Making Sense of Pensions

Shola Salako

Member Communication

Communication is never easy, even when what is to be communicated is simple.

There are many ways we manage to say the wrong things at the wrong time to the wrong people.

Imagine then trying to tell people about pensions.

There’s an argument that the Industry itself has led the way in the confusion.

Members ask simple questions, such as,

What do I get when I retire?

Why should I be in a Pension Scheme?

These are simple questions with complicated answers.   Who is answering these questions?

We have helpdesks, sometimes backlog and labyrinth style automated systems which do not help.

We forget people are driven by their emotions so will make decisions based on how they feel.

How do we communicate effectively & efficiently?

We need to build relationships with our members, to enable us to understand their views regarding this valuable benefit and make it easier for them to trust us.

Member nominated trustees know the members and are a useful way of keeping in touch with Trustees. Are we using member nominated trustees to their full potential?

We should consider other ways to build relationships with members. This in a world increasingly made up of deferred and pensioner members with limited engagement from the employer.

Why answer one question at a time when you can answer a thousand?

Trustees might consider making a video of them speaking about the scheme.

Have a weekly or monthly blog, a podcast, so there’s no vacuum, monitor websites visits, web forums, emails etc.as more use is made of social media.

Tell stories, there are many stories from the industry. The stories can show case how pensions and lifetime savings touch the lives of ordinary people.  Introduce personalities; tell stories of how pensions has changed people’s lives.

Lets think like a newsroom.   What are people talking about then look at it through the mirror of our industry.

Even if we say just a little, or that we will report back on a trending news item. We will update you later; it’s around using language that builds trust.  Such language allows us as Trustees to get closer to our members.  It sets the tone that we are part of a partnership.

Instead of saying “we assist”, “we notify”, “we consider”, let’s say, “we help” “we tell”, “we think carefully”.   Seek to use language that combines empathy with trust.

Communication is never easy, however we as an industry can work on making it simple.

David Davison

In June 2018 the Scottish Local Government Pension Scheme Advisory Board launched a consultation on the future structure of the Scottish LGPS. The Board’s consultation sets out four options for the future structure of pension funds in Scotland. The review provides excellent background for all LGPS in the UK as the range of scheme sizes provides a microcosm in which to review the options presented more widely.

There are 11 Scottish Funds with total assets of around £42Bn and liabilities of about £55Bn. Scheme sizes range from the largest, Strathclyde Pension Fund, with around £20Bn of assets and 210,000 members to the smallest, Orkney Islands, with only £335m of assets and just over 3,600 members. The four options being explored along with the key considerations are shown below.

  1. Retain the existing structure

Retaining the status quo is likely to mean that inefficiencies will remain as most funds will not achieve the benefits of scale such as improved bargaining power, access to greater resources and reduced duplication of efforts in administration, governance, spending on advisers and fund management. Larger funds are also likely to be able to better access infrastructure investments. Maintain the existing approach is therefore likely to mean that costs per member are likely to be higher than necessary.

A potential negative would be the loss of local input and oversight and the regional diversification of resource such as staff as it may be difficult to access specialist staff in a single location. However the existing structure does potentially also create a key person risk as there is less available resource to cover key roles as well as budgetary and staff risk due to other competing local priorities..

Clearly any savings made or improvements achieved would need to outweigh any initial transition costs but all research to date would tend to support a move away from the status quo.

  1. Promote co-operation in investing and administration

There have already been some examples of collaboration particularly in the investment area and around procurement. This approach would allow the current governance structure to continue, allowing for continued local oversight, although requiring some sharing of control. There would also have to be some adaptation of governance.

Approaches to date seem to have been relatively informal which results in a degree of uncertainty over their future persistence so a more formal structure may be of value to assist with planning as well as the distribution of costs and returns. To date this sort of co-operation has been pretty limited despite its obvious benefits which would suggest that without strong vision and direction it will remain  something of an outlier. I can’t help feeling that greater structure and compulsion is needed to really drive change.

  1. Pool investments

This option would see all assets pooled in one or more asset pools managed centrally on behalf of a number of Funds. Schemes would retain their governance, administration and back office functions and continue to appoint and manage their advisers. This is very similar to the approach currently being adopted in England and Wales.

A single pool would double the asset size to about £42Bn over the largest Fund which has assets of just under £20Bn. At this size it would be of a similar size to 3 of the English pools and larger than the 3 others.

