs Incurred: The Company has to bear the future administration costs of the DB pension scheme, by contribution, or out of residual surplus, or by the capitalised cost in a buy-out transaction.
  3. Benefit Efficiency: For a targeted level of annual pension benefit, CDC should require 33% less total employer and employee contributions compared with a DC arrangement. As CDC scheme members, as opposed to DB scheme members, bear the administration costs of the CDC scheme, the benefit Efficiency of the contributions paid in is poorer than with DB, but better than with DC to a Mastertrust or a GPP arrangement.
  4. Employee and Member Considerations: Cash payments to the DB scheme members in excess of benefits available to them under the Deed at time of service are treated when received as unauthorised payments and are currently taxed at 55% but following the 2025 Budget proposals will be taxed at the Employee’s marginal rate, as at present applies to any discretionary benefits paid under the terms of the Deed. Enhancements to deferred benefits will count against the current year’s Annual Allowance and could trigger an Annual Allowance (tax) Charge on the Member.

 

Conclusions

Although there may be a short term cash flow benefit to the company, the company cannot control the outcome and there are considerable losses to taxes and reported company strength and profitability.  Over the longer term, the company is left with a fixed or increased cash outflow and Profit and Loss charge in the form of contractually fixed CDC contributions. It is however more efficient in terms of the improvement in current employees’ retirement income for the amount of surplus being given up than a transfer to individual DC pots.

 


5.    Transferring Funds from the Pooled DB Fund to Individual DC Pots within the same Pension Trust Fund

  1. Loss of Assets to a Tax Charge: As there is no real or notional refund to the employer, the pension scheme does not have to levy a refund tax charge.
  2. Availability of this option: This will only be possible if the power to transfer from the pooled fund into the notional DC pots of individual members is permitted within the Trust Deed. Such a Deed is likely to specify the situations in which this will be possible.
  3. Possibility of change: It is unlikely a new DC section could be introduced into an existing DB Trust which allows the existing pooled DB fund partly funded by members’ contributions to be transferred into the individual notional DC pots of employees who were not also members in the DB fund. The precedent case (Standard Life) where the permission of the Courts was obtained to amend the Deed to permit a DB pool to be used for DC benefits recognised that the donor DB scheme had been almost entirely employer funded.  In any event, it is likely that considerable legal costs will be incurred in pursuing this option.
  4. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree the amount to be retained as a reserve in the pooled DB fund and an “equitable” and Deed permitted distribution of the surplus between enhancing the benefits the previous employees who are pensioners or have deferred benefits in the DB section and increasing the individual DC pots in the DC section. This is entirely outwith the company’s control.
  5. Effect on the Company’s Assets and Balance Sheet: The company’s Balance Sheet and distributable reserves are reduced by the full amount of the transfer from the pooled fund into the individual employees’ DC pots.
  6. Effect on the Company’s P&L A/c in the transfer years: The P&L A/c will reflect as a charge the full amount of the contributions out of the pooled fund into the individual DC pots even though there was no cash flowing from the company.
  7. Effect on Future Years’ Profitability: Future years’ Profit and Loss will reflect the loss of the interest on full reduction in the pooled pension scheme asset from the transfer into the individual employees’ DC pots and also by DC contributions fixed or increased by employment contracts or legislation.
  8. Employee and Member Considerations: The transfer into the Members’ individual DC pots will be treated as a pension contribution during the year subject to the Annual Allowance is the same way as they had been contributed by the company.
  9. Administration Costs Incurred: The company has to bear the future administration costs of both the DB and the money purchase sections, either by annual contribution, or out of residual surplus in the DB asset pool, or by meeting the capitalised cost in a DB benefit buy-out transaction.

Conclusions

Although there is a short term cash flow benefit to the company and no loss to tax, over the longer term, the company is left with a fixed or increased cash outflow commitment and P&L A/c charge in the form of future DC contributions and the loss of investment return from a decreased asset base in the pooled fund. It is however more efficient in terms of the improvement in current employees’ retirement income for the amount of surplus being given up than a transfer to individual DC pots resulting from pooling the investments and no forced sale of assets.


