REPUTATION MATTERS FOR PENSION TRUSTEES Issue 4 2015
CONTENTS
Introduction
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The Investment Transformation Programme at the Railways Pensions Scheme By CiĂĄran Barr
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Longevity De-Risking A New Model for UK Pension Schemes? By Andrew Waring
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An opportunity cost of de-risking By Andy Downes
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A letter to the Prime Minister By Allan Course
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How can the sponsor covenant be affected by major one-off events? By Donald Fleming
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A Consersative majority: full steam ahead on radical reform By Joshua Peck
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INTRODUCTION
Welcome to our fourth issue of MHP’s Reputation Matters for pension trustees.
Allan Course of Capital Cranfield writes a light-hearted plea to the new Government to treat pensions seriously, much as trustees approach their responsibilities to their schemes.
This edition is mainly concerned with new approaches that are being or can be taken by Trustees which may have wider relevance to other schemes. We feel it’s a theme especially appropriate in an election year, and with radical changes impacting on the broader pensions landscape.
Donald Fleming of Gazelle looks at how risk management for trustees should now encompass major one-off events that can impact the covenant disproportionately.
Ciáran Barr, Investment Director of RPMI, writes about the Investment Transformation Programme that RPMI is undergoing. Designed specifically for RPMI’s unique requirements, there are nonetheless wider lessons for other schemes. Andrew Waring, Chief Executive of Ensign Pensions and the MNOPF, describes the longevity swap via a ready-made insurance cell that they created with Towers Watson – an innovative solution which could be used cost-effectively by many other smaller schemes.
Finally Joshua Peck, head of MHP Corporate Affairs summarises what we can expect of the Government in the pensions arena following on from the high level of activity in the last five years. We very much hope you find the articles of interest. As always we welcome your comments and suggestions. This year we are doing almost all distribution online but there are print copies which we are happy to provide in appropriate quantities.
Nick Denton and Andy Fleming MHP Communications nick.denton@mhpc.com
Andy Downes of Stamford Associates has written on the opportunity costs of de-risking and the need to balance between return driven and liability matching investments. For the former there should be an important role for genuine active managers who can make a significant difference for schemes over the long term.
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THE INVESTMENT TRANSFORMATION PROGRAMME AT THE RAILWAYS PENSION SCHEME By Ciarán Barr
The Railways Pension Scheme (RPS) serves the UK rail industry and has around 350,000 members and pensioners from over 100 different employers. The Scheme has over £21 billion under management and has been in existence in its current form since the privatisation of the railways over twenty years ago. In 2012 the Trustee started the Investment Transformation Programme (ITP), a thorough review of the investment arrangements. In this article Ciáran Barr describes why the review was thought necessary as well as outlining the resulting changes, which are now being implemented.
Why change? The RPS is a complex Scheme. There are over 110 individual pension arrangements (known as Sections) each of which has its own distinct liabilities. These Sections invest their assets collectively through pooled funds. Before the ITP there were 14 pooled funds most of which represented single asset classes, all with distinct benchmarks and performance targets. The multi-asset Growth Pooled Fund had already been launched in 2010 and was gradually growing in importance, both in its aggregate size, and as part of individual Sections’ investment strategies.
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Each Section’s individual strategy needed to take account of its distinct profile (including maturity, employer covenant and cash-flow requirements). Against this complex background, the global financial crisis underlined how quickly circumstances could change in financial markets. In addition it highlighted how it is unrealistic to rely on diversification across asset classes at all times, and reaffirmed the need to consider the management of cash-flow and liquidity in stress scenarios. Just as importantly the crisis also provided investment opportunities – something that is often overlooked in commentary on lessons learned – and reaffirmed the importance of flexible, effective decision-making. Finally, as we moved into the post-crisis world there was a concern that future returns on risk assets might be compressed by the low level of real interest rates. This meant investments needed to work harder to generate the required return.
A new investment approach In response to these challenges the Trustee decided to review the Scheme’s investment arrangements and tasked RPMI Railpen to work with Roger Urwin of Towers Watson on the ITP. The objective was to become a worldclass asset owner by considering – individually and holistically – all aspects of the investment process. One of the early tasks was to review the Scheme’s investment beliefs which were felt to be too complex and difficult to apply.
