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Weekend reading: Caveat emptor needs to make a comeback post image

What caught my eye this week.

I mentioned the other day that I’m getting increasingly grumpy about the supposed victims of financial misdeeds seeking redress for shooting themselves in the foot.

Not a popular stance for a personal finance blogger to take, but the truth.

Paul Lewis for instance on Radio 4’s MoneyBox reliably turns me to the Dark Side like a neophyte Sith Lord as he rails against – oh, I don’t know – Tesco having the temerity to sell apples at ‘rip-off’ prices of more than what it paid for them.

A more serious example came this week in the Financial Times [Search result] in an article about interest-only mortgages.

The FT is not the first publication to warn of a looming crisis from interest-only mortgages. The charge is that borrowers have not saved up enough money to repay the capital at the end of the term.

And to be fair, the FT didn’t quite headline the mis-selling angle in this piece, though it did raise the juicy prospect.

But a victim narrative was certainly foreshadowed in the angle it took and the quotes it used.

The article led by painting a picture of a son being denied the inheritance of the family home because of his mother’s decision to take out an interest-only mortgage:

Linda needs to have a difficult conversation with her son. The expectation was that one day, he would inherit the family home in London where she still lives. But her decision to take out an interest-only mortgage of £182,000 nearly a decade ago has effectively cost him his inheritance.

Well, no.

I don’t know Linda’s circumstances, obviously, but from as much as we can tell here it was her decision not to save up to repay “a penny of the underlying debt” that has cost him his inheritance.

Alternatively, if she would never have been able to find the money to pay for what she bought, then she shouldn’t expect to own it.

That’s not a scandal. That’s shopping.

Later on we have Gary, who claims “we didn’t have things explained to us”. This might point a way forward to the sort of compensation windfall enjoyed by the PPI-paying masses, except that Gary immediately adds “Anyway, our hands were kind of tied at the time — it was more or less our only option.”

I don’t mean to dismiss the issues faced by these people, or make fun of them; I’m sure they have their worries. But they are in the victim role as portrayed by the FT, and it’s a role that needs to be challenged.

Why not a piece saying that the rest of the banks’ customers or shareholders – or the State – will need to bail out these kinds of individuals if they’re not to be turfed from their homes entirely because of their own decisions? Somebody always pays.

As for mis-selling, happily this kind of mortgage’s purpose is made pretty clear in the name itself.

We’re not talking about a Property Financing Multi-Year Upkeep and Retention Vehicle, or some other financial nonsense.

It is an Interest-Only mortgage. As in – slowly now – you only pay the interest.

[continue reading…]

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The FCA is avoiding the elephant in the room

The FCA is avoiding the elephant in the room post image

The Financial Conduct Authority’s recent report into the asset management industry didn’t go far enough for one frustrated fund manager. Requesting anonymity (but known to us at Monevator) they share their thoughts below…

The report by the Financial Conduct Authority (FCA) into the asset management industry is, in the view of this writer, a lost opportunity.

Nowhere in its 144 pages does it mention the words beta or alpha. Yet the heart of the problem with fund managers is not costs, as the report focusses on, but miss-selling.

Active managers claim to deliver better returns than the average – i.e. to offer alpha – but the reality is that in aggregate active management fails to even deliver beta – i.e. the market return – because of the higher risks and costs associated with trying to achieve alpha.

As regular Monevator readers will know, the evidence is overwhelming. Over meaningful time periods, most active fund managers underperform.

Should not the fact that most private investors fail to understand or take this into account when buying funds be a key concern?

Cut out the middlemen

In its defence the FCA says it didn’t want to use the terms alpha and beta because they are too technical for investors to understand.

This is the second mistake the report makes. It consistently refers to ‘the investor’ yet the reality is that most funds are bought by intermediaries – that is, IFAs and wealth managers.

They are not the principals in the transaction but the agents. That gives then a very different incentive from the owners. As agents they are far less worried about the costs of ownership and returns, and more worried about the risk to their reputations and businesses.

As a consequence they would rather recommend a fund that appears safer than one that is cheaper. It is the old “no one ever got fired for buying IBM” argument.

There is a secondary element to this issue of who makes the purchasing decisions relative to who is the ultimate beneficiary, too. The agent has a vested interest in making his role look more complex and demanding to his customer than it really is.

If the end investor realised that it was not actually that difficult to buy beta then he would do it himself and cut out the middleman – and about 1% in charges.

After all, that is essentially what budget airlines have done by cutting out the travel agent and marketing direct to the consumer. It is the same with many products and services now sold over the Internet.

Massive cost savings are available by bypassing the distribution chain and going direct to the consumer. The consequences can be seen in high streets and shopping centres up and down the land as shops are closed and boarded up.

Truly disrupting the financial services industry

This brings us to the real failure of the report. It is still difficult for asset managers to present hard data, such as turnover rates, information ratio, beta or even compound interest directly to the public for fear of giving advice. Instead the FCA seems to prefer them to use intermediaries, who have a different agenda. This is what is preventing real competition from shaking up the industry, reducing costs and bringing in new ideas.

The FCA says fund management is too complex for the average investor to comprehend. In this writer’s opinion, that argument is fallacious. Mobile phones, computers, cars and TVs are far more complex than the average fund but that does not stop the population buying them and, by and large, making decisions in their best interests.

Why should that logic not apply to asset management?

The reason is of course that there are lot of well paid, and highly intelligent, people who have a vested interest in preventing the public from buying beta, the market return, very cheaply.

Instead, they want to sell alpha, the goal of outperforming everyone else, for a much higher price.

The illogicality of that argument is not lost on them but they respond by saying that while it might be true that, like the children of Lake Wobegon they all claim to be above average, they can always find some element of complexity – often related to tax wrappers – to persuade the investor he should be guided by an expert.

Expecting the public to effectively separate signal from very noisy data, and then factor in risk and costs is deemed far too onerous. Intermediaries get around that problem simply by using past performance, despite all its flaws.

A beta solution

As Upton Sinclair famously said: “It is difficult to get a man to understand something, when his salary depends on his not understanding it.”

There will always be a need for intermediaries for more complex financial situations. However, the reality is that the average investor can satisfy much of his basic investment requirements by purchasing beta cheaply and simply through a passive fund without using an intermediary at all. The FCA report makes this no more likely now than before it was written.

If we really want transparency in this industry we need to use simple clear language to explain directly to investors what they are being sold. The FCA’s reluctance to use technical but clear labels like beta and alpha does not help the process.

Transparency is also aided when goods and services are sold directly by the provider to the consumer. Making it difficult to do this – and encouraging the use of intermediaries – makes transparency more difficult because the agenda of the agent is different from the principal.

Further reading

  • The issue of intermediaries is set to be explored in the FCA’s follow-up platform market study, which launched on July 17th.
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Weekend reading: ETFs are on the right side of history post image

What caught my eye this week.

Ben Carlson has no truck with the gathering notion that ETFs will destabilize the markets, swindle active managers out of their dues, damage the economy, and cause kittens and puppies to be sad.

Writing in Bloomberg, Carlson notes:

Those who are concerned that indexing is causing a market bubble don’t realize that active investors have had no trouble doing so in the past when index funds didn’t exist.

There were no index funds during the Roaring 20s that led to the Great Depression nor in the go-go years in the 1960s that led to the Nifty Fifty blow-up.

These funds had nothing to do with the brutal 1973-74 bear market because they weren’t even invented until 1976.

I entirely agree. Most of you don’t watch much financial news. You don’t regularly hear pundits saying when the market has fallen 0.5% in a day that it’s down to “all the algos and robots and passive dumb money mindlessly driving volatility in the market”.

Markets have always gone up and down. Prices of assets with uncertain future returns will always be volatile.

The only threat we can yet be sure of from ETFs and other index funds is to the financial industry’s bottom line.

[continue reading…]

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What to do with old private pension plans

Photo of Mark Meldon, IFA

The following guest post is by Mark Meldon, an independent financial advisor who has come on-board to explain some of the more obscure or technical corners of personal finance.

I began my career in financial services back in 1988, working at the head office of a long-gone life insurer in Surrey. I then joined an independent financial advisory practice in 1990 with a specific remit to advise members of occupational schemes about things like insurance policies and additional pension contributions.

Mainly, though, I was involved in arranging the new kid on the block – personal pension plans.

Private Pension Plans

In a certain guise, personal, or private, pension plans have been available in the UK continuously since the Finance Act of 19561 when what are known as ‘retirement annuity policies’ or ‘Section 226 policies’ were introduced under legislation. They were often marketed specifically at the self-employed.

Then, in 1988, personal pensions were launched to great fanfare. These remain available today, but much has changed over the last 30 years as far as charges, retirement options, and who offers them are concerned.

It isn’t my purpose to deal with too much history here (fascinating as it might be to me), but there are a few things that need to be understood regarding old policies that are gathering dust in the traditional box under the bed.

Sometimes – quite often in fact – gems can be found among those dusty piles of paperwork accumulated after years of neglect.

In order to keep things reasonably clear, let’s just call these ‘private pension plans’. Although there were distinctions between ‘S226’ and ‘PPP’ policies (the latter, for example allowed millions to ‘contract-out’ of the then state pension top-up scheme, SERPS), most of these have now vanished as legislation has changed over the decades.

What has not changed, with one very important exception, are the contract terms and conditions applicable to whatever plan(s) you might have2. This is the potentially very interesting bit!

Insured or SIPP?

Up until very recently, the vast majority of private pension plans were sold by life insurance companies. SIPPs (Self-Invested Personal Pensions), incidentally, are subject to exactly the same rules as those ‘insured’ schemes – they just have more investment choices and have become increasingly popular as administration and investment charges have been driven down by technological advances.

There are, however, millions of insured arrangements in the UK and, anecdotally, the majority of these are not currently receiving contributions. I think that there has never been a better time to look at these ancient policies to see how well they meet your needs.

Crucially, some might have very favourable guarantees that give certainty of payment throughout retirement, at a level that current investment conditions are unlikely to match.

That said some consideration should perhaps be given to rounding them up into a shiny new arrangement that can offer all of the flexibility permitted under the pension freedoms introduced in 2015.

If you think about it, a personal pension requires two basic things to make it work: administration and investment management. An insured plan bundles these two things together and can offer additional features such as life insurance and disability benefits (this is called a ‘waiver of contribution benefit’). Whereas, briefly, a SIPP separates these basic elements. You pay an administrator and you choose the investments.

I think the general perception that all insured private pensions are markedly inferior to a SIPP simply isn’t true, and I’ll try to explain why in a moment.

But first we need to look at who sold them.

Disruptive technology and administration costs

Looking at administration first, I remember filling in huge data input sheets in the new business department of that long-gone life office. These sheets were then sent off to a computer department that occupied a whole floor of a large building for an overnight run.

Whilst that makes me sounds ancient, those computers were state of the art then, albeit vastly inferior to today’s smart phones that we all take so much for granted. Such disruptive technology quickly overtook many life offices and made many of their products uncompetitive as far as administration costs were concerned. (Who would have thought of the impact of the likes of Hargreaves Lansdown and others back then, with the operating efficiencies their business model later introduced?)

Most private pensions were not sold through IFAs. Rather, in those days many life offices had huge direct sales forces. Indeed the number of  such advisers has shrunk by as much as eighty percent.3

Back in the early 1990s there were over 100 hundred companies selling private pensions. Today there are just a half-dozen serious players left in the market! Running from Abbey Life, Allied Dunbar, London & Manchester, NPI, Royal Life, Sun Life to Zurich Life, these so-called ‘zombie’ life offices have often been bought up by consolidators such as Phoenix Life and ReAssure. The consolidators now run hundreds of legacy books of business – and pretty well in my opinion, in the main.

These consolidators are subject to strict rules and conduct of business but are, of course, commercial organisations and need to make a profit. They do this from the multitude of plan charges and investment charges that came with these old policies.

Up until the abolition of commission at the end of 2012, the typical private pension might have the following charging structure:

  • A 5% bid/offer spread as an initial charge on every contribution paid.
  • A policy fee of £3 per month.
  • Contributions paid within an initial period defined in the policy conditions were often allocated to ‘capital’ or ‘initial’ units, which suffered an annual management charge of, typically, between 3% and 9%. Regular contributions paid after the initial period and single contributions were usually allocated to ‘ordinary’ or ‘accumulation’ units, which suffer an annual management charge of, typically, between 0.5% and 1.5%.
  • Providers used initial/capital units to recoup their expenses associated with setting up regular contribution pension policies and the cost of commission payments, which were substantially higher for regular premiums than for single premiums.
  • Alternatively, rather less than you paid was actually invested into ordinary units for a period of time – known as front-end loading – with the quid pro quo being that there were few, if any, early termination charges.

As far as the commission paid in those far-off days is concerned, let us consider someone deciding to pay a not unreasonable £250 per month into a private insured pension for 30 years. Based on the commission scales from the mid-1990s, the direct salesman would expect to be paid something like £2,900 in up-front commission, whereas an IFA rather less at something like £1,900 – the differential being explained by the fact that the direct salesman gives 100% of his business to the life office.

Now you can see why the charges were so high!

Had our investor paid a £3,000 single contribution, by the way, the commission would have been £240 for the direct salesman and £150 for the IFA. Hmm!

Investment management for insured pensions

The choices here fell broadly into two basic options: ‘with-profits’ and ‘unit-linked’, with the latter far more prevalent than the former thanks to the likes of disruptive innovators such as Abbey Life and Hambro Life (later called Allied Dunbar, now Zurich Assurance).

With-profits funds were, and are, substantial pools of money managed internally by the life office. Unit-linked funds came in various flavours such as a Managed Fund, UK Equity Fund, Property Fund and others.

The most commonly perceived difference between with-profits and unit-linked investment is that the value of unit-linked policies is more volatile. This is because the policy value is obtained by multiplying the number of units held by the prevailing published bid price, which fluctuates directly in line with the market value of the assets held in the fund.

The return achieved, therefore, directly follows market conditions and volatility can clearly be seen though variations in the bid price of units. I have always found this a rather more transparent approach to investment.

By contrast, the value of a with-profits policy is largely determined by the insurance company and is not directly related to the value of the underlying assets of the with-profits fund. Instead, insurers allocate a return through the mechanism of bonus declarations, which aims to smooth out the volatility in the value of the underlying assets. This conservative approach was favoured by many IFAs back in the 1980s and 1990s but is rarely available today.

Traps for the unwary

You might think that all old insured private pension plans are terrible, but that isn’t always so. For example, many policies have valuable features that are just not available today.

Indeed, some are extraordinarily attractive.

For instance, up until the mid-1990s, many life offices offered a ‘guaranteed annuity rate’ on their policies. Simply put, you can take a fixed secure income for life from the policy when you reach retirement age. Sometimes this so-called GAR isn’t actually much use in the real world, as it might only be available as a pension paid annually in arrears with no options like a spouse’s pension. However, many do offer flexible options – you really need to check.

A couple of years or so ago, I advised a client to exercise a GAR which gave him a return of 16% on his fund! From an after tax-free cash fund of £85,000 or so, he has already been paid gross income of £27,200, and he is only 67 – amazingly, that is around 3.5x what he could buy today from a pension annuity on the open market today. Bearing in mind that he only paid in around £12,000 in net contributions to the plan back in the 1980s, I can only say “kerching!”

