Should I be worried about the new CDC schemes going wrong?

Posted on April 7, 2026 by henry tapper

One of the discussions over Easter about my posts on CDC complained that I only made claims for CDC if a CDC pension scheme was “open”. I referred to the possibility of a CDC scheme entering an endgame and what that would mean for those relying on the promised pension. I posted a picture explaining that it would be bad news for people in the future and I stand by this, here is the picture from my friend Derek Benstead.

A collective scheme (whether DB or CDC) depends to deliver in future to be open. That means open to contributions from employers (it being a workplace pension at present). It will doubtless be the back end of the DC horse and this will be called Retirement CDC and there if will equally be responsible for new money that comes from employers – paid by them and by employees under auto-enrolment.

Can we rely on CDC schemes staying open? Well there are dependencies. CDC is dependent on employers and on conversion of DC schemes. It is dependent on the plug not being pulled on it by future legislation and most of all, it depends on the competence of those who manage the CDC scheme finances (the proprietor) and manage the scheme (the trustees and their executive). This is why we have a Pensions Regulator scrutinising both.

There are three pathways that a CDC scheme can follow if it gets into trouble and finds itself in difficulties with promises it is making. They are called continuities because they protect members in the way that the PPF protects members of DB schemes whose sponsors are not able to meet obligations. We should not pretend there is not risk here, there is risk in everything. There is a lot more risk in pretending that the future is not full of risks, it is best that future risks are managed.

The three continuities are (to simplify)

  1. That the CDC proprietor and trustees set things right and with the help of TPR get back on track.
  2. That if that fails that an agreement is made with another CDC scheme for the other scheme to take on the members and the transferring scheme to close.
  3. That failing one and two, a third continuity path is followed that swaps the individual member rights to a pension to rights from a purchased annuity.

Let’s not pretend that any of the continuities are easy , but they minimise the concerns to members. There are of course similar paths for DC and DB schemes to follow and for the most part we can term them improvement, consolidation or buy-out. The PPF is not an option for DC or CDC schemes, it is exclusively for DB schemes that have guarantees which DC and CDC schemes don’t have.

So how seriously should CDC setting up today be taking continuities?

Very seriously, I’d say!

  1. To launch, a CDC proprietor must display to TPR that it has capital behind it to make sure that it can drawdown if running the scheme is tough. As the first line of defence, the capital can be used but must be replenished.
  2. When there is a market, there should be agreements between the limited numbers of CDC schemes to take on or have taken on, the promises made to members . Coincidentally, I am speaking with the other potential commercial CDC together and on my agenda is what assurance we can give DWP and TPR that we’ll work together if either of us gets into trouble and need to consolidate
  3. If there is no consolidation to be had then we have the insurance sector to fall back on and necessarily “continuity 3” is only to be considered as a last resort . But it would mean a systemic problem in my opinion and there is no guarantee that a systemic problem might not make any pension certain to be paid, even as an annuity.

Sometimes there is an expectation of certainty about the future that cannot be met. I can remember as a little boy the Cuba Crisis and being told by a girl at school that we would not make it into our teens because the world was going to blow up in nuclear holocaust.

That did not happen and had I taken her advice , she and I would have spent our time digging a nuclear shelter (ridiculous as it sounds today – we must have been 4 or 5 years old). It feels a bit like this setting up CDC today and if we spend our time worrying to a point that we’ve built a pension nuclear bunker, then we won’t have built a pension product that providers up to 60% more pension.

Growing up in the 1960s , nuclear holocaust was what I dreamt of.

But I have Claire (the girl’s name) in my head and it keeps me thinking steadily of worst case. If you can plan for the worst case you have a way to keep your dream open!

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“My property portfolio is no longer a good pension”

Posted on April 7, 2026 by henry tapper

What an easy way “buy to let” seemed.  It got you rich and a retirement income in due course.

“We all lived in a Robbie Fowler House”  at some time and for many of us ,  it was time for us to get our own back. So many of the people I talked with over the past 40 years explained that their properties were their pension

But we are less than a month away from new rules. The FT tells us so in this article.

The FT article says that a lot of the rentals are “accidental” with people inheriting properties and becoming amateur landlords. The “get rich” bit is no longer happening.