In 2014 a new simplified set of core beliefs was agreed and introduced by the Trustee. These were woven around some key considerations including:
•a focus on risk premia (the returns available for taking identifiable risks) • t he need to manage risk in multiple ways • t he importance of asset class valuations on long-term returns •a lignment of interests both internally and externally •c lear accounting of costs in investment decisions
Another core belief focuses on the importance of strong governance, leadership and culture. With this in mind the Trustee decided to create a new Railpen Investments Board (RIB) to oversee the management of the pooled funds. RIB is made up of a majority of independent non-executive investment professionals (including the Chair). Before this new structure was introduced much of the discussion about investment decisions took place at the Trustee level. The new arrangement allows the Trustee Board to focus on strategic top-level issues such as the nature of the pooled fund range and appropriate principles for setting investment strategies for Sections. The Trustee believes that the best investment solution for most of its Sections can be achieved through investing in a small number of distinct multi-asset funds.
Following a review of the existing range the Trustee decided to move to a smaller number of distinct multi-asset funds (covering different risk and liquidity requirements) and a ‘de-risking platform’. The aim was to further develop the more flexible and efficient multi-asset approach, while also ensuring that every potential attractive investment opportunity had a home. Although the pooled fund range has been simplified, it still allows for a wide range of Section investment strategies.
Ciarán Barr is Investment Director at RPMI Railpen
ITP has also led to a change in the way that the Scheme manages the funds to efficiently implement risk premia. There are several strands to this. Firstly, we analyse which risk premia we want to hold within the pooled fund range by estimating expected return drivers over different time periods. Secondly, when assessing an investment or asset class, we look to estimate the underlying risk premia being accessed and hence “strip out” disguised beta. Thirdly, we are agnostic as to the method of investment (e.g. internal vs. external, passive vs. active) but make an assessment based on net value add after taking into account costs. One of the important characteristics of the review was to make the investment arrangements, ‘as simple as possible but no simpler’. We believe this has been achieved with the use of clear investment beliefs, stronger governance, a flexible pooled fund range and clear estimations of what we are buying and what we expect to get in return. This should support the RPS as it faces uncertain financial markets in coming years and decades.
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LONGEVITY DE-RISKING: A NEW MODEL FOR UK PENSION SCHEMES? By Andrew Waring
In recent years, de-risking has become a focus for the Trustee Boards of mature DB schemes as they seek to improve the security of their members’ benefits. The Merchant Navy Officers Pension Fund (MNOPF) is such a scheme, having been established in 1937 to enable shipping companies to provide retirement and death benefits for their officers. Last year, the MNOPF completed the buy-out and wind-up of its Old Section, which closed in 1978, and earlier this year completed a “longevity swap” involving the New Section of the Fund. The nature of this transaction was interesting and perhaps will provide a path for other schemes to pursue similar transactions that may previously have been prohibited by cost.
Largest Future Risk Longevity risk was the third biggest risk that the Fund was facing (after equity and interest rate risk) and was expected to become by far the largest risk over the coming decade as the Fund’s investments were progressively de-risked. The Trustee recognised that should members live longer (and therefore continue to receive their MNOPF pension for a longer period) than currently expected, consistent with significant improvements over time in seafarers’ living conditions at sea, this would present a significant risk to the Fund’s objective of achieving full funding. Longevity hedging works on the basis of a pension scheme paying an insurer an agreed “premium” in exchange for 4
the insurer agreeing to meet the pension liabilities of the insured population. The reinsurance market specialises in this area and is utilised to ensure that competitive pricing can be obtained. Pension schemes are not permitted to deal directly with reinsurers however, so an intermediary is required to transact with the scheme and the reinsurer. In the past the options previously employed by schemes were to use a traditional ‘intermediary’ such as a UK bank or insurer or to create an insurance cell company for this purpose. (This was the route followed by the BT Pension Scheme in 2014). Both routes, however, involve significant cost to implement. Towers Watson has a long standing relationship with the MNOPF, acting as Actuary and Delegated Chief Investment Officer. Towers Watson was developing a service, “Longevity Direct”, aiming to offer a more cost efficient route to execute a longevity transaction. This would provide clients with a ‘readymade’ insurance cell to access the reinsurance market. What Towers Watson needed was a pension fund that was prepared to transact a longevity hedge via this innovative solution.
