Under current plans, all dashboard providers will be required to present member data in a standardised way with strict restrictions on ‘manipulating’ the basic data or presenting the data in a different way. Depending on the final design standards, this could inhibit ‘added value’ services such as modelling the impact on retirement income of extra contributions or working for longer.
DWP say explicitly in their consultation:
“Our aspiration is that restricting the way in which view data can be presented and manipulated on dashboards will help to build trust and confidence in the information shown” (Chapter 1, para 25)
However, it is envisaged that users will be able to ‘export’ their data so that it can be used on other sites. DWP go on to say:
“However, [qualifying dashboards] are not prevented from offering people the ability to export their data away from the dashboard, either to another page within the [dashboard] provider’s system, or beyond” (Chapter 1, para 26)
LCP have warned that this extremely cautious approach could simply result in users taking their data to somewhere much less regulated where the risk of scams or poor decisions would be increased. LCP argue that it would be better to have ‘fully interactive’ dashboards to support users in thinking through their options rather than ‘dumb dashboards’ with consumers being exposed to less tightly controlled interactions on other sites. Given that being a dashboard provider will be an FCA-regulated activity, regulators have more ability to protect consumers against bad practice if consumers stay on the dashboard site than if they are driven off the dashboard by lack of functionality.
Other points raised by LCP in their consultation response include:
The risk of a ‘dash for cash’ as pension businesses seek to use dashboards to harvest dormant pension assets on the basis of heavy marketing and investment in technology, potentially at the expense of low costs and/or good investment returns;
The dangers of a ‘big bang’ launch of dashboards when the entire working age population could become eligible to log on to dashboards on a single day; not only could this cause website and IT problems, but it risks swamping pension schemes and sponsors with queries and request for transfers, leaving scheme members frustrated and dissatisfied;
The lack of available ‘Integrated Service Providers’ (ISPs) for schemes to choose from at present; pension schemes are being encouraged to plan ahead for dashboards and a key decision will be whether to connect directly or via a third party service (an ISP); yet the ISP market barely exists at present, with only one active participant working with the Pensions Dashboards Programme; LCP calls for urgency in getting this market developed so that schemes can make the connection decision that is right for them.
Commenting, Steve Webb, partner at LCP said: “The desire to protect consumers is understandable, but if this results in ‘dumb dashboards’ then this could do more harm than good. Simply seeing all your pensions in one place is the start of a journey not the end. If dashboards themselves are severely restricted in the support and services they can offer, consumers will simply take their data elsewhere, almost certainly to a less regulated environment. The best antidote to scammers and poor choices is to provide more help and guidance within the dashboard environment, rather than to drive people off”.
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