Many people will not be able to sell their houses or flats at a profit and this is especially the case in London where flats are in particular in deep price-fall.

As for the attraction of being a landlord, this is looking to reduce from next month when

  • Telling tenants to get out with minimal notice is no longer going to be legal-the abolition of Section 21, which allows landlords to evict tenants without cause.
  • For tenants, the act will mean they can challenge any “unreasonable” rent increases at a tribunal
  • This change is expected to lead to more property tribunal cases and added pressure on an already strained court system
  • Landlords who do not comply with the act will face fines, including £7,000 if they fail to send a Renters’ Rights Act Information Sheet to tenants
  • Landlords will face additional penalties for failing to deal with mould and electrical risks.

If all of this seems to be bad news for Landlords looking  to use their “buy to let” properties to pay their income, there is some hope that

  • tenants are most likely to be the worst hit as the regulations cause landlords to reprice risk and increase rents.

Assuming the increases aren’t seen as “unreasonable”. I can see the word becoming a point of legal dispute the country over. 83% (don’t forget) of private property owners are “small scale”.

Property will be a battleground between landlords and tenants, the former looking to get an income that can be used in later life as a pension, the tenants looking to save for a pension but being held back from doing so by “re-priced risk” from their Landlord.

The big winners look like being the lawyers

I do not see this ending well for pensioners or those who want to have a proper pension. Property is no longer an alternative to pensions for the high percentage of Landlords who find themselves relying on buy-to-let investments to supplement their inadequate pension entitlements.

Let’s hope that this works out fairly and well for small landlords and their tenants; if it doesn’t then pensions will be the worse for it (not that I ever thought buy-to-let was an alternative to our pension system).

 

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Members of the BP pension still wait for promises to be paid

Posted on April 7, 2026 by henry tapper

“Although BP have yet again refused a discretionary increase, the fight goes on. We are waiting for a Pensions Ombudsman ruling, but fully expect it to take several more months. Who knows what the outcome will be, but we are keeping our fingers crossed”. – Murray C Mclaren

BP can afford to pay discretionary increases including payments to those who get no increases. My question to BP is

“should the members of DB pension schemes have a say in the spending of any surplus that their pension scheme distributes?”

Murray and 3,000 others would like to know.

and finally

an article in IPE in which Robert Hulme, ESG manager at West Yorkshire Pension Fund, said:

“BP must publicly explain why they have chosen to trample on shareholders’ rights, or lose the faith of institutional investors.”

I doubt he is alone, either among investors or members.

 

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Tom McPhail’s on Pension Playpen Coffee Morning tomorrow (Tuesday).

Posted on April 6, 2026 by henry tapper

Tom McPhail

Comment from Derek Scott suggests that tomorrow morning’s meeting may be fun

My AI tells me that Henry Tapper and Tom McPhail have a cordial but sometimes sharply different view of pension policy.

Their exchanges have focused on issues such as tax-free cash before a Budget and McPhail’s idea of using private savings as a bridge to a later state pension age, which Tapper has argued is politically unrealistic.

More broadly, Tapper uses their debates to show that pensions are not just technical questions but political ones.

They often seem to disagree on the direction of reform, but do so in a way that reflects professional respect and a shared interest in testing pension ideas.

My own take on an earlier Playpen appearance by Tom, after he had become a new (and by his own admission, inexperienced) trustee for the Aviva Staff Pension Scheme, was to file away for another day (perhaps tomorrow) Tom’s assertion that any DB trustee with a low dependency funding surplus would surely always move to full buyout.

Does Tom still believe that buyout is the gold standard for DB pensions, which will be this year’s Law Debenture debate?  I presume yes.

The invite

The following invite has been  sent by Steve Goddard.

Pension Playpen Logo
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Where bankers show their pension fallibility!

Posted on April 6, 2026 by henry tapper

I know a fair few bankers (and I bet some don’t want to remember me!). They want to mark their happiness to the market but pots of money never do! They need pensions like the rest of us.

You can find the original here.

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Two ways to happily impact growth using pension funds

Posted on April 6, 2026 by henry tapper

Impact investing is something I have a lot of time for. So I was pleased to read these positive messages on an Easter Morning!

I am learning on this subject from my son who works to get impact from our pension investment.

It is a great day to think about positive impact from what we do. I wish my son, his family and those he works with , good will this Easter

 I wish success to those from South Yorkshire who have made their intention for their LGPS pension money very clear!

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How well did your wealth manager really perform in 2025?

Posted on April 6, 2026 by henry tapper

I do not often consider wealth management, I neither manage it or have management to have managed. Robin Powell comments on this world and as a friend I read what he says. You can do here in a blog he made available on linked in for all of us to read.

Nice suit. Glossy brochures. But has your wealth manager ever shown you what a simple, low-cost passive portfolio would have delivered instead?

Robin Powell

Robin Powell

Journalist, producer and financial content marketing consultant

96 per cent of wealthy investors believe they know whether their portfolio performed well. 84 per cent of wealth managers failed to beat a simple passive benchmark. That’s not a knowledge gap. That’s a confidence trick.

If you’re a senior professional, you sit through an annual performance review. Your results are measured against agreed targets. Nobody tells you ‘good year’ and leaves it at that. You’d want the numbers.

Yet that’s the standard most investors accept from their wealth managers. When Y TREE surveyed 250 high-net-worth individuals, 96 per cent were confident they knew whether their portfolio had performed well. But Y TREE’s Plugged into Wealth Management 2026 report tells a different story: 84 per cent of wealth managers underperformed against a risk-equivalent benchmark in 2025.

How can so many feel confident about something the numbers say isn’t happening? Partly because they aren’t measuring what they think they’re measuring. 22 per cent judge performance based on what their adviser told them. Another 21 per cent benchmark against inflation. Very few compare returns to what they should have earned, net of fees, for the risk they were taking. Wealth management underperformance is real. The confidence isn’t.

Why your memory is an unreliable scorecard

Part of the answer lies in how investors remember their own results. A 2021 study found that investor memory is positively biased in two ways. First, distortion: people recall their returns as better than they were, inflating winners and softening losses. Second, selective forgetting: losing investments are less likely to come to mind at all. Both biases independently predicted overconfidence (Walters, Fernbach, Fox & Sloman, 2021).

Your internal track record, in other words, is unreliable. You’re not consulting the data. You’re consulting the edited highlights.

And when the industry’s reporting practices lean on vague reassurances rather than risk-adjusted benchmarks, they don’t correct the bias. They reinforce it. The comfortable feeling that things went well goes unchallenged, because the right numbers are rarely presented.

Wealth management underperformance: three years of data, one consistent pattern

So what do the right numbers show? In 2025, Y TREE analysed more than 550 portfolios across 110 providers. But the real story is the three-year trend. The pattern is persistent.

In 2023, 92 per cent fell short, by an average of 6.2 per cent. In 2024, 88 per cent lagged, by 4.1 per cent. In 2025, the figure was 84 per cent, with an average gap of 4.3 per cent.

Credit where it’s due: that trend is improving. But 84 per cent is still damning, especially across three years of strong global equity returns.

“Stock and bond selection, the core activity wealth managers are paid to do, reduced returns by 3.4 per cent on average. Bad luck doesn’t explain it.”

What’s most telling is where the losses came from. Stock and bond selection, the core activity wealth managers are paid to do, reduced returns by 3.4 per cent on average. That isolates manager decisions from broader market movements. Bad luck doesn’t explain it. This is what clients are paying for.

The pattern held across every risk level, too. Cautious portfolios lagged. Aggressive portfolios lagged. Taking more risk didn’t improve the odds.

A note on how Y TREE measures this. Their benchmark is an investible, risk-equivalent, globally diversified fund, measured net of fees. Think of it as a nutrition label for your portfolio: it shows what you should have received given the risk in your holdings, not a comparison to the FTSE 100. It measures whether your manager added or destroyed value relative to a straightforward, cost-efficient alternative that is available to buy in the market today.

This isn’t an outlier

Y TREE’s findings might look dramatic in isolation. They’re not. They sit within a global evidence base stretching back decades.

The SPIVA Europe Scorecard Year-End 2025, published by S&P Dow Jones Indices, found that 75 per cent of GBP-denominated Global Equity funds underperformed over one year. Over 10 years, 97 per cent. For UK Large- and Mid-Cap Equity funds, 89 per cent fell short in 2025; over a decade, 95 per cent.