6.    Reopening or maintaining DB accrual within the same Pension Fund

  1. Availability of this option: Apart from the mandatory employee consultation, an employer is entirely free to introduce a new section of DB benefits for future service into an existing DB pension fund. The benefits need not reflect those previously provided by the Scheme.
  2. Effect on the Company’s Assets and Balance Sheet: The entire pool of scheme assets including those contributed by both the company and employees in respect of both past and current service are available to fund all the benefits accrued. The capacity to fund the benefits of the historic section from current contributions gives significant investment freedoms not available to a closed scheme and thereby reducing the future cost to the employer under the balance of cost arrangement.
  3. Effect on Valuation Surpluses or Deficits: The scheme will be regarded as a single entity for valuation purposes. This will progressively push forward the “significant maturity” date (subject to employer’s longevity covenant).  This will provide considerable protection against short term market risks affecting either asset values or the liability valuation assumptions.
  4. Loss of Assets to a Tax Charge: There is no loss to tax as no surplus is being refunded to the company.
  5. Share of Surplus with Previous Employees: The Trust Deed instructions to Trustees remain under the control of the company. Trustees are not required to consider a shared distribution of surplus between the company and pension scheme members who were previously in pensionable service with the company or its predecessors. (Although in Equity, Trustees may wish to consider using existing discretionary powers under the Deed to maintain real values of pension benefits before agreeing a Schedule of Contributions with a full or partial employer contribution holiday)
  6. Future freedoms: Under the balance of cost arrangement, the surplus can be returned to the company through reduced future employer contributions. There are no minimum contributions set for DB schemes under the auto-enrolment regulations (there is a minimum benefit accrual rate of 1/120th of “qualifying earnings”).
  7. Effect on Future Years’ Profitability: The company’s Profit and Loss will reflect the current service cost of the current DB benefit accrual (calculated using the opening AA bond yield) offset by an interest credit on the opening surplus (calculated using the same basis). With realistically stronger investment performance than the valuation assumption, it is therefore quite feasible for the net pension cost to become negative and the pension fund to be a contributor to company profitability.
  8. Competitive Considerations: The cash flow and reported profitability advantages should give the company providing DB accrual a competitive advantage against competitors who are providing DC pension benefits. This would be particularly marked against competitors who are following a high cost buy-out strategy for their pension scheme.
  9. Employer Covenant Considerations: Provided the current service cost is being fully funded, the employer’s covenant towards the pension scheme should be enhanced by the continuing accrual of DB benefits.
  10. Administration Costs Incurred: The company has to bear the future administration costs of the pension scheme, either by payment, or out of surplus in the total asset pool. However these costs are relatively fixed with regard to the increasing number of members in the scheme and total asset values.
  11. Recruitment and Retention Benefits: There are the recruitment and retention benefits of an employer providing a “gold plated” DB pension promise. The current employees have a guaranteed pension in retirement, protected by the PPF, without the uncertainty and potential stresses of a DC arrangement. Given that the employer directly or indirectly funds the administration costs, the value for money of the employee and employer contributions should be greater than that provided by a CDC arrangement, itself significantly greater than that provided by the equivalent contributions into a DC arrangement. As the employer defines the pension terms for its employees, there is no need to consider inter-personal “fairness” associated with a wealth generating pension savings vehicle.

 

Conclusions

Compared with the other alternatives, it does appear that providing DB accrual to current employees may be the most cost effective and lowest risk alternative for an employer with an existing DB scheme in surplus (and also potentially for employers whose pensions scheme is not yet fully funded).

 


The Taxpayer’s Point of View

This paper is written from a company point of view with reference to a “loss to tax” where relevant.  This does not necessarily mean that there is a cost to other tax payers when measured over the longer term:

If a company with a DB pension scheme in surplus uses that surplus to fund further pension accrual, the Exchequer gains from the unused tax relief on the future contributions which otherwise would be paid.  This results in increased Corporation Tax paid by the Company and the Income tax and National Insurance Contributions paid by the Employee respectively. The taxes at issue are 25% on company contributions, 20%, 40%, or possibly 55% marginal rate on employee contributions plus employee National Insurance at 8% or 2%, plus in some circumstances 15% Employer NI.


General Conclusion

It is important that advisors should fully explore all options with employers, whether or not the employer has already commenced a strategy designed to achieve an eventual buy-out.  A failure to do this is likely to lead to a further degradation of the UK industrial and commercial base.

 


Details

[1] Balance Sheet totals may reflect a release of a previous provision for deferred taxation to the extent that it is no longer required.

[2] Balance Sheet totals may reflect a release of a previous provision for deferred taxation to the extent that it is no longer required.

