Stronger Nudge to pensions guidance

Question 1

Introduction

Accepted Answer

This consultation seeks views and evidence on the proposed regulations relating to occupational pension schemes to implement section 19 of the Financial Guidance and Claims Act 2018. The draft Occupational and Personal Pension Schemes (Disclosure of Information) (Amendment) Regulations 2021 propose to require the trustees and managers of schemes in scope to ensure individuals seeking to access, or transfer for the purpose of accessing, their pension flexibilities (generally, defined contribution benefits) have received or opted out of receiving appropriate pensions guidance.

The Financial Conduct Authority (FCA) will have a corresponding duty to make rules to implement section 18 of the Financial Guidance and Claims Act 2018 covering personal pension schemes (contract-based pension schemes).

Question 2

About this consultation

Accepted Answer

Who this consultation is aimed at?

We would particularly welcome responses from members of occupational and personal pension schemes, employee representatives, Trustee and scheme managers, trades unions, consumer groups, employers, and pension industry professionals, including scheme administrators, independent financial advisors, employee benefit consultants, members of the advisory community and any other interested parties.

Purpose of the consultation

The purpose of this consultation is to seek views and evidence on the draft Regulations for delivering a Stronger Nudge to pensions guidance when individuