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Should you consolidate old pension plans?

Photo of Mark Meldon, Independent Financial Advisor

The following guest post is by Mark Meldon, an independent financial advisor. Occasionally Mark volunteers to explain an obscure corner of personal finance.

Now seems an opportune time to return to a long-standing bugbear of mine, the £250bn of pension pots languishing in what are known as ‘Zombie’ life offices.

That’s because the Financial Conduct Authority (FCA) released a number of interesting papers back in July. These were mainly concerned with the thorny issues of defined benefit transfers and how pension funds should be invested, but one looking at non-workplace pensions particularly caught my eye.

What is a ‘non-workplace’ pension?

I suppose I could say “something that a financial adviser flogged you when you were young”, but that isn’t entirely fair.

What we are talking about here are things like Stakeholder Pensions, Personal Pensions, SIPPs, and ancient (but very interesting) vehicles like Free-Standing AVCs, Section 32 Buy-Out Bonds, and Retirement Annuity Contracts.

These things came into being from 1956 in the case of retirement annuity contracts and 2001 as far as Stakeholder Pensions are concerned.

The numbers

According to the FCA data, an amazing £470bn is currently held in these obsolete policies; rather more than the £370bn held in all non-final salary company pension schemes!

Apparently, there are 12.7m of these policies – I like to call them ‘accounts’ – and the FCA paper confirms that 89% of these individual pensions are held by firms that are closed to new business. That’s nearly 70% of the total in these Zombie firms.

The FCA say that there are around 8m accounts worth £250bn in the hands of the Zombies.

Reasons to consolidate

I take the view that if you have an account like this it would be very sensible to consider your options. It is unlikely that these old plans will ever offer full digital access. They often have terrible service, and there is no competitive pressure to produce good investment returns in order to attract new business.

If you were, after suitable analysis, to transfer to a modern pension plan, you are likely to gain the following advantages:

  • Simplicity – always a good thing
  • Lower charges – nearly always
  • Better service – it’s true!
  • Enhanced flexibility – old plans rarely offer ‘flexi-access drawdown’ for example
  • A wider investment choice – including index funds

The FCA points out that older and smaller pots bear disproportionately higher charges – quelle surprise!

It is my experience that clients who do consolidate often gain a double benefit by doing so as they end up with one larger account held in a modern, lower-cost and better invested arrangement – and there really are some excellent choices for consumers out there nowadays.

Other benefits that can be gained by consolidating include the automatic re-balancing of your investment fund, surety regarding death benefit nomination forms, and the option to self-invest through a SIPP.

As the FCA says, clients who have consolidated – about half of those who did so shortly after the introductions of the Pension Freedoms in 2015 – did so to access features that were simply not available from their old account. Things like flexi-access drawdown, the uncrystallised funds pension lump sum, and the automatic phased payment of tax-free cash.

There is always a ‘but’

Although I’m rather bullish on the benefits of pension account consolidation, there are several important things to be carefully considered prior to your taking any action.

A good IFA can certainly add value here, as they can draw upon their experience with looking under the bonnet of old accounts – a slow, but fascinating (I know, it’s sad) exercise.

Exit penalties

The FCA says that exit penalties are becoming rare, with 84% of personal pensions having no such penalties.

For the rest, the FCA acted in 2017 which meant pension firms were no longer allowed to impose an exit charge of more than 1% on any contract-based defined contribution scheme.

If the exit charge happened to be less than 1% at the time, the charge could not be increased, either.

In October 2017, the Department of Work and Pensions extended the FCA exit charge regime to occupational defined contribution schemes.

So, exit charges are much less of a problem that they were before 2017, but they still need to be established.

Guaranteed pensions

This is much more interesting.

Back in the 1970s and 1980s, inflation and interest rates were much higher that they are today. Up until 2015, most people bought an annuity with their pension account after drawing their tax-free cash – many sensibly still do – and the rate they got was determined by the prevailing yield on 15-year government stock and the longevity statistics.

Thus annuity rates were, nominally at least, higher than they are today.

As a marketing gimmick designed to attract new business, many life insurance companies also offered a minimum level of income based on your age when you drew your benefit – a so-called ‘guaranteed annuity rate’ (GAR).

At the time, these were at below market rates and were seen as a kind of insurance. (Don’t ask former Equitable Life account holders about this, by the way, as you might get your head bitten off!)

Then the Great Financial Crisis of 2008 happened and one significant consequence of this was the collapse in annuity rates, making those old “they’ll never use them, anyway” GARs suddenly very attractive and expensive for the life offices to honour. (The FCA has insisted on adequate reserves).

Earlier this year, I helped a 60-year-old plumber from Wiltshire set up a GAR he had with Scottish Widows. His £98,500 fund is paying him £6,900 per annum, in monthly installments, fixed for the rest of his life. That’s equivalent to a rate of about 7%, nearly double what he would have obtained on today’s open market.

Good for him, bad for Scottish Widows.

I have often seen GARs of 10%, which is around twice the going rate for a healthy person today. I recall that the highest I have seen was 16% at age 60 from an old Equity & Law executive pension plan.

Marvelous – or is it?

The big downside is that many GARs are inflexible – they might only apply annually in arrears, for example. They might not be able to include a spouse’s pension – which was why life insurance was nearly always arranged at the same time as a retirement annuity all those years ago – and they will generally be fixed in payment.

Often, it’s use it or lose it, too. If you don’t take you GAR on your 65th birthday, for instance, it’s gone.

So, using the GAR isn’t always the right choice. It very much depends on your circumstances.

It is, however, potentially a very valuable thing, a GAR, and it should not be given up lightly. Yet recent FCA figures show that something like three in five of over-55s are not taking up the GAR from their pension account.

There are all sorts of reasons for this, I suspect, but two-thirds of these people merely cash out.

Anecdotally, many people have cashed out and put the money in their bank. Why would you abandon the tax-exempt pension wrapper like this?

Protected tax-free cash

This is, perhaps, an odd one, but is something I have come across quite often, particularly for those individuals who were in defined contribution occupational schemes in the past.

If you built up benefits before 2006 you might be entitled to a tax-free cash lump sum above the normal 25%. The highest I have dealt with was 83%!

In most cases, if you transfer to a new account, this ‘protected’ tax-free cash will be lost, unless you have somehow managed to ‘buddy up’ with someone and are able to undertake a ‘block transfer’.

Block transfers are hard to do – I have never done one – and don’t apply to accounts like S32 Buy-Out arrangements. HMRC and the FCA need to simplify this.

Choices

If you have old pension accounts, dust them off and review them. For most people who are employed, it’s worth looking at your Workplace Pension first as these usually have very low charges and the process of consolidation is straightforward and inexpensive.

Otherwise, you might like to chat to an IFA about your options. These are either a decent modern personal pension from a life office or, if you fancy being rather more involved with your pension account, a SIPP.

To conclude: A case study

Earlier this year, I met with a lady who had set up a personal pension in 1997 with what was then called Skandia Life, into which a regular payment of £100 was being paid.

The fund, invested in a range of higher-risk actively managed funds, had accumulated to just under £74,000 on contributions of about £35,500.

Not too bad, but there was a problem in that the old account was costing an eye-watering 2.16% per annum in charges – excluding the 2.5% of each contribution still being paid in commission to the original adviser.

I recommended de-risking the way in which her account should be invested – as the time until her retirement was quite short – and that the fund be moved to a modern Pension Portfolio plan with the excellent Royal London.

The new plan is invested in a Flexible Lifestyle Strategy, and has a management charge of just 0.45% – a huge saving on before. The new plan offers all the flexibility she needs going forward, unlike the old one.

The cost to change was modest at about £1,000, and this agreed fee, to cover my time and research and establishment costs, was deducted from her tax-exempt pension fund.

The automatic rebalancing and portfolio adjustment undertaken by Royal London periodically should prove helpful, too, and Royal London’s expense deductions drop if the fund grows.

Mark Meldon is an Independent Financial Advisor based in Cheddar, Somerset. If you need an IFA closer to home, try the directory at Unbiased. You can also read Mark’s other articles on Monevator.

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Weekend reading logo

What caught my eye this week.

Josh Brown at The Reformed Broker offered a fresh take this week on what long ago became a hoary debate: the alleged existence of a ‘bubble’ in passive investing.

We’ve covered this ground before, of course, from the misunderstandings in how index funds operate to the impossibility of passive investing distorting prices in a zero-sum game – let alone of active funds in aggregate exploiting any (mostly non-existent) opportunities so created.

Josh now adds that rather than a newfangled mania that’s threatening global capitalism, passive investing is actually what we used to just call ‘investing’ before the 1980s made Wall Street and The City (sort of) sexy:

The popularity of passive investing isn’t new at all, it’s a throwback to the days of people focusing on their own work and careers, not trying to pick managers and become part-time market speculators.

You can never have a bubble in humility, apathy and passivity, which had always been the status quo up until the ’87-’07 period and is the more natural posture for investors to adopt for the future.

I agree. Indeed I’ve mildly argued with my co-blogger over the years when he’s slipped in a reference to alternative – yet still sleepy – strategies such as investing in mainstream global active funds or UK equity income funds for dividends as dangerous or destined to leave you eating baked beans in retirement.

In reality those approaches will probably serve you okay in your accumulation phase. They almost certainly won’t do as well as a pure passive fund strategy – you’ll be buying some fund manager a new sports car for nothing – but if you save enough for long enough in a diversified range of sensible funds, you’ll get there. Just a little poorer.

It’s really the hyper-active, concentrated, ultra-expensive and ‘churny’ approaches to investing that can truly eat up your wealth.

Performance chasing allied to the sort of strategies employed, in fact, by many of the under-performing hedge fund managers who frequently bemoan the rise of index funds.

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How will no-deal Brexit affect your investments?

How will no-deal Brexit affect your investments? post image

First let’s set out the terms of engagement. I’ll keep this one politically neutral. I’ve got an opinion like everyone else, but this post is about the practicalities and not how we got here. Let’s put the tribal warfare on hold for a few minutes.

I’m not going to BS you with 1,000 words on Brexit-proofing your portfolio either. The idea that we can take back control (of market volatility) with a quick shimmy into this fund or that is delusional.

What I am concerned about, as a passive investor, is whether I’ll still be able to buy and sell my ETFs and index funds as needed in the midst and aftermath of a no-deal Brexit.

Specifically, what are the chances that a UK-based investor who owns index trackers domiciled in the EU (mostly Ireland and Luxembourg) will experience some kind of disruption?

Could your investments be stuck in the financial equivalent of a lorry park outside Dover?

To stop asking questions for a sec and to start answering them, I’m glad I’ve looked into this because I’m much less worried now than I was.

The relevant authorities seem to have taken the steps necessary to ensure that it’s business as usual – even in the event of no-deal.

Just in case I misrepresent the scale of my expertise, I’d like to state upfront that I’m not a world expert in the dissolution of 47-year-old international treaties.

I’ve reached my conclusions by triangulating the announcements and actions of the various institutions and groups with direct control, influence, or interest in the outcome.

That list of party guests includes:

  • UK Government
  • The Financial Conduct Authority (FCA) – the UK financial markets and services regulator
  • European Securities and Markets Authority (ESMA)
  • Central Bank of Ireland – the Irish financial regulator
  • UK fund industry
  • Irish fund industry
  • UK financial media
  • UK mainstream media
  • UK and Irish law firms
  • Platform managers
  • London Stock Exchange

I expected to find plenty of cracks in the facade between those groups given their competing interests, but closer inspection of the Brexit timeline reveals a reassuring pattern:

  • Uncertainty is raised and speculated upon by the media.
  • Advice is issued by the law firms.
  • Industry stakeholders pressure their governments.
  • Governments wake up.
  • Regulators issue some fix or patch.
  • Media move on to the next concern.

It’s quite the civilised waltz when you view it over a few years worth of cached pages. The level of cross-Channel interdependence is unsurprisingly huge and nobody has an interest in screwing it all up.

Obviously, there are unknown unknowns and you can’t entirely discount the possibility of someone sticking a cosmic spanner in the works. But the loss of EU domiciled investments is no longer on my list of nagging concerns.

If you care to know why then let’s keep going…

The potential problem

If you own an ETF in your portfolio then it’s probably domiciled in Ireland. You may also own ETFs domiciled in Luxembourg.

(Your ETFs are overwhelmingly likely to be listed on the London Stock Exchange but this isn’t the same thing.)

Meanwhile your index funds are likely to be a mixed bag, predominantly domiciled in the UK or Ireland.

As a UK-resident investor I don’t need to worry about disruption to UK-domiciled funds, but Brits abroad may well be concerned.

European domiciled investments use ‘passporting’ rules to take advantage of the single market. The passporting rules allow any firm or fund authorised in one European Economic Area (EEA) state1 to conduct their business in any other EEA state without further hoop-jumping. Passporting enables EEA-domiciled trackers to be marketed at ‘retail’ investors (that is, the likes of you and me rather than institutions) across borders.

Passporting to and fro the UK goes up in smoke in a no-deal Brexit scenario.

ETFs are generally domiciled in Ireland and listed across the rest of Europe because the Irish regulatory regime is the easiest and cheapest for fund companies to navigate.

My immediate concern is that the end of passporting could:

  • Prevent trading in my investments until the regulatory log-jam is sorted.
  • Decimate my choice of investments. (For example, I’d be allowed to remain in my EU domiciled trackers but not to add to them.)

My longer-term concern is:

  • Costs go up due to an increased regulatory burden or lack of choice in the UK.
  • Some useful new trackers aren’t made available in the UK.

If you like dwelling on problems then enjoy this meaty list of Brexit-related investing issues.

The Temporary Permissions Regime ‘backstop’

Vanguard told me that it will be able to continue selling and marketing their Ireland-domiciled funds and ETFs in a no-deal scenario thanks to the UK Government’s Temporary Permissions Regime (TPR).

This checks out.

The UK’s financial markets regulator, the FCA, states:

The temporary permissions regime will allow EEA-based firms passporting into the UK to continue new and existing regulated business within the scope of their current permissions in the UK for a limited period, while they seek full FCA authorisation, if the UK leaves the EU after 31 October and there is no deal.

It will also allow EEA-domiciled investment funds that market in the UK under a passport to continue temporarily marketing in the UK.

The key takeaways from the underlying detail are:

  • The temporary permissions regime solves the passporting problem for UK-resident investors in a no-deal scenario.
  • Temporary means the arrangement lasts for three years after Brexit.
  • Firms can obtain UK authorisation for their EEA-domiciled funds during that three year period.
  • The FCA says the temporary permissions regime is now law.
  • Firms must sign up to the temporary permissions regime and the FCA recently extended the deadline to Oct 30 2019.

I’m assuming that global corporate giants like Vanguard and BlackRock (the owner of iShares) have the wherewithal to get their paperwork sorted by the deadline.

I’m also assuming that this open door to the UK market won’t be closed by the EU. They’re no more likely to block your access to EU-domiciled trackers than to deny you a new BMW or a wheel of Brie.

I didn’t come across a scheme that waves UK-domiciled funds through EU passport control, but I wasn’t specifically looking for it, either. A few UK investment firms have commented and don’t appear concerned. More on that below.

One wrinkle to watch out for is if you own funds that aren’t labelled Undertakings for Collective Investment in Transferable Securities Directive (UCITS) or Alternative Investment Funds (AIFs).

The temporary permissions regime specifically states that it covers UCITS and AIF funds.

The vast majority of index trackers are UCITS but it’s possible you own stuff that doesn’t qualify.

  • Some fund-of-funds aren’t UCITS, though Vanguard’s LifeStrategy product is. (It’s also domiciled in the UK.)
  • Exchanged Traded Commodities (ETCs) aren’t UCITS. You may well own a gold ETC.

Look out for sneakiness like iShares labelling its gold ETCs as UCITS eligible. That doesn’t mean the ETC is a UCITS fund. It’s not. UCITS eligible means the ETC can be invested in by a real UCITS fund.

I couldn’t find out whether ETCs are somehow covered by the temporary permissions regime. The regulatory tenor is to minimise disruption but this is one doubt I couldn’t dispel.

Worst case scenarios

Perhaps you’re tiring of my optimism and would like some good ol’ reptilian brain food as brought to you by Project FearTM?

Let’s turn to the FakeNews media to undermine our faith in this great country of ours. What’s the worst Brexit nightmare they can conjure?

The Money Observer came up with this blood-curdler:

A worst-case scenario would be that UK investors face less choice when it comes to selecting funds.

The Investors Chronicle chilled my spine with:

Exchange traded fund (ETF) providers could face higher costs and investors might have less choice of ETFs if Brexit (a UK exit from the European Union) brought with it the end of single-market trading agreements whereby Ireland and Luxembourg domiciled funds are automatically granted access to the London Stock Exchange.

In a worst-case scenario, providers would have to list separately in the UK, an exhaustive process involving high fees and an administrative burden.

And some managers of EEA UCITS funds may not seek UK authorisation once the temporary permission regime expires, foretells law firm Allen & Overy.

Whatever you think of experts these days, it’s plausible that UK regulators will make it extremely simple to rebadge EEA UCITS funds as UK UCITS funds. If so then the ‘less choice, increased cost’ nightmare scenario shouldn’t come to pass. Fingers crossed that British administrators don’t replace red tape with red, white, and blue tape.

The lack of incentive for our government to create friction for UK plc’s financial services industry dovetails nicely with the incentive for companies like Vanguard and Blackrock to ensure their index trackers remain widely available, given that scale is a critical component of their business model.

What do the investment platforms say?

Remarkably little given you’d think they’d want to address any customer concerns. There’s plenty of ‘Hey, don’t stop investing because of a leetle bit of Brexit uncertainty’ but virtually no guidance from the major players on how no-deal could affect access.

The notable exception is AJ Bell who published a decent piece outlining the risks – though even that was written for financial advisors rather than consumers.

At least back in October 2018, AJ Bell didn’t see a problem with trading ETFs on the London Stock Exchange:

ETFs are very rarely domiciled in the UK, however all our investments are in ETFs listed on the London Stock Exchange. Although the underlying fund may have to consider any regulatory effects due to not being domiciled in the UK, we will be able to continue to buy and sell our holdings through the secondary market, trading on the LSE.

Although it also speculated that costs could rise post-Brexit:

Announcements made to date by the FCA indicate temporary permissions would be put into place to allow existing funds to be held and traded after Brexit for a period of time. However it would create a cloud of uncertainty.

It is likely that fund groups will look to set up UK-domiciled vehicles and transfer investors across, which could incur costs for both the fund group and the underlying investor, depending on the mechanism used (such as a scheme of arrangement).

EU investors using UK domiciled funds

I came across a couple of UK investment firms who made reassuring noises about continued access to products for EU residents. Generally the information was scant and buried in Brexit FAQs but I ran out of time to pursue this angle.

There doesn’t appear to be an EU equivalent of the temporary permissions regime and the FCA advised back in February:

If the UK leaves the EU without a withdrawal agreement (a no-deal scenario), UK firms’ ability to continue to service EEA-based customers (including UK expats) remains a concern.

EEA-based customers (including UK expats) holding retail investment products serviced by UK providers could be affected if their UK provider cannot operate in the EEA after Brexit.

I don’t want to worry you unduly. The general thrust is that bridges are being lashed together rather than wired to detonate. There were some rumblings about EEA access to the London Stock Exchange a few months ago but the EU regulator seems to have rowed back on their intransigence since.

Interdependence creates workarounds and there’s a reason that both Vanguard and Blackrock have been busy expanding their European branch offices while maintaining their European headquarters in London.

Many other firms have been doing the same thing.

Nothing to worry about?