And the few who do outperform? They almost never keep it up. The SPIVA Europe Persistence Scorecard Year-End 2024 shows that of UK equity funds in the top half, just 3 per cent were still there after five consecutive years. For the top quartile, the figure was zero.

None of this should surprise anyone familiar with William Sharpe’s arithmetic of active management: before costs, the average actively managed pound must match the average passively managed pound. After costs, it must be less. Pure mathematics (Sharpe, 1991).

In the US, Morningstar’s Mind the Gap 2025 research adds a further wrinkle. Investors’ own timing decisions cost them roughly 1.2 percentage points a year over the decade to December 2024, around 15 per cent of total returns forgone. Manager underperformance is only part of the problem.

What underperformance actually costs

Basis points sound abstract. Years of your life don’t.

Y TREE’s report puts the cost of wealth management underperformance in terms any high-earning professional understands. At three per cent annual drag over a decade, a £10m portfolio could fall £4.67m behind where it should have been, the equivalent of roughly 8.5 additional working years.

The chart below tells the same story from a different angle. Even at a lower drag of two per cent, a £5.4m portfolio forfeits £6m over 20 years — more than the original investment.

Set that against BlackRock’s long-term assumption for global equities: six to seven per cent per year. If your wealth manager is trailing by four to five per cent, they’re giving back most of your expected returns. You’re taking the risk. Someone else is keeping the reward.

Think back to that annual performance review. A managing director or senior partner who discovered a supplier eroding value at this rate wouldn’t schedule a follow-up meeting. They’d replace the team. Yet when it comes to their own wealth, that professional rigour vanishes. One in four investors in Y TREE’s survey have never changed their wealth manager.

If you think of yourself as the CFO of your own financial life, the question writes itself. Are you holding your wealth manager to the same standard you’d hold any other supplier?

“You’re taking the risk. Someone else is keeping the reward.”

The review your wealth manager never gave you

The wealth management industry has, for years, operated the equivalent of an annual review with no targets. Your manager tells you it was a good year. Your memory agrees. And the reporting you receive is rarely designed to challenge either assumption.

What Y TREE’s data has done is supply the benchmark that was missing. Wealth management underperformance isn’t an anomaly; it’s a persistent pattern backed by decades of independent research. The psychology explains why it goes unnoticed: your memory flatters your record, and the industry’s reporting lets it.

So, do you want to see how your wealth manager has performed against a risk-adjusted benchmark? Y TREE can show you. The only thing more expensive than finding out is not finding out.

Resources

Y TREE. (2026). Plugged into Wealth Management 2026. Y TREE.

Walters, D.J., Fernbach, P.M., Fox, C.R. & Sloman, S.A. (2021). Investor memory of past performance is positively biased and predicts overconfidence. Proceedings of the National Academy of Sciences, 118(36), e2026680118.

S&P Dow Jones Indices. (2026). SPIVA Europe Scorecard Year-End 2025. S&P Dow Jones Indices LLC.

S&P Dow Jones Indices. (2025). SPIVA Europe Persistence Scorecard Year-End 2024. S&P Dow Jones Indices LLC.

Sharpe, W.F. (1991). The arithmetic of active management. Financial Analysts Journal, 47(1), 7–9.

Morningstar. (2025). Mind the Gap 2025. Morningstar Research Services.

Robin Powell is a freelance journalist, author and financial consumer advocate. He’s the Editor of The Evidence-Based Investor.

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Can DC pensions invest for growth or should we move to CDC?

Posted on April 6, 2026 by henry tapper

The questions discussed on the VFM blog have so far been rather less than challenging. I posted my review of the latest podcast yesterday and got this question on my blog. John is an IFA who started in the mid 1970s and still thinks hard about delivering value to those who were his clients and now are pensioners as he is. Here is his question.

Well the answer to that question has been simple over the past fifteen to twenty years. If you run a DB scheme your strategy whether as trustee, executive or sponsor is to “de-risk”. The appetite for higher growth assets like UK tech or infrastructure has been reduced by threats by TPR to take action against trustees who take risk and jeopardise the sponsor (employer).

For DC schemes, there is the commercial consideration that investing in alternative assets, often in the private markets and hard to value , makes such assets unfeasible for the provider and of little interest to the trustee (who is the goalkeeper not the striker) to use a good analogy from Nico in the latest blog).