Fund assets and liabilities would still be allocated in the same way to ensure specific employer responsibility for liabilities.

A move of this type would be likely to result in lower cost investing though subject to some initial cost increases to manage a transition. It would also be likely to mean that the asset pool was of a significant enough size that more of the investment and administrative tasks could be undertaken in house.

From a governance perspective each Pension Committee would retain responsibility for asset allocation and managing the legislative structure however day to day investment management would be delegated to the pool. Each Fund would also maintain its Pension Board.

As has been shown in England and Wales this approach is very achievable and its hard to deny the value so would seem to be a minimum required step.

  1. Merge funds in to one or more funds

This option would see the creation of a Scottish ‘superfund’ which would manage all LGPS benefits in Scotland. Such a move would benefit from the asset pooling advantage s in 3 above but also allow for merging of the administrative and governance functions.

Such a move, whilst ultimately desirable from a cost and consistency perspective is not without its challenges. Each of the Schemes is funded at a different level and there would have to be a recognition of this and a mechanism to resolve it to ensure there was not a cross subsidy between different regions and even potentially employers. There would also have to be clarity in terms of governance, priorities and costs. There are also political drivers as well as a need to ensure that the right level of resource is available to the new consolidated scheme.

None of these challenges however are insurmountable and really just need commitment to achieve the objective and a clear plan to do so over a reasonable timescale.

The Funds all provide consistent benefits based upon a single regulatory framework. Consolidation would remove regional variations and inconsistency. Legacy arrangements would have to be clearly documented and honoured but future practice could be implemented on a wholly fair and consistent basis. Undoubtedly given the size distribution of schemes in Scotland a number of them would be likely to benefit from cost savings and improved governance very quickly. Market buying power in terms of services would be improved and greater investment possible in staff, technology and scheme communications.

Conclusion

Research carried out by Deloitte in 2011 suggested that costs per member in Scotland compared favourably with funds in England and Wales and that a single operating model and common administration system may have a greater benefit than formal administration mergers though research by APG concluded that administration costs decline with larger funds and certainly this seems to be the model being employed across UK defined contribution businesses.

It also needs to be considered that the number of employers participating in LGPS in Scotland is falling so less resources are needed and greater consistency of practice can be achieved. In addition with greater employer consolidation there will undoubtedly be increased demand for larger employers to have all benefits consolidated in a single fund rather than across multiple schemes.

In addition the benefits of having a single scheme which is not accountable to a local authority and can operate in an autonomous way based on its agreed priorities should provide greater flexibility in staff terms and conditions and therefore provide the opportunity to attract a much higher calibre of staff.

There are clear benefits which can be achieved through investment pooling and even further benefits through a consolidated single scheme for Scotland – it just needs vision and commitment to achieve them.

Hugh Nolan

The Pension Regulator’s Powers

Something must be done! So says the work and Pensions Select Committee chaired by Frank Field MP in the wake of high profile cases like Carillion and BHS. Knee jerk reactions in Parliament rarely lead to the best laws and I suspect that this habitual problem will only be exacerbated with laws made while everyone is distracted by Brexit. What are the chances of the Government actually improving the pension’s landscape?

Well, firstly, there are some changes that can be made which are at least harmless in principle and may even do some good. It’s hard to find a compelling reason to argue against strengthening penalties for wilful or grossly reckless behaviour by trustees and employers, for example. On the other hand it’s only ever been a tiny minority of schemes that have suffered from such behaviour so it’s unlikely that making it a criminal offence will improve things much. There’s also the likely unintended consequence that some diligent trustees will be prompted to err too much on the side of caution rather than run any risk at all of being accused of recklessness.

The problem is that the Select Committee is extrapolating to the wrong conclusion. The Pensions Regulator had been involved with Carillion before it collapsed, but had still not managed to avoid the current problems arising for its pension schemes. The dilemma was though that Carillion was already struggling and the Trustees and the Regulator were in an invidious position. They could have encouraged (or even tried to force) the employer to pay higher contributions at the expense of dividends. If so, that could well have driven investors away and led to a collapse sooner. With the benefit of hindsight the Committee is convinced that the decisions made were wrong, but who really knows what would have happened otherwise. In any event, the problems at Carillion were with the company itself and the pension scheme was just collateral damage. Companies will always be at the risk of going bust and it’s unrealistic to insist on full solvency funding for every scheme at all times just in case it happens to be one of the unlucky ones. Perhaps we just need to be honest about the fact that sometimes bad things happen and it’s not always possible to completely protect people.

Secondly, I happen to have liked the practical way that the Regulator worked in the good old days. They encouraged trustees to do the right thing and explained when they were getting it wrong, only using their formal powers as a last resort. Sometimes they got it wrong but mostly the Regulator found a good balance in a difficult area. Now that something “must be done”, the Regulator has used its enforcement powers in 22% more cases in the second quarter of 2018 than in the first quarter. Have there really been 8,000 more cases where the Regulator needed to step in or are we just seeing a reaction to the unfair criticism for past performance?

Finally, there is definitely a bright side. The Regulator has historically been slightly nervous about using some of its existing powers even when they are clearly justified, possibly due to a fear of being over-ruled later. In the latest quarterly report, the Regulator has used its information gathering powers 31 times, taken action against 25 schemes for failing to submit an annual return and appointed 162 trustees to protect member benefits. The Regulator also exercised powers for the first time ever under the Proceeds of Crime Act 2002, Section 10 of the Pensions Act 1995 and the Computer Misuse Act 1990 (which by my reckoning has been in force for 28 years so far). That certainly seems to support the claim that the Regulator already had more powers if it wanted to use them!

In particular, the Section 10 fine of £25,000 for the Trustees who had failed to produce two actuarial valuations is a welcome wake-up call to the handful of trustees and employers who behave badly. However, I still hope (and expect) that the Regulator will limit the toughest stance to those that deserve it and continue to support hard-working and dedicated trustees to do their best – without leaving them terrified of being sent to jail or the poor house if they ever make an honest mistake or things go wrong for their scheme.

David Davison

If you’re one of the lucky admitted bodies who benefit from a council or other guarantee for your LGPS membership then this is likely to mean that you are currently disclosing a much more negative position on your balance sheet than actually should be the case.

In most cases transferee admitted bodies, and community admission bodies with guarantees, benefit from preferential exit terms should they leave the Fund, with the debt payable on exit calculated on an on-going basis (as per that used to calculate Fund contributions) rather than the more stringent cessation basis. This is good news of course as it means the likelihood of having a large debt on exit is much lower.

However, there is no correlation between the assumptions used in the calculation of the on-going funding position and those used when compiling the FRS 102 disclosures for company accounts. Under FRS 102 the discount rate must be set in line with the yield available on high quality corporate bonds. At the moment, corporate bond yields are low and so the discount rate used in the FRS 102 calculations is likely to be much lower than that used for the on-going funding basis, resulting in higher liabilities and a much larger deficit (all other things being equal), which therefore reduces balance sheet value.

I recently witnessed an example of this where, on an on-going basis, the organisation was in surplus but on the FRS 102 basis the organisation had a £100,000 deficit. The organisation had a guarantor and so was able to exit the Fund at any point paying off any on-going funding deficit (which in this case was nil). The FRS 102 deficit cannot be correct in this case as the worst case scenario is the on-going position. This meant that the charities balance sheet was £100,000 worse than it should have been, which, for the charity in question, was very material.

A further difficulty from a disclosure perspective are the recent changes to UK wide LGPS Regulation which now permit the return of surplus on exit from schemes. To date where a surplus has existed this has been discounted and a net neutral position assumed as any surplus could not be recovered. This however is no longer the case and the position will vary depending upon whether the organisation has a guarantee and whether their ultimate exit position is based upon an on-going or cessation position.

The disclosure position has therefore become much more complex and employers need to be considering their position well in advance of their company year end to leave enough time to take any remedial steps necessary. So if you have a guarantee or are very well funded on your exit basis, discuss this with your auditor. It may be possible to add a note to the accounts to provide greater clarity or better still, update your accounts with disclosures on a basis more consistent with the value of the liabilities actually owned.

Ciaran Harris

Trustees and sponsors of defined benefit (“DB”) schemes could be forgiven for assuming that the only way was up for life expectancies of their scheme members. For decades, mortality rates had been significantly improving. In the context of DB schemes, this generally resulted in more costly benefit provision for sponsoring employers.

The Continuous Mortality Investigation (“CMI”) then introduced their 2016 mortality improvement tables which showed a slow down in mortality improvements and therefore a reduction in life expectancy in comparison to previous years. Was this a blip? The 2017 tables have shown the same slow down. Perhaps one of the biggest indicators that this is the ‘new norm’ is the PPF consulting to revise their s143/s179 guidance to reflect updated mortality assumptions.

In relation to DB pension schemes, what might this affect?

  1. If insurers adopt the most up to date assumptions for mortality, then the cost of insuring benefits is likely to reduce. It may be a good time for sponsoring employers to consider this option if they are already close to being able to secure benefits.
  2. The size of cash equivalent transfer values will fall if calculations are updated to reflect new mortality assumptions. Anyone considering a transfer or within a guarantee period may want to consider this.
  3. The size of the scheme’s technical provisions will likely fall if the trustees decide to adopt the most up to date mortality assumptions in the scheme’s triennial valuation.
  4. Accounting deficits may reduce.

In terms of potential impact, the life expectancy of a 65 year old male based on the CMI 2014 improvement tables is around 22.9 years. Fast forward to the CMI 2017 model and the corresponding male life expectancy has fallen by 3.5% (with a similar reduction for females). The changes are even more pronounced when considering life expectancies for individuals not reaching 65 for 20 years which fall by around 5% – 6%. The impact on liabilities is a reduction of around 3% – 8%.

Trustees should consider if triennial valuations should reflect the most up to date tables and therefore a reduction in life expectancy. This will reduce liabilities all other things being equal.

Employers should consider the impact on insurer company pricing, accounting disclosures and transfer value exercises and should speak to an advisor to ensure optimum timing for any transactions or employer sponsored exercises.

Vineet Sood

Following the Competition & Markets Authority (‘CMA’) review of the Investment Consultancy Market, on 18 July 2018, it has provisionally proposed some changes that it believes will improve competition and help trustees gain more information to make more informed choices, and get a better deal from investment consultancy and fiduciary management services.

The CMA has proposed the following key changes, which has consulted on before making any final decisions:

  • Mandatory tendering for moving into fiduciary management. For those who already have it, but did not tender, they must also do so within five years.
  • Mandatory warnings when selling fiduciary management.
  • The Pensions Regulator to provide new and improved guidance for pension schemes when tendering for investment consulting or fiduciary management services.
  • Better information on fees (for fiduciary management only) and standardised performance reporting (both advisory and fiduciary management).
  • Trustees will be required to set their investment consultant strategic objectives and firms must report against these.
  • Regulation of investment consulting and fiduciary management services by the FCA.

These changes are a good way to encourage more competition and ensure that trustees have access to better information when making choices.

In particular, the mandatory requirement for a tender of fiduciary management services will reduce the competitive advantage that investment consultancies have. They will also need to provide explicit warnings that they are marketing their own fiduciary offering, and that others are available.

The unintended consequence of this regulation maybe that investment consultancies with a fiduciary management service will be reluctant to offer fiduciary management services, if there is a risk of losing the client, given the significant set up costs incurred when onboarding a client. However, this should encourage these firms to improve the quality of their service in order to ensure they have the best chance of retaining clients that consider fiduciary management.

Those firms that already provide fiduciary manager reviews are at an advantage as they have expertise to scale up this side of the business, but those not previously involved may consider this as an opportunity for adding new services.

From a trustee’s perspective, it should help to give them a better understanding of the fiduciary management market in order to make a more informed decision when choosing a fiduciary manager. However, the cost of running such an exercise can be expensive and at the moment and there are only a handful of firms that offer a review of fiduciary managers. Therefore, it may prove challenging for some schemes that have a limited budget. The CMA should consider this before any details are made final as it could force some schemes to rule out fiduciary management altogether, on the grounds of cost of conducting a review of different providers, even if it could be the best option for them.

Greater guidance from The Pensions Regulator is welcomed to help trustees make more informed decisions when tendering for investment or fiduciary management services. We believe that this will be helpful to trustees in getting the most out of the tender process, especially for smaller schemes who may have limited experience of running such exercises.

Our view on better transparency on fees charged by fiduciary managers is that, it will help trustees understand what they are paying for to assess value for money but also could allow comparison between different providers to be easier. This could form a good basis of negotiation for trustees. The requirement to standardise reporting of performance should help trustees to make easier comparisons of consultancies and fiduciary managers.

The requirement for trustees to set objectives for investment consultants will mean there is a measureable approach when assessing the performance of the investment services that are provided. This now gives trustees a good way to assess the performance of their investment advisor to see if they are doing a good job, and potentially makes it easier to make comparisons between advisers. The Pensions Regulator will have responsibility for setting guidance on objective setting and we are supportive of this, to encourage investment consultants to improve the quality of the services they provide.

