APPENDIX 58
Response to the Department for Work and
Pensions' Green Paper and the Inland Revenue Review by INVESCO
(PEN 72)
SUMMARY
The key to encouraging individuals to save who
do not presently do so is to educate them on the importance of
saving for retirement, throughout their life. Pension providers
and employers must take responsibility for this alongside government.
Rather than focus on narrow objectives, such as ensuring all savers
have a yearly snapshot of their likely pension entitlements, it
is important that they are provided with a broad range of tools
and information which allow them to make informed investment,
savings and spending decisions, at any time. INVESCO already has
a working model in the United States of a system which assists
and encourages employees to take stock of all their savings, income
and expenditure and helps them to plan financially at every life
stage. Such a model could prove a valuable contribution to the
Government's stated aim of increasing uptake of pensions and long-term
savings and it is INVESCO's recommendation that such a methodology
be further researched for application in the UK.
INVESCO applauds attempts to make pensions simple
and attractive for savers. Broadly, it welcomes the moves in this
direction in both the Green Paper Simplicity, Security and
Choice and in the Inland Revenue paper Simplifying the Taxation
of Pensions.
However, INVESCO feels that while changes to the
taxation regime around pensions and simplification thereof are
very beneficial, and will be attractive to investors who are already
pensions aware, they will not of themselves reach those individuals
for whom saving for retirement is not yet a habit.
INVESCO firmly believes that the key to encouraging
those individuals who have not made appropriate provision for
their retirement to do so is education. Here, a genuine partnership
between government, employers and providers is required to ensure
that savers are equipped to make financial decisions from an early
age, and that a level of education appropriate to the consumer
is maintained throughout their life.
In the first instance, a basic level of financial
education clearly needs to be provided through the secondary and
tertiary education systems, so that long-term saving and financial
planning are not perceived as something with which to be concerned
in middle age alone.
Beyond this point, after savers begin their
working life, INVESCO considers that it is equally beholden upon
government, employers and pension providers to equip savers with
the tools to help them make long and short term savings decisions.
It is apparent that the workplace will increasingly become the
conduit for communication of financial information and advice,
and INVESCO believes it therefore makes sense that employers and
their pension providers take more responsibility for educating
their employees and customers respectively.
The Green Paper's proposals for improving consumer
understanding of pensions and financial planning are commendable
but are at this early stage relatively basic. Simplifying the
pensions framework, improving the number of people receiving pension
forecasts and providing further telephone and internet information
services are an encouraging start. However, there is a more proactive
role that employers and pension providers can play to ensure that
employees have access to complete information on an ongoing basis
and not just at the point of their annual forecast.
INVESCO itself, for instance, operates an effective
and sophisticated retirement savings tool in the United States,
which helps to guide users through their savings and spending
life choices, aiding them in analysing their long-term and short-term
goals as well as their own saving and spending history. Users
are assisted in establishing their financial goals and building
an understanding of the many factors which will impact on their
quality of life, both in the near future and in retirement. Either
by themselves through the internet or with the assistance of an
advisor, the tool acts as an entry point into the concept of long
term savings and pensions specifically, while also educating on
the basics of savings more generally. It helps users to make better
informed choices and helps to take some of the mystery out of
making financial decisions. This methodology, proven in the United
States, goes much further in terms of employee education than
the basic communication packages used in the UK.
There are currently two constraints that would
need to be addressed in order to enable this retirement planning
tool to be implemented in the UK.
Firstly, for such a tool to be effective
in achieving the government's objectives to increase retirement
savings, it would need to be able to provide information to the
individual in terms which may currently be deemed to be "advice".
Current regulation does not permit this approach.
Secondly, provision of this retirement
planning tool would need to be paid for separately by employers
outwith the 1% cap. This could be paid for by employers or as
an additional charge on the policy.
INVESCO's proposal focuses on a practical way
of getting information and advice on pensions to employees, who
may not be prepared to pay fees to advisers, through a partnership
between employers and pension providers. Educating and motivating
employees in this way clearly carries a cost, but INVESCO's experience
is that the benefit is that people who are educated about the
importance of financial planning generally, and saving for retirement
more specifically, then become more motivated to make and implement
decisions. INVESCO believes that these principles could be adopted
by the Government in its own attempts to boost the savings level
in the UK. Should the Committee be further interested in this
practical example of how pension providers education could be
taken on in part by the pension provider sector, INVESCO would
be delighted to arrange a presentation.
Mr David Butcher
Chief Executive
8 January 2003
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