Innovation Solution Having allocated a risk budget, the Trustee’s objective was to insure £1bn of pensioner liabilities. However, the competitiveness of the reinsurer pricing meant that £1.5bn of pensioner liabilities was eventually included in the transaction. The longevity hedge has been a major success for MNOPF, reducing risk in the Fund by around 10% at what was felt to be a very attractive cost.
To effect the transaction, MNOPF set up a Guernsey based cell, MNOPF IC Limited, which is an incorporated cell set up with Towers Watson ICC Limited. MNOPF then entered into an insurance agreement with MNOPF IC Limited with the cell acting as a conduit, passing risk from the MNOPF to the reinsurance market.
On the other side of the transaction MNOPF IC Limited entered into a reinsurance agreement with the reinsurer on terms which were economically the same as the insurance agreement between MNOPF IC Limited and the Fund. Therefore MNOPF IC Limited retains no direct insurance or market risks from the transaction.
But why Guernsey? Well, Guernsey has the necessary infrastructure and regulatory regime to accommodate such arrangements. In particular, the Guernsey regulatory capital regime requires a minimal level of capital reflecting the position that no risk in relation to the longevity hedge remains within the cell.
Two Major Benefits
The pension fund, MNOPF, pays to MNOPF IC Limited premiums that are defined amounts, being 100% of the pension payments that would be expected to be made to the pensioners and widow(er)s based on the defined longevity assumptions. These premiums include the “fee” for the reinsurer to take on the longevity risk. MNOPF IC Limited then pays to the Fund amounts equal to the pension payments (in respect of the pensioners insured) that the Fund has actually paid out. The net payment in any period between the cell and the Fund will simply be the reinsurer’s fee where actual longevity experience follows that expected by the reinsurer. If longevity is more or less than assumed, this will result in a net transfer from or to MNOPF IC Limited depending on whether pensioner mortality is heavier or lighter than expected.
How it works:
MNOPF benefitted in two areas; first under a typical longevity hedge, the intermediary insurer/bank typically charges 1–1.5% of the liabilities as an intermediary commission. Under the Longevity Direct structure, this fee is replaced by the cost of setting up and operating MNOPF IC Limited, a saving of well over 50%. In addition, when a transaction is completed via an intermediary, it may typically be spread across two or three reinsurers as the intermediary may have limits on its credit exposure to individual reinsurers. This results in the price of the hedge being the average of two or three market prices, which may significantly increase the price of the transaction. With the captive cell structure, the best reinsurance price can typically be achieved for all of the covered liabilities. Both these factors resulted in a significant cost saving to the Fund when compared with the traditional approaches. Overall, this new approach opens up the opportunity of more cost effective longevity hedging for smaller pension schemes and presents a new opportunity for both the funds and reinsurers. It will be interesting to see if the idea is taken forward by other schemes.
TW Guernsey ICC Limited
Beneficiaries
Payments based on actual experience
Payments based on actual experience
MNOPF
Andrew Waring is CEO of Ensign Pensions and of the MNOPF
Reinsurance market MNOPF IC Limited
Reinsurer Payments based on agreed assumed experience
Payments based on agreed assumed experience
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AN OPPORTUNITY COST OF DE-RISKING By Andrew Downes
Trustees can find themselves in a difficult position when trying to satisfy three different and sometimes opposing constituencies – members, employers and the Pension Protection Fund (PPF) – while dealing with pension schemes in deficit. It is not surprising that many are gravitating to de-risking solutions and, although we believe these can have a role to play, trustees run a risk of over-using them to the detriment of members and employers as a result. The Pensions Regulator encourages trustees to work with the employer to improve the stability of their pension scheme so that the risks of insolvency and having the PPF act as a last resort are minimised. At the most recent NAPF Investment Conference in Edinburgh one attendee is alleged to have described de-risking solutions as a “disaster”. 1
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We wouldn’t go quite that far, but it is nonetheless incumbent upon trustees to ensure that any de-risking strategy is in the best interests of the member beneficiaries and not just the employer or the PPF. According to the latest edition of the Purple Book,2 pension schemes continued to reduce their risk in 2013/14 and our concern is that if trustees err too much on the side of prudence there is a danger of de-risking unnecessarily. The opportunity cost of an otherwise potentially better investment return could prove immensely regrettable, such that the trustees would sacrifice an improved chance of securing member benefits and the employer would lose the flexibility to invest capital elsewhere in the business.