The CMA consultation on these proposals closed on 24 August 2018 and the deadline for its final report is 13 March 2019.

Overall, we are supportive of the CMA’s drive to increase competition as well as increasing the level of transparency among investment consultants and fiduciary managers, in order to provide pension schemes with better outcomes. However, this will need to balanced with a sensible approach and avoid any unintended consequences for pension schemes.

 

 

Angela Burns

Liability management

 

 

Employers have chosen to manage their defined benefit pension liabilities using liability management exercises for a number if years now but these exercises have recently been given a fresh impetus through the introduction of pension freedoms which has given individuals much more flexibility in how to take their benefits from Defined Contribution schemes.

Below is a transcript from the video above.

Liability management exercises involve offering defined benefit pension scheme members various options in relation to their pension benefits.  These options include:

  • Transferring benefits to an alternative defined contribution arrangement;
  • Taking benefits as a cash lump sum, subject to regulatory limits;
  • Changing how pensions increase in payment.

The sponsor objective in conducting a liability management exercise is two-fold:

  1. Discharging liabilities via transfer values and lump sums is often less costly than the ‘on-going’ cost of providing benefits, or the cost of securing benefits with an insurer – therefore the cost of providing benefits is reduced on exercise of these options. Risk is also reduced if pension increases are swapped for a higher initial pension;
  2. Providing members with a greater choice over how they take their retirement income all carried out in a controlled environment. Individuals can choose options that best suit their needs (see my previous blog on what drives people to transfer for some issues that individuals may consider).

A liability management exercise, if run correctly, can therefore be a win-win for both the employer and scheme members.

So if you are an employer and you are considering providing your membership with OPTIONS – what do you need to think about?

Outlay

Can you afford to incentivise the options available to improve attractiveness and aid take up?  Consider the cost of the exercise and whether or not you can afford this.  If it’s unaffordable at this time can you implement ‘business as usual’ practices to get a similar result over a period of time? For example providing transfer value statements along with retirement packs, or writing to members to remind them of their options?

Possible impact

An initial feasibility study helps to identify the potential impact, the cost of enhancements (if these are affordable) and any concentrated liabilities.  It is useful to carry this out prior to implementation.

Target membership

Using the results of the feasibility study you can target your exercise to ensure the maximum cost/benefit ratio.

Independent advice

If you are offering incentives then you must provide members with Independent Financial Advice (paid for by the employer).  There are a very limited number of IFA’s with the qualifications and authorisations to conduct this very specialist advice so ensure you choose an IFA that has the relevant experience.  Initial screening can help control costs as only those individuals who would be suitable to receive full advice with the associated costs would make it through the screening process.

Operation

Ensure you appoint an advisor with a strong track record of project managing successful liability management exercises.  Advising multiple individuals over a relatively short timescale is a complex process and it must be managed by an experienced professional.

Needs of membership

Consider the needs of your membership throughout the process – what will get them engaged in the exercise?  Are written communications enough or will access to a website, specific member presentations and a dedicated hotline aid engagement and understanding?

Sound communications

Ensure that all communications are engaging and jargon free.  Defined Benefit pensions are complex and it is important that individuals understand the options that are being made available to them and their implications.

This area is very highly regulated by the FCA and tPR has provided useful guidance which needs to be followed to compliantly conduct any exercise.

Angela Burns

There have been huge increases in the numbers of individuals taking transfer values from their defined benefit pension schemes over recent years. This has been driven by numerous factors, one of which being all time low interest rates, giving us record high transfer values. Individuals have been seeing multiples upwards of 30 times pension in many cases, which when added to the increased flexibility now available, is proving a mixture all too difficult to resist.

With the Bank of England raising interest rates for only the second time in a decade (up 0.25% p.a. from 0.50% p.a. to 0.75% p.a.), having been stuck at 0.5% for over nine years, this change is likely to have an negative impact.

Gilt yields rising results in liabilities falling, all other things being equal, so we are likely to see a reduction in transfer values. At this stage the impact is likely to be relatively modest with a 0.25% p.a. increase in gilt yields reducing a £150,000 transfer for a 45 year old by about £10,000 and for a 60 year old by about £5,000.