In short there has not been much motivation to invest in high risk investments because the short-term impact of failure outweighs the potential for growth in the long term. Although pensions have the longest of liabilities (our lifetimes and those of future generations), the thought of DB schemes lasting much longer than the current “end game” has made the question exclusive to LGPS and to an extent USS, Railpen and a few defiant schemes run by UKAS , the unions and a few outliers from the public sector (the MP’s DB scheme is an outlier).

The DC schemes are now beginning to adopt risk. Mark and Elizabeth and Paul at Nest have shown they are interested in investing in infrastructure and People’s and a few other larger insured and consultancy  schemes are  taking a few decisions to invest for the long term in what are high-risk short term assets. But let’s not be too optimistic, we have no Maple 7 equivalent yet in Britain. If VFM pits DC schemes against the best, there must be “best” DC schemes which invest for the long term for growth and this is very hard for DC to do. There is always the consideration that it is the member/policyholder’s pot. There is freedom to take money away and that means liquidity is more important than perhaps it should be.

When I say “should be”, I mean the situation that DB and CDC schemes have when in their sweet spot with no consideration of liquidating individual pots and where the DB and CDC schemes have an infinite investment horizon. You know the diagram that Derek Benstead drew me to explain the innate advantage of a pension scheme over a savings scheme.

Here we have the answer to John Mather’s question. So long as CDC stays open , the market value of the fund is irrelevant. It is not marked to market as a DC or closed DB scheme is because it is not in an end-game, liable to pay-out its proceeds free from pensions or to a bulk annuitant.

With the clarity that an open pension scheme has (whether DB or DC) , a DC scheme has no chance to compete over the long term and so is relatively lousy value for our money. It is simply constrained as a closed DB scheme is constrained.

I hope that the longer term impact of CDC is to return pensions to the kind of strategy that John Mather wants to see as the benchmark for VFM. That strategy may be achieved to a degree by the larger DC schemes which can as the big master trusts are beginning to do, invest in long term assets but I think they will never reach their full potential till they become collective with a single pot and a simple aim of paying everyone as much pension as can be afforded.

I could have asked John’s question and should have done to the podcast. I hope that people will send in their views to this blog either privately or by comment. It is important that the big questions facing us as we consolidate and move towards collective pensions, are discussed and that we do so openly and passionately!

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Questions to the VFM boys

Posted on April 5, 2026 by henry tapper
Darren
Nico

I’ve listened to the V-FM Pensions #154 at which point the boys start answering the numerous questions that have followed their plea for an interrogation.

Let’s be clear , this is the AI summary, not the inspiration of the boys.

In this episode of V-FM Pensions, hosts Darren and Nico put themselves at the mercy of listener questions in this Q+A special (part one…) that lays bare some of the current and emerging fault lines in UK pensions…

Listeners’ questions push Darren and Nico to discuss whether VFM is about member outcomes, system outcomes, or society at large? Pensions exist to pay money in retirement, and anything else is a bonus only if it doesn’t cost members…. discuss?

From net zero to DB schemes quietly propping up government debt, the episode surfaces a deeper tension that is at the heart of the system… are pensions private savings vehicles or instruments of public policy?

The hosts are critical of the current VFM framework as being too focused on inputs, blind to real-world outcomes, and ill-equipped to judge a 60-year savings journey. Meanwhile, engagement remains superficial, policymaking short-term, and adequacy the elephant in the room.

And hanging over it all, a bigger doubt: what if the long-term equity growth story the whole system relies on doesn’t hold?

Actually , what we get is a chance for Nico to explain why he’s on the side of Rousseau and against Hobbs when he answers a question from David Porter (or Doggo the dog).

We get another question from David Porter and one from Karen, Darren’s partner at Untamed Consulting. Chris Blackwood asks a question about investments (he’s the comms guy at Border and Coast).  All questions give Nico opportunities for merriment at Darren’s simplicity.

Darren promises to keep within the Tapper timescale of 60 minutes but as you can see above, they fail – not keeping it within 7o minutes. However-  we don’t get an hour’s question time, half the time seems to be discussing where the podcasts are going, come from and how they are going to fit in all the other questions.

Here’s that enjoyable Chat GPT talk – again!

All the questions so far have been reordered by AI and restated. As well as the abovementioned we have questions from Helen Forrest Hall, Simon Chrystal , Karen Quinn and  Paul Watson (whose idea this and the next podcast was). That’s about ten minutes answering each question.

All the questions are apparently too long. I think I’m down on the list for my question

Should the members of DB pension schemes have a say in the spending of any surplus that their pension schemes distributes?

If that can get a little shorter, no doubt Chat GPT or similar will find out how. We have till later in the weekend to find out if we get an answer.

Or another podcast at a time when our two Arsenal fans must be desperate at the team’s performance at Southampton on Easter Saturday.

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Sub scale DC schemes -another whinging amendment goes through the Lords

Posted on April 5, 2026 by henry tapper

The amendment is being introduced as Amendment 77 –

put forward by excepted hereditary Conservative peer Viscount Younger of Leckie and voted for by the Lords on Thursday (19 March) – added an exemption from the scale requirement for DC multi-employer schemes to hold at least £25bn in assets from 2030.

Lord Younger who makes his money from recruitment and from being a Lord

I do not know of any reason why Lord Younger has been  involved in this amendment other than the Conservatives needed someone to put it forward.

This amendment is supported  by Penfold (a GPP that offers workplace “pensions”). The amendment every small DC scheme will take some hope from and an amendment which will get thrown out by a lower house that’s getting used to dispensing with frivolous pension amendments.

Frankly, it has no place being discussed seriously when it is clear the only intention of the Conservatives is to wreck the bill.

Just about every DC workplace scheme (apart from NOW pensions) can show some people whose pot has passed a VFM test in terms of performance and the fluffy bits around the side.

But as we all know, the point of the VFM test is to find another route to get rid of small workplace pension schemes, especially the non-commercial ones that don’t get clobbered by the commercial scale test.

So is the Government going to give all the workplace pensions (including the commercial ones) an escape hatch?

Well let’s look at some of the options available to Penfold, and other commercial GPP workplace schemes.

  1. They can sell out to a commercial scheme which has got scale (or are likely to)
  2. They can convert to a CDC that do have the contention that DC schemes don’t get
  3. They can go and buy something very big and get scale PDQ

The proposal from threatened small commercial DC schemes will look like this (thanks Professional Pensions).

The Lords’ amendment to clause 40 of the bill would give TPR the power to determine a relevant master trust or group personal pension scheme is meeting the scale requirement if it was satisfied there was “no reasonable evidence that consolidation of the scheme into another arrangement would be likely to improve outcomes for members”.

It said that, in making the determination for an exemption, TPR must look at areas such as net risk-adjusted investment performance; governance quality and operational capability; and whether or not the scheme benefited from integrated, pooled or cross-scheme investment arrangements.

I’m sorry but I have no idea what good this will do other than keep a small number of small commercial DC savings schemes going. I say “savings” as Penfold have made it clear they are looking to use somebody else’s default retirement income arrangement (R-CDC or Flex and Fix).

The amendment also said TPR should consider the extent to which the scheme invests in a default arrangement operated by another scheme or manager meeting the scale requirement; and whether the scheme benefits from participation in a wider asset management group of substantial scale.

So what have we got left from schemes like Penfold and other workplace arrangements? As far as I can see they are there to collect contributions via auto-enrolment from employers and act as feeders to other schemes that are prepared to offer retirement income.

Isn’t it time that option 1-2-3 (see above) is put into place so that by 2030, these workplace pensions are either CDC, sold to a current rival or owning a bigger current rival? The reason for Penfold and Collegia and others to exist is to bring new ideas to the market. They excel in adapting new technology but mimic what is already there in terms of GPP schemes and the same could be said of excellent commercial mastertrusts (Lewis master trust springs to mind).

There is of course a non-workplace version of what these schemes do, it is demonstrated with brilliance by Pension Bee. This type of scheme does not solve its distribution problem by using AE to connect with employers providing a “workplace” solution. It is not subject to the scale test because it is chosen by savers not by bosses.

The alternative  solution for schemes like Penfold involves a different VFM assessment. It would be tested by consumers who know what they want, choosing their savings plan on merit.

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