[3] Balance Sheet totals may reflect a release of a previous provision for deferred taxation to the extent that it is no longer required.

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Pensions have a lot on ; no commercial dashboards for a good while please!

 

The idea of having more than one pension dashboard – indeed dashboards for commercial purposes, has been mooted since the outset of the project but has never seemed further away. We have three questions we should ask about them

  1. Will private dashboards improve the pensions or freedom from pensions that we get?
  2. Will focussing on them rather than other priorities detract from overall worth?
  3. Is there any evidence from other countries that commercial dashboards done good for citizens?

I don’t think that a clear answer can be given to any of the three.

  1. Do we need more than a public dashboard?  We are yet to see the impact of the public pension dashboard that will be delivered some time after October this year. The pension dashboard has to give this dashboard 6 months from being unleased till being delivered so April is the first break point, otherwise the dashboard will drift back day for day delayed. So supposing that we need more is pre-emptive, we just don’t know whether a public dashboard will do the trick. What is the trick? I suspect we won’t know that people are satisfied with the pension dashboard for a while to come.
  2. Will focussing on commercial dashboards have be to the detriment elsewhere?  Pension dashboards rather than a dashboard seem to benefit predatory providers who are looking to consolidate individual pots into the DC equivalent of a super-pot! I think this has limited value to the public, a consolidated pot may be good or bad and we hope that the VFM estimation will give us some help in this. But it does not help us with the big questions about pensions. The big questions being posed are in the Pension Schemes Bill and centre on decumulation rather than accumulation or consolidation of pensions. I think it is too early to see the impact of the first dashboard and the deadlines on providers to offer default decumulation to their policyholders and members.
  3. Is there any evidence of commercial pension dashboards in other countries? We are at the back of the queue when it comes to pension dashboards; our Scandinavian networks are way ahead of us. I see no evidence that dashboards of the style being promoted by private companies have not worked in other companies who have got on quite well with a state system.

With People’s Pension the opposite of a dashboard approach is proposed

There is an alternative to a dashboard aggregating pots into a DC superfund. The five changes the People’s Pension is calling for include: 

  • Clear, comparable pension information: A requirement for pensions providers to display simple, comparable, and easy-to-find information on investment performance, charges and customer service.
  • A ban on  pension transfer incentives.
  • A more consumer-focused Value-for-Money framework
  • Delaying to commercial pension dashboards until VFM metrics displayed across all pensions 
  • Mandatory scheme comparisons during transfers, including  an obligation on the receiving  pension scheme to flag important differences between pension schemes.

My view is that so long as we aren’t careful about transfers, we will open the door to the lowest common denominator – brand. I would like people to think about pensions as a regular income increasing with inflation till you have no need of it. Pensions are not like pots and are not transferrable. So long as we persist with an obsession with pots and super pots


More important things to think of.

I am sorry that the Pension Dashboards Program has given in and published proposals as to how to carry on to commercial dashboards.

This I suspect will be taken up by the commercial pot providers who are looking for alternatives to the important developments in the Pension Schemes Bill and subsequent CDC and VFM legislation and regulation.

But we need to prioritise the legislation that is going through parliament right now. This means turning down the heat on commercial pension dashboards.

 

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Anthony Manchester; Global Policy BlackRock ; Tuesday 10.30

Coffee Morning – In conversation with BlackRock’s Antony Manchester 

Attending CPD included

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Transparency front and centre- the Government statement on VFM

I’m publishing this statement on this blog to remind us all that “transparency” is the key word. It is the word that fired many of our careers ;it is the word that incited AgeWage and Clearglass and the Transparency Task Force. 

The blog is infact a press release from the Government but I think it owes  a debt to Andy Agethangelou, Chris Sier and Con Keating for their efforts more than ten years ago to get transparency in play.


Pension schemes must now publish transparent data on their performance, costs, and service quality, according to new proposals from the FCA, DWP, and TPR.

Pension schemes will need to publish clear data on their performance, costs and quality of service, under proposals announced today by the Financial Conduct Authority (FCA), the Department for Work and Pensions (DWP) and The Pensions Regulator (TPR). If a pension offers poor value, firms and trustees must then fix it by moving savers to better schemes or driving improvements.

The proposals aim to make it clearer how pensions perform, what they cost and the quality of service. So that people can get good value, and so that poor performing schemes are pushed to improve.