Such a change means that the amount transferred needs to return a lot more to be able to match, or improve on the benefits offered by the scheme. This change is likely to see the investment return needed to match or improve on the benefits increase by around 0.5% p.a. for the 45 year old and by 1.0% p.a. for the 60 year old.

The investment return required in the period until retirement (also knows as the critical yield or in recent parlance ‘personalised discount rate’) is often seen as a benchmark which needs to be reached before an adviser can even consider if a wider discussion on transferring benefits is even possible. So lower transfer values, which result in higher critical yields, is likely to mean that fewer people reach the threshold and so many more stay with their existing scheme.

For employers incentivising staff to transfer through the use of enhanced transfer values, lower transfer values will mean that higher top-ups are required to reach an attractive level, placing a greater cash requirement on the employer and therefore making exercises less attractive. Alternatively, retaining the same top-up value may result in a lower take-up.

As the transfer value basis in some schemes may not react immediately to changes in gilt yields this may provide individuals with a short window of time before any changes are made. In addition, individuals who are currently within their transfer guarantee period may be keener to have their transfer value processed within the guarantee window, to ensure they take advantage of a higher value than would be likely to be available post the guarantee, given the gilt yields rise.

Further rate rises may be on the horizon. We don’t have a crystal ball to see what will happen in the future, however, current perceived wisdom seems to be that rates will slowly rise over time on the basis that they can’t possibly stay this low. However, this has been the general belief since around 2009! Some think we have entered a ‘new norm’ where rates are unlikely to rise materially.

Individuals and sponsors should take care when considering transfer values or transfer exercises as gilt yield increases can materially affect the ‘real’ monetary value of any transfer, with timing now increasingly important.

David Davison

In an earlier Bulletin ‘A Landmark Judgement’ I provided some information on the welcome news that the Government had thankfully lost a case in the High Court which would have forced LGPS Funds in England and Wales to invest their assets (£263Bn in 2017) in accordance with UK foreign and defence policy.

Unfortunately my relief that common sense had prevailed on this issue was misplaced as on 6 June the Court of Appeal overturned the High Court ruling forcing schemes to comply with government policy, all this despite numerous warnings from pension experts about the negative impact and increase in pension scheme costs such a decision could have.

This whole saga started back in 2016 with the Government introducing legal guidance as it was concerned pension schemes could be taking actions which might “give mixed messages abroad, undermine community cohesion in the UK, and could negatively impact on the UK defence industry.”

The policy was successfully challenged by the Palestine Solidarity Campaign and an individual scheme member in 2017 when the High Court ruled it unlawful.

The whole approach smacks of state intervention and interferes with the ability of pension schemes to take decisions wholly in the interests of the members of the scheme. The Appeal ruling also seems to contradict proposed policy to require trustees of pension funds with 100 or more members to show how they have considered environmental, social and governance factors in their investment decisions.

The Government has refuted that its objective is to make pension schemes invest in line with government policy and has commented that it is not seeking to direct schemes investment decisions but despite the assurances the legal position seems to contradict this view.

It’s hard to see how the ruling won’t lead to schemes having to review policy resulting in increased complexity and additional costs which will be wholly unwelcome and not adding any value to scheme members.

Watch this space!

Andrew Kerrin

“Time flies like an arrow – but fruit flies like a banana.” Just a personal favourite line (often attributed to Groucho Marx) that popped into my mind when sitting down to introduce Spence & Partners latest Quarterly Update. It seems like only last week that I was searching for words to introduce our first report of 2018!

Having taken aim at the topics that hit the headlines over the last quarter, marking with an arrow those of most interest, we have fired them into a neat summary for your consideration. We hope you enjoy reading this compilation, that it helps you pass the time, and who knows, might help you avoid a banana skin or two.

This quarter we have a wide variety of tasty morsels for you to digest, including a summary of the potentially far-reaching opinion from the Advocate General in Hampshire v PPF, a discussion of the main cyber security issues for trustees coming from the Regulator’s recent practice note, to a bite-sized rundown of the key legislative changes that hit the pensions industry back in April.

Enjoy your latest Quarterly Update – I hope you agree that our selection has hit the bullseye and our efforts have been fruitful!

To download this report click here or on the image above.

As always we love to get feedback from you. If you like what we do please tell us – it’s nice to get great feedback. If you would like things included, excluded or done differently please drop us a line too. The report is to help you, so help us tailor it to your needs.

And … if you find that you do have time to keep up with things, why not follow us on Twitter @SpencePartners and keep up to date as you go along.

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