In its response, the SPP highlighted the following three areas needing improvement in the proposed rules, primarily focused on the establishment of a Dashboards Available Point.
Dashboards Available Point (DAP)
• The industry should be made aware of an “anticipated DAP” at least 12 months in advance, so that actions can be taken to ensure the industry (whether dashboard providers or pension providers) is ready.
• Provided 12 months’ notice is given, our strong preference is for at least 6 months to be given on final confirmation, to ensure final arrangements can be made. If this is not provided, there is the risk members will be affected as services (such as processing of death claims and bereavement cases) are disrupted. Delivery of pensions dashboards could also risk being ragged and deemed chaotic, which would be contrary to the policy intention.
• We expect widespread announcement of the anticipated DAP, so all providers are aware of the date to ensure a level playing field for all parts of the industry.
Incremental DAPs
• It is crucial that any incremental DAP approach avoids being costly, complex or potentially counter-productive. We think this could be achieved if access was linked to an essential data item – the individual’s date of birth – and operated by the central Pensions Finder Service.
• Incremental DAPs may be very helpful for all parties. From an administrator and dashboard provider perspective, staging access to dashboards, perhaps by age of the individual, would allow dashboards to be launched to the public in a manageable way for providers. If millions of savers have access from the same day that could create very large spikes in demand.
• We do not envisage the timing of incremental DAPs needing to take a long time. New member groups could be given access 2-4 weeks apart, over a period of perhaps 3-6 months.
• We encourage the DWP to include provision for incremental DAPs in the next draft regulations, so such an approach is possible, even if a single DAP is eventually chosen.
DAP and Qualifying Pensions Dashboard Services (QPDS)
• To ensure fairness, there should be an equal opportunity for providers who wish to be a QPDS to have received authorisation ahead of the DAP. Therefore, the DWP and FCA must work together to agree the DAP. To ensure no providers are given unfair advantage over others, the DWP should confirm their timescales for DAP and the FCA confirm publicly that applications received before ‘X date’ will be concluded prior to the DAP.
Mark Bondi, Chair of the Legislation Committee at the Society of Pension Professionals, said: “The Society of Pension Professionals remains very supportive of the pensions dashboard. However, getting the Dashboards Available Point right will be central to the final, orderly rollout of dashboards to pension savers.
“The pensions industry needs at least 12 months’ advance notice of an anticipated Dashboards Available Point, to ensure the industry is in the final state of preparedness for an effective rollout, while incremental rollouts to different groups of pensions savers may make the administration of this key moment more manageable. As an industry, we will continue to work with regulators to finesse these final staging details, and ultimately deliver the successful rollout of the dashboards project.”
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