2018年-FCA英国金融行为监管局_ms16_1_3_annex_3_24页_579kb

Retirement Outcomes Review Summary

Core Content

The Retirement Outcomes Review (June 2018) is an analysis of the UK pension market, particularly focusing on drawdown and early access to pension pots. The review includes feedback from stakeholders and responses to these inputs, aiming to improve consumer outcomes and market efficiency.

The review was based on an interim report, which outlined key findings and initial thoughts on potential remedies. A total of 56 formal written responses were received from various stakeholders, including providers, consumer bodies, trade associations, and individuals. These responses largely supported the findings and contributed to the development of the remedies.

Main Findings

1. Consumer Understanding and Behavior

• Most consumers accessing their pension pots do so early (before 65) and take tax-free cash, indicating a trend that has become the new norm for early access.
• There is low consumer understanding of pensions, especially regarding longevity risk and the need to save more for retirement.
• Shopping around for drawdown options is generally low, with some consumers accessing multiple pots and others not needing to do so due to full encashment or prior planning.

2. Guidance Uptake

• The Pension Wise service has been underutilized, but the review acknowledges that guidance is sought from multiple sources, including pension providers and the Pensions Advisory Service.
• The interim report may have underestimated the use of guidance, as the same consumer can access multiple pots, and the Pension Wise website has received over 5 million visits.

3. Market Challenges

• Regulatory uncertainty and complex charging structures are barriers to competition and innovation.
• Consumers often withdraw their entire pension pot (especially smaller pots), and this behavior is influenced by fears of future policy changes.

Key Issues and Stakeholder Feedback

1. Early Access as the New Norm

• Some stakeholders challenged the claim that early access has become the "new norm", arguing that it is not widespread and that such terminology may influence consumer behavior.
• The review clarified that early access and withdrawal of tax-free cash is the norm among those who have accessed their pots, but this is not the intended outcome.

2. Guidance Uptake

• Stakeholders highlighted that guidance is not always sought alongside drawdown access, and that Pension Wise should be more prominent in the analysis.
• The review acknowledged that consumers use guidance from various sources, and that the Financial Guidance and Claims Act is helping to streamline access to guidance.

3. Policy and Regulatory Certainty

• Many stakeholders called for greater policy and regulatory certainty to restore consumer confidence.
• They argued that uncertainty has deterred new entrants and hindered innovation.

4. Consumer Education

• There is a strong call for education on retirement savings and the longevity risk.
• Stakeholders emphasized that normalizing early access could be harmful, and that the message should discourage early withdrawal unless necessary.

Proposed Remedies and Stakeholder Response

1. Intervention Timing

• Stakeholders had mixed views on whether to intervene early or wait for market adjustment.
• The review concluded that intervening now is more beneficial to prevent harm from crystallizing.

2. Default Investment Pathways

• The review proposed default investment pathways for non-advised drawdown users to help them make informed decisions.
• Stakeholders supported the idea but raised concerns about the use of the term 'default', ongoing engagement, and the application to all consumers.
• Some argued that default pathways could discourage engagement, while others felt that off-the-shelf products and multiple pathways would be more appropriate.

3. Charge Controls and Governance

• The review suggested charge caps for default investment pathways and the extension of Independent Governance Committees (IGCs) to oversee decumulation products.
• Stakeholders supported charge controls but questioned the feasibility of a one-size-fits-all approach.

Our Response

1. Revised Approach to Remedies

• The review has adjusted its language away from "default" and is now proposing investment pathways tailored to different consumer groups.
• Periodic reminders from providers to consumers about their investment pathway and its objectives are being considered.
• The focus remains on drawdown due to its increasing prevalence and the significant proportion of consumers using it without advice.

2. Balancing Consumer Protection and Market Competition

• The proposed remedies aim to enhance consumer engagement, provide clearer information, and protect against poor choices.
• The review acknowledges that not all consumers can or will engage, and therefore protections are necessary for vulnerable groups.

3. Collaboration and Policy Context

• The review emphasizes the need for cooperation across Government, regulators, industry, and consumer bodies.
• Policy and regulatory changes are outside the FCA's mandate, but the review calls for greater stability to build trust in the pensions market.

Conclusion

The Retirement Outcomes Review aims to improve the retirement income market by addressing consumer understanding, early access trends, and market competition. The review acknowledges stakeholder concerns and has made adjustments to its approach, including tailored investment pathways and enhanced guidance access. The final package of remedies is intended to protect consumers while encouraging better market outcomes.