The Association of Consulting Actuaries (ACA) has published responses to the Government’s “Review of the Default Fund Charge Cap and Standardised Cost Disclosure: Call for Evidence” and the FCA’s Consultation on Driving Value for Money in Pensions. |
ACA Chair, Patrick Bloomfield commented: “The ACA wholly supports pension savers receiving good value. But the charge cap is a blunt tool that doesn’t deliver value for members in isolation. Instead, DC governance standards must continue improving, focussing on value rather than just cost.” Chair of the ACA’s DC Committee, Tess Page, added: “The two consultations covered overlapping issues across different types of DC pension scheme, reflecting the differing regulatory regimes in place. However, trust-based and contract-based plans must be equally capable of delivering value for members. Greater consistency is needed in the approach to Value for Members assessments across the board, in order that all members benefit, regardless of their scheme design. At this stage, we do not see sufficient evidence to support better member outcomes being achieved through a charge cap on transaction costs. Focusing governance time and energy on improving the quality of DC arrangements more broadly must be prioritised. Linked to this point, whilst investment returns are one aspect of performance and can contribute to delivering the “quality” elements required for good value schemes, it is important to consider risk-adjusted outcomes and other performance factors, notably administration and the member experience. Furthermore, preventing the erosion of small pots can be more efficiently achieved by requiring pot consolidation than regulating on charging structures.
The market is also evolving as master trusts and other consolidation options emerge and mature. Consolidation can be a very positive step to drive value, provided it is underpinned by strong governance and a “member first” philosophy.” |
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