Obviously I can’t say nothing could go wrong. I’m personally reassured by the FCA’s moves but if you’re still nervous then:

  • You could switch your investments into a near-identical portfolio of index funds domiciled in the UK. There’s plenty of good, cheap funds available via the major index fund providers. Look out for the letters GB at the start of the fund’s ISIN number which you’ll find on its webpage, Key Investor Information Document or factsheet. GB means that it’s domiciled in the UK.
  • Or you could leave things as they are knowing you can always continue to pound-cost average into UK-domiciled funds if there is a no-deal Brexit interregnum.
  • It might also be wise to fatten up your emergency fund with extra cash to cover any extended period of disruption. I’m doing this right now but that’s more with an eye on the gathering clouds of global recession.
  • Go straight to the sources below for more reassurance (or worry-fodder!)

Aside from that, when it comes to no-deal Brexit, I’m making like a good passive investor and doing absolutely nothing.

Take it steady,

The Accumulator

Further reading: A no-deal Brexit linkfest for the fastidous

  1. EEA = EU member states plus Norway, Iceland, and Liechtenstein. []
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Weekend reading: 75 not out*

Weekend reading logo

What caught my eye this week.

Just when you thought pensions had been rehabilitated with the freedom to spend your savings how you like in retirement – and the laudable success of auto-enrollment nudging you there – along comes a conservative think tank ready to bugger them up again.

Not content with his faction bringing us the thermo-nuclear bungle that is Brexit, former Tory ‘leader’ Iain Duncan Smith’s Centre for Social Justice suggest the government withhold the state pension until 75:

The SPA [State Pension Age] should better reflect the longer life expectancies that we now enjoy and be used to support the fiscal balance of the nation.

The SPA in the UK is set to rise to 66 by 2020 (Pensions Act 2011), to 67 between 2026 and 2028 (State Pension Act 2014) and to 68 between 2044 and 2046 (State Pension Act 2007).

We propose accelerating the SPA increase to 70 by 2028 and then 75 by 2035.

There’s a lot to be written about this. For one thing, my co-blogger The Accumulator might have to revisit his fear-de-mongering article on why your pension won’t be plundered.

(Oops! Lucky it’s a Bank Holiday @TA!)

More seriously, the CSJ report shows its workings, and it’s hard to come away from it without thinking Something Must Be Done. I also personally happen to like the idea of working indefinitely, in some capacity, professional damp squib to the FIRE brigade that I am. I believe it’s probably healthier for most of us.

However I’d certainly expect to be easing up into my 60s. Perhaps a day or two a week by 70. I’d want to have options. I wouldn’t want politicians forever moving the goalposts away from me like some demented version of football devised by the Greek philosopher Zeno.

More darkly, as The Guardian points out there are pockets of the country such as Glasgow where male life expectancy doesn’t even hit the 75-year old mark. And life expectancy isn’t the same as healthy life expectancy, anyway.

An additional fear for the likes of us is that the age when we could access private pensions could also leap.

It’s already set to rise to 57 by 2028. Perhaps you’d be barred until 65 under the CSJ’s regime?

The alternative – wealthy types retiring in their 50s en masse to be served lattes on weekday afternoons by bitter septuagenarians – sounds almost worse.

Existential diversification

Of course this is only a proposal. It carries exactly zilch formal weight. Even Duncan Smith has said it’s not his policy, and he’s a Magneto for nonsense.

But I do think it’s a reminder that the rules of the game can and will change again and again.

In just the life of this blog we’ve seen it with everything from the pension lifetime allowance to the taxation of dividends to those who came here from the EU in good faith and lived here for decades being ordered to pay up for the right to stay.

Change is constant, which is why I’m as bemused when I hear people explain their entire strategy is 100% based on pensions as I was when old-time investors told me they eschewed using ISAs because their dividends were tax-free.

Political risk is hard to avoid unless you’re ready and able to move (and let’s not mention expats again this week, eh? 😉 )

But there are pragmatic approaches you can take, such as using various investment vehicles together (ISAs and pensions, at a minimum, and probably also property), keeping your hand in at earning to preserve your human capital, and trying to stay healthy for as long as possible.

As someone should have trademarked: Not everything that can be modeled to two decimal places on a FIRE spreadsheet matters. And not everything that matters can be modeled.

*If only Joe Root could say the same.

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