Over 16 million workers have defined contribution (DC) pensions. Value for money makes a real difference for pension savers: over 5 years, a £10,000 pot could grow to £10,400 in a poor scheme or £15,100 in a high-performing one – 46% more.

The proposals focus on long-term value and build on feedback from last year’s consultation, with new measures showing what returns and risks savers can expect over the next ten years. This latest consultation is for decision makers across the DC market, including trustees.

Value for money assessments will be shown in a colour rating, with dark green for strong performance, light green for good value, amber for improvement, and red for poor value-making comparisons clear and easy.

FCA deputy chief executive, Sarah Pritchard, said:

‘Good value isn’t just about low costs – it’s about strong performance, good service, and transparency. We want to see a focus on value. By working with government and The Pensions Regulator, we will help secure better returns for pension savers.’

TPR chief executive, Nausicaa Delfas, said:

‘Millions of people rely on pension income to support them through later life. We have to make sure they get value for their money. This framework will empower decision-makers to either improve their scheme or consolidate out of the market. We want to hear the views of trustees to make sure we get this right and help transform pension saving for millions.’

Minister for Pensions, Torsten Bell, said:

‘It is simply too difficult for people to know whether their pension savings are working for them. That’s not right when we’re talking about something as important as people’s security in retirement.

‘These proposals change that. Pension schemes’ performance will be public with a simple rating system. In future, savers will know if they are getting a good return or not.

‘This is about being straight with people and making sure people’s savings work as hard as they did to earn them.’

The framework also sets out:

  • Stronger governance with clear expectations for trustees and providers.
  • Clear steps to take when schemes are not giving members good value, including closing them to new business and moving members to better-performing schemes.

These joint proposals are open for comment until 8 March 2025. Final rules will only be confirmed once responses have been considered and are subject to the Pension Schemes Bill receiving Royal Assent.


Help available

Helpfully the Government gives some helpful hints to those not familiar with the differences between the FCA and TPR and starting points for Trustees and others interested in getting value for money from saving into DC pension pots.

You can…

  1. Read the Consultation Paper (PDF).
  2. TPR has a landing pageLink is external for trustees which provides an introduction to the Consultation.
  3. See previous work from the FCA, DWP and TPR on Value for Money.
  4. The FCA regulates contract-based pensions, which involve a contract between an individual and the pension provider.
  5. TPR regulates trust-based pension schemes, which have a board of trustees overseeing the scheme.
  6. The UK government’s Pension Schemes Bill 2025 is currently progressing through Parliament and includes the legislative powers to mandate a Value for Money (VFM) framework for trust-based schemes. FCA rules will introduce the framework for contract – based schemes. Timing of the framework is therefore subject to legislative agreement.
  7. The framework is one of a number of joint initiatives to deliver better outcomes for pension savers including Targeted Support and the Pensions Dashboard.
  8. The Consultation Paper is aimed at pension providers and aligns with the wider FCA objectives, including the Consumer Duty and competition.
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Torsten Bell speaks in the VFM debate for the consumer.

Bell

What practically will the work on Value for Money mean to providers , employers and ultimately savers into our DC plans? We have this statement from the FCA

We plan to offer roundtables and stakeholder events to discuss practical aspects as we develop the Framework. As set out in the previous consultation, and subject to the legislative process for the Pension Schemes Bill 2025 and underlying regulations, we
intend that both contract and trust-based arrangements will come into force at the same time. We are currently working towards 2028 for the first VFM assessments to be required.

Let’s work back from that to now and we see a project that has been ongoing three years (It was introduced in 2024 by the then Pension Minister Laura Trott).  We are halfway into the implementation of VFM and we have reached conclusions that I’ve been surprised at. I have been surprised that the consumer has yet to be involved in the thinking of FCA and TPR. We have one consumer event between now and 2028 – the pension dashboard.

My assumption was that consumers would be the ultimate users of VFM scores and this seems to be Torsten Bell’s too. Here he is in a blog that accompanies the latest consultation on VFM by the FCA

Minister for Pensions, Torsten Bell, said:

‘It is simply too difficult for people to know whether their pension savings are working for them. That’s not right when we’re talking about something as important as people’s security in retirement.

‘These proposals change that. Pension schemes’ performance will be public with a simple rating system. In future, savers will know if they are getting a good return or not.

‘This is about being straight with people and making sure people’s savings work as hard as they did to earn them.’

I doubt the Pensions Minister has been reading the headline of this blog but we are at least as one in wanting savings to work as hard as we did to get them.