Many old policies I look at also offer insurance benefits like life cover and ‘waiver of contribution benefit’ – the former is often rather expensive but the latter means that the insurance company will effectively pay your pension contributions on your behalf if you suffer from long-term ill-health. I had experience of a lady who became ill and her pension payments continued for 12 years under this provision.

Marketing gimmicks were common, too – loyalty bonuses, charge rebates and the like. I have a handful of clients who set up private pensions with what was the Sun Life in 1992 and these policies were all set up to finish at age 55. Two of these clients have long gone past that age but have kept the policies up and they now benefit from ‘Extra Fund Injection’ (remember all those ‘EFI’ badges on the back of cars in the early 90s?) which effectively wipes most of the policy charges and makes their contracts very attractive even in comparison with today’s low-cost options.

However, I have looked at hundreds of old private pensions over the last 15 odd years and most, unfortunately, are pretty poor value, exhibiting high cost, mediocre investment returns and no special features.

I’d say that my advice has been to ‘hold’ about a quarter of the plans I have investigated in detail and to ‘fold’ three-quarters into a better value contract offering access to all currently permitted options on retirement. About half of these funds are now in a SIPP wrapper and the other half (generally the smaller funds) in insured policies.

Good news and what to do

The good news is that it is now much easier to fold an old pension into a new arrangement as the FCA (Financial Conduct Authority) introduced a 1% maximum exit charge rule in April. That is now the most a life office can charge on exit. (That said, at least half of the plans I have looked at didn’t have exit charges anyway.)

To undertake what I call an audit of old pension policies is rather complex and time-consuming. But you could do it yourself and here is what you need to do.

1. Obtain a projection of benefits from your existing private pension plan provider. This will effectively confirm the charges on your contract, the current fund, and transfer values, but you will need the life office to firm up details (see below).

2. Undertake an initial assessment of the charges, paying particular attention to the ‘reduction in yield’ (RIY) and transfer value figures. Also refer to fund charge information and with-profits guides.

3. Alternative illustrations should then be sourced from potential alternative providers using today’s different charging regimes. It’s certainly worth asking the current provider for a so-called ‘existing business illustration’ if the firm is still accepting additional contributions – many will not take increases where high guarantees feature in the policy.

4. You then need to do a detailed product charge analysis. Most IFAs will have some groovy (and quite expensive) software to do this, but you might need to set up spreadsheets.

5. For with-profit investments you need to:

  • Analyse independent fund ratings, and financial strength of the provider;
  • Consider the provider’s bonus track record;
  • Analyse the asset mix of the fund. Does it still meet you requirements, does the annual management charge represent good value for that asset mix?

6. Then you need to factor in any special features mentioned above as objectively as you can in the light of your circumstances now.

7. Eventually, you can make some kind of reasoned decision about what to do.

Alternatively, you could hire an IFA to do all of this heavy work for you. They are likely to have access to industry tools that you can’t get hold of and will have plenty of subjective experience on which to draw.

Whether to Hold or Fold an old pension plan is ultimately your choice, but I do think the decision needs to be carefully thought through. There are a multiplicity of factors you need to take into account, as I hope I have demonstrated.

Please note: The article above ONLY concerns ‘defined contribution’ or ‘money purchase’ pension plans. These can be personal pensions, company-sponsored schemes, AVC’s, FSAVC’s, Executive Pensions, and stakeholder plans. It does NOT concern defined benefit or final salary pensions – that’s a much more complicated area.

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.

  1. Source: Personal Pensions Handbook & Unit-Linked Survey 1994/95. []
  2. The exception is it is now much less onerous to fold an old pension into a new arrangement, thanks to a 1% maximum exit charge rule that was brought in by the Financial Conduct Authority in April. Previously charges could be 20% or more! []
  3. Source: Personal Finance Society 2016. []
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