Unnecessary De-risking An ill-conceived (excessive) switch from return-seeking to liability-matching assets can hinder the potential for a pension scheme to reduce any funding shortfall of its own accord. Unfortunately, a good number of schemes have been let down by active investment managers taking a short-term closet index approach with very little, if any, added-value for the relatively high fees charged. Trustees should not, however, tar all with the same brush and lose faith in the ability of carefully selected active investment managers to play their part.
A focus on cost reduction has also pushed pension schemes down the path of cheaper passively managed strategies, although trustees should not be hoodwinked into the belief that such an approach is less risky. Passive investors need to be aware of concentration risk for instance – where portfolios can be predominantly invested in a relatively small number of companies3 and be exposed to hefty unmanaged sector/country/currency exposures. Passive investment managers do not analyse companies or pay attention to their fair value. Rather than attempting to separate the wheat from the chaff, they simply accept the good, the bad and the ugly on a rollercoaster ride they cannot control. Interestingly, it has been reported that LGPS, which may be forced to go passive by the government, may consider legal action to stop such a shift.4
Genuine Active Management Active investment managers, on the other hand, are vital for the markets to function efficiently and as passive investment becomes more prevalent their prospects to capitalise on increasing market inefficiencies actually improve. In our view, the best investment managers show conviction in their best ideas, generally ‘eat their own cooking’ and are patient investors, exploiting opportunities that inefficient markets offer through short-term sentimentdriven behaviour.
Yes, the most gifted managers tend to limit the investment capacity of their offerings and so this does mean that this exclusivity can come at a higher price. Ensuring financial fitness in retirement is possibly the longest investment commitment an individual is likely to face and time should really be a friend. A sensible split between return seeking and liability matching assets should provide a solid platform from which to allocate to genuine active managers who can make a meaningful contribution to the benefit of members and the employer alike. De-risking should therefore be carefully considered alongside the realisation that it is the complexity and volatility of markets that offer opportunities for genuine, first rate active investment managers to make a significant difference over the long-term.
Andrew Downes is a Senior Investment Consultant at Stamford Associates
It is true that these managers are hard to find, but trustees should not lose heart. In our experience a forensic approach to manager research and monitoring over the long term can prove very effective in supporting the search for alpha.
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“TPR criticised for pushing de-risking – NAPF Investment Conference”, Pensions Age, 13th March 2015
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The Purple Book, published annually by the PPF and the Pensions Regulator, monitors the risks faced by more than 6,000 defined benefit pension schemes covering over eleven million members in the UK
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e.g. just fifty UK companies (7.8% by number) account for nearly three-quarters of the leading FTSE All Share Index by value
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“LGPS funds could consider legal action over mandatory passive shift”, Investments & Pensions Europe, 23 April 2015.
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A LETTER TO THE PRIME MINISTER By Allan Course
Dear Mr Cameron Pensions – the next five years I am delighted that you have appointed Ros Altmann as Pensions Minister – while she is getting underway, in the spirit of helpfulness I’d like to put forward a few suggestions.
The New Regime The previous government introduced the most fundamental change to private sector pensions in a generation – allowing DC members complete freedom on how they take their benefits. Also, by continuing to allow DB members to transfer to DC arrangements, they can also access these new options. As you know, opinion has been divided on the merits or otherwise of this change. The media has not been overly helpful in this respect, with its obsession of trying to categorise such matters as “good things” or “bad things”. While this may make for more interesting articles, it does not make for a meaningful debate. For what it is worth, I would bet that most people will make fairly sensible decisions while a small minority will make unwise ones. Of course, “unwise” is a very loaded word. Critics might consider it unwise for someone to blow all their pension benefits on a few years of holidays, parties and general fine living and then have a meagre lifestyle thereon, but who are they to judge?
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If you’ve had forty years of struggling along in a fairly boring, averagely-paid job, five years of good living could be a real treat, with great memories to treasure for the rest of your life. The one caveat I would put to this is that I personally would not be happy about that person then getting excessive social security benefits (or even sympathy) in respect of their reduced circumstances in later years. With pensions, as with most things in life, “do what you want to, but then accept the consequences without moaning” is a good maxim. By the way, are you ready for the law of unintended consequences to come into effect? I can well see quite a few people re-investing their pension benefits into property, with an aim to “buy to let”. Consider someone aged 55, with a deferred DB pension from age 60 of £10,000 p.a. or so – not a lot, I think you’ll agree. Nevertheless, the transfer value for this would be of the order of £250k, which the member pays into a DC arrangement and sets up a 10 year drawdown or annuity to pay for the mortgage for the buy to let house. The results? Increased housing demand, pushing up prices and making it even harder for young people to get on the property ladder! If I were you, I’d start thinking about how you could do an objective review in five years’ time of whether the changes have overall been positive – if they have not, do I have the courage to reverse them!
The Pensions Regulator Please have a think about the Regulator’s duties and powers. One of its objectives is “to protect the benefits of members of occupational pension schemes” and another is “to minimise any adverse impact on the sustainable growth of an employer”. You don’t have to be an Einstein to see that when it comes to discussions on funding scheme deficits, the objectives of a scheme’s trustees can be fundamentally different from those of the scheme’s sponsor. Often, this results in the two parties failing to agree, missing the 15 month deadline for completing the triennial valuation and having to report to the Regulator. What does the Regulator then do? It merely urges both parties to work together and arrive at a solution both can live with! Not exactly effective, I think you’ll agree. While it is true that the Regulator does have powers to intervene and direct in extreme situations, this is pretty much a “nuclear option” and is hardly ever used. Would it not be a good idea to give the Regulator additional, lesser powers so that it can step in as a referee or arbiter when trustees and employers simply cannot agree?
Next, please would you have a quiet word with the Regulator and ask them to give us all a break and stop issuing guidelines and pronouncements as if there is no tomorrow. This creates extra work for trustees who already run their schemes well but feel that they ought to meet the Regulator’s expectations, no matter how trivial. By contrast, it does nothing to change the behaviour of trustees who just do the minimum they can get away with. Micro-management by government has been a significant factor behind the demise of DB schemes – we’d all like you to learn from this.
Allan Course is a Client Director at Capital Cranfield Trustees
Lastly, as an aside, are you aware that practically every covenant assessor goes down on bended knee every night and offers prayers to the Regulator that it does not recommend we all use a simple, broad-brush approach to considering the long-term viability and profitability of an employer? They are all aware that looking further ahead than three or four years is little better than a guess, but the work does pay well!
Conclusion I hope you will have gathered that when it comes to pensions, I would like governments to act like good trustees do – with clear objectives in mind, proportionately and pragmatically. I live in hope that this may happen in my lifetime.
Best wishes Allan Course
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HOW CAN THE SPONSOR COVENANT BE AFFECTED BY MAJOR ONE-OFF EVENTS? By Donald Fleming
Tesco, BP and Deepwater Horizon, UK banks and PPI selling – just some of the numerous examples of corporate practices, unforeseen industrial accidents and events which have damaged corporate reputations, created material financial liabilities due to litigation or product claims and, in some cases, precipitated major changes to business models. DB pension schemes rely on their corporate sponsors to be able to support them typically over several decades. How should the risk of seemingly unpredictable events and the sponsor’s ability to repair or address losses caused by such events be viewed from the long-term perspective of the pension stakeholder? We suggest that even if the events cannot be foreseen, it is possible to gauge the potential financial risk to members’ benefits through advanced modelling techniques and to help prepare trustees to be as well positioned as possible through scenario planning exercises.
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Gauging long-term financial risk to members’ benefits Covenant analysis of the sponsor’s financial statements and the business dynamics will help trustees assess the financial impact of major one-off events in the near-term. For instance, there is extensive information available to BP stakeholders about the direct financial costs of the Deepwater Horizon disaster. For most companies though, the number of macro-economic and business variables limits the value of deterministic forecasts over the very long-term. (An exception would be the regulated utilities sector). This in turn limits the ability to assess longerterm risks to members’ benefits – even without a corporate disaster. Adding major one-off events to the mix adds just one more “known unknown”. Taking the BP example again, the direct financial effects of settling the legal claims and penalties on BP has only now been settled, some few years after the disaster, while the longerterm opportunity cost and the financial impact of the damage to its corporate reputation (which itself is not captured on the current balance sheet) is very uncertain. The use of advanced probabilistic modelling techniques (which process a very large number of financial scenarios) is now enabling trustees to consider what would be the impact on pensions risk of a wide range of financial scenarios, including financial stress, even if the triggering event giving rise to this cannot be foreseen.
There is a spectrum of event scenarios, ranging from those with an identifiable event where the financial impact is controlled to those which cause the company to collapse, and any number of events and compounding factors in-between. For example, the effects of a product defect which does not affect safety or reputation might be limited to the financial cost of product recall. At the other end of the scale are apparently strong businesses brought down by events. For example, problems in the wholesale funding markets threatened Northern Rock’s liquidity; when combined with failures in board oversight, regulatory intervention and rapid media dissemination of concerns, there was a “run” on the bank. This also exemplifies the importance of reputation to corporate strength in some industries such as banking. Bank creditworthiness is underpinned by its counterparties’ confidence in it – reputational failure can in itself be existential. Even without collapse, the way in which management reacts to reputational events can lead to reduced profitability and financial strength, as shown by the business and regulatory responses to PPI in the banking industry.
Scenario planning How can pension trustees plan for events which are inherently unpredictable and dependent on how other parties behave? Just as companies develop their own risk management plans and strategies, so too are some far-thinking trustee boards carrying out exercises to plan how they might react to specific events and how these might affect their view of sponsor covenant risk. The scenarios will of course be highly company and scheme specific; such as, an incident at a manufacturing company’s key site. Such exercises are also an opportunity to work with the company’s risk management team to understand any plans that the company might have and to improve governance – it is vital to have good communications and decision-making procedures in place.
Donald Fleming is Managing Director at Gazelle Corporate Finance, Pension Advisory
Surveys of major company boards repeatedly point to reputational risk as being the key area of focus, but also the most difficult for them to assess and to manage. Trustees are not running the company but are exposed to the risk that the company’s senior management fails to assess and manage the variety of risks affecting their company, including reputational risk. So it is critical that trustees think about “what if…?”
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A CONSERVATIVE MAJORITY: FULL STEAM AHEAD ON RADICAL REFORM By Joshua Peck
Steve Webb was a key figure in revolutionising the UK pension system in the last parliament. His introduction of auto-enrolment (AE) and weighty reforms to the state pension ensure a long-lasting legacy, even if he has since lost his seat in parliament. Despite this, the nature of his role was already shifting towards the end of his tenure. Steve Webb’s quiet revolution suddenly became George Osborne’s very public revolution. From the Budget 2014 onwards, Mr Webb’s role became more focused on implementing the Chancellor’s pensions’ freedom policy agenda. With the grey vote a key Tory constituency, Osborne was clearly keen to ensure that it was Tory reforms that grabbed the majority of the headlines.
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While the Chancellor’s annuity reforms initially shocked the industry, it was the Labour manifesto that it feared most. They had threatened to water down a whole host of government reforms and this would have created considerable uncertainty had they got in to government. In contrast, the pensions sector would have hoped that a Conservative majority provided some much needed continuity. The sector would have hoped that the government now gives them time to consolidate, in order to allow the reforms from the last parliament to bed down. It is now clear this will not be the case. Last month’s Budget announced a consultation which could turn pension provision on its head.
The consultation, open until the end of September, will look at “an alternative system”, which would help young savers understand pension plans. One option which has been mooted is an ISA-style model, in which taxation ceases to be applied when the pension is withdrawn, and instead levied on contributions. So-called Isa-isation would likely trouble Labour, as it moves pensions even further away from a source of income. (Not that the Labour party is currently in any fit shape to oppose the Government’s reforms.) Industry figures have also raised a series of questions, not least if pensions are simply to become much more like savings, what exactly does the role of the pensions industry become? Others have suggested that the move to an ISA-style ‘Taxed-Exempt-Exempt’ format looks like another crafty deficit reduction trick. By moving the tax burden to future Chancellors, Osborne could open up an instant revenue stream for himself.
At the very least a consultation process on these issues will be welcome. The Government was widely criticised for not consulting on the annuity reforms introduced in the 2014 Budget. While the desire to go further and open up a secondary market for annuities was restated recently, this has been delayed until 2017.
Joshua Peck is a Managing Director of MHP Corporate Affairs
With the more existential consultation now open though, this will be of little respite to an industry now faced with another period of potential upheaval. The pensions sector looks set to be in the news over the course of this parliament, and one area in which an ambitious Chancellor is keen to leave his mark.
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