VFM is about what you get in retirement, the Pensions Dashboard will show you an income and you will be able to refer that provider’s VFM to one of four colours.

These are instructions to employers on what can be done to get to green. But for savers viewing their dashboard, the question may be more explicit. Do I want to entrust my retirement finances to a red one or a green one and why am I in a red one when my employer and/or adviser made the choices.

I do not see VFM as without risk for consumers or consumerists or advisers. Any system that calls providers to account retrospectively runs that risk. But Forward Looking Management (FLM) is of little use to savers who have lost confidence in the backward management of their money and I suspect the capacity of DC providers to maintain hold of money when they have a history of failure will be limited, especially if the pension dashboard catches on.

For VFM to be effective it must do, as Torsten Bell asks,  and show consumers how they are doing ;  there will be very real alternatives by way of pensions coming into play by 2028.

The consumer bears all the risk in DC pensions.

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Simon Eagle reels CDC back from the pond of Nico Aspinall

Simon Eagle on the edge of a big pig pond

This podcast aroused my attention when I was sent it by said Simon, a friend and long-time comrade in the campaign for CDC pensions. I was in a trolley queue in the Wexham corridor call so I listened to this podcast and then the  famous podcast “Ralfe-pod #133” where Nico sounds he’s spent in the company of John Ralfe.

I suspect that Nico Aspinall has been chastened by  the gentle intelligence of Simon Eagle. Simon’s firm, Willis Tower’s Watson have a lot to lose from DC having a DC master trust (Life Sight) already up to 2035 size. I suspect that he is more on Nico Aspinall’s side than the CDC pioneers who created a replica of a DB scheme (without the guarantees) in Royal Mail. This was certainly the target for Nico Aspinall’s anger in #133.

It is of course possible to operate a withered version of the whole of life plan. This is the version that starts at retirement and loses the DC proprietor only decumulation (which they never really had). This I suspect Simon, being the good corporate soul. has in mind. It’s known as Retirement (R) – CDC and has just finished its own consultation. It will be ready for the UK in 2028 which is a little too late to be a default decumulator for DC scheme’s like Lifesight.

Peace has broken out between fellow actuaries Eagle and Aspinall and it had never broken out with Darren Philp who seems to be quite at peace with the idea of getting pensions, infact he promotes Richard Smith as having invented it, which in a DC sense – Richard has.

Simon’s 67 minutes of avenue procession is very pleasant as it does not make its way into the actuarial disputes on justness. Where was for instance the discussion about smoothing relative to the more modern approach of dynamic process? Can we progress data management to the point where a scheme can be valued every day, – it’s liabilities be known its assets be known it never be in balance but for moments of coincidence?

I couldn’t quite hear the discussion creeping into the 21st century when it came to data . but DB had its zenith in the 2oth and I don’t suppose that a dynamic system of pricing, making use of the speed of data transmission, hasn’t quite made it to CDC (according to the major actuarial houses).

Indeed, the major financial institutions didn’t make it into #141 (cherish those numbers like symphonies). We have a discussion of Royal Mail’s struggle to CDC without mentioning that it was CDC (Terry Pullinger) and First Actuarial (Hilary Salt and Derek Benstead) who broached the idea. WTW and Aon took over in time because they always do but that doesn’t mean they had the idea!

That said, Simon’s remarkable resilience is supreme. No one can have had to overcome such obstacles as have been placed in Simon’s way . Simon has used numbers to express himself and now he has found ways to do it himself and very well. He know I can’t do numbers like him and maybe he can’t do words like him but I hope we will never fall out over CDC where we press in the same direction, albeit with different masters!

It is a great pleasure to hear him on this podcast. I have not heard many that captured the moment like this and when Simon is asked what his definition for VFM his answer is as mine “better outcomes”. “Than what?” I hear you ask. There is no better than DC for most people though we may find our pensions are the bigger pound for pound with CDC – rather than DB.

Like everything in the future, comparative VFM depends on what can be extracted from the CDC pot and when….But only DB can beat CDC and only then  if the world is grim.

I do recommend Simon Eagle’s Podcast 141 and not just if you’re lying on an ambulance trolley in a hospital corridor.

 

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Value for Money – a new way forward with a Pension Schemes Act?

The FCA have led the Value for Money, unlike previous versions where TPR led but hand in hand with it.

The Government is progressing the Pension Schemes Bill 2025 to create new rules for certain trust-based pension schemes with defined contribution benefits. Consultations on draft regulations and supporting guidance will follow, led by DWP and TPR.

At the same time, rules for contract-based schemes are being developed, with a parallel consultation planned. We are currently working towards 2028 for the first VFM assessments to be required.

The artificiality of having a separate regulator overseeing contract based and trust based schemes is obvious. Contract based schemes are increasingly operating in the wealth market and have a legacy of workplace saving. TPR (in DC terms) are almost exclusively in the workplace pension market with money from bosses.

So the market is increasingly splitting in terms of purchasing decisions and advice on the purchase. The FCA govern advisers to the wealthy and advisers that may have been around long enough to have advised on contract based workplace savings plans.

The dichotomy between regulators has never been greater, tPR has the weight of the flows and the FCA regulate the weight of savings!

The FCA’s opening to the consultation it (and TPR) are mounting on Value for Money in DC plans. This is the meat of it. Schemes will be divided into four types


The FCA gives us four reasons for

Why we are consulting

We are proposing revisions to make the way arrangements are assessed and compared more objective and robust. We are also responding to feedback and refining the data required.

The main changes proposed since consultation CP24/16 are:

  • The introduction of forward-looking metrics to be considered alongside backward-looking metrics in assessments.
  • Fewer cost and backward-looking investment performance metrics, focused on key metrics.
  • Streamlined service quality metrics to allow further engagement with industry on others.
  • Comparisons of value against a commercial market comparator group rather than 3 other arrangements.
  • A four-point rating system rather than three, to allow identification of top performers.

Let’s look at those emboldened words

The way ; this is an attempt to guide those taking and helping to take decisions in a certain direction

Objective and robust; “not based on subjective feelings , based on what has and will be delivered” in my words!

Forward looking; predicting what might be delivered is not easy. Who would have thought that NOW with the Danish Government behind them, could have been such an investment and administrative disaster. Who could have thought that the LGPS Kensington and Chelsea Borough could have delivered more than the might Border and Coast. Predicting capability for the future is a big taking on and it will have much consultation. No one has yet found a crystal ball

Cost and backward Performance metrics are being down-played. The ghost of my friend Dr Chris Sier will be turning in his grave to hear of such on value for money. It is of cause to remember the leakage of performance through costs charged to funds that aren’t disclosed (transparency is needed). It is of course worth building up a library of information on the capacity of certain providers to deliver more than average, but it is not everything, or we would only back Man Utd for the premier league.

Streamlined service quality metrics comparable with other markets. This is slam on. There is no point in reckoning an admin or member communication service good compared with others among workplace or wealth pensions. We need to be able to compare them with what is state of art in each service and determine whether that we are getting is value for our money.

Comparing providers against a “benchmark” – which I take to be a “commercial market comparator“. This is one that AgeWage has run with Hymans Robertson. It gives a composite performance  in terms of unit performance, volatility and it is created from returns from current indices and historic ones from Morningstar going back to the 1990s. We must get away from comparing with favoured rivals and towards benchmarks like ours. We will discuss how the baskets can work as we have been doing this 8 years now.


The FCA gives us an explanation of

Who this is for?

We encourage firms operating contract-based workplace pensions, their IGCs and GAAs, and the trustees of trust-based schemes to respond to this consultation. We welcome feedback from:

  • firms operating contract-based workplace pensions
  • IGCs and GAAs
  • trustees and sponsors of trust-based schemes
  • DC pension scheme savers and beneficiaries
  • pension scheme service providers, other industry bodies and professionals
  • employers
  • civil society organisations
  • consumer organisations / representatives with an interest in pensions capability / financial capability
  • pensions administrators
  • any other interested stakeholders

This is where I think we are a little mystified. This stuff will not be coming available to these stakeholders till 2028 which will be five years after the idea was brought to life by a past pension minister. By then we will have a different world for pure DC , we will have CDC and DC schemes will have default pensions for those not opting for their own pathway (annuity, drawdown, cash-out).  There will be fewer bigger schemes as commercial figures hone in on £10bn in 2030 and £25bn five years later.

Next Steps

We are asking respondents to reply to the FCA and the Pensions Regulator (TPR), who will share responses with the Department for Work and Pensions (DWP).

The end point of this work will be DWP, the intermediaries will be FCA and TPR. That notes its origin with Laura Trott – the pension minister in 2023. I fear it does touch the sides of His Majesty’s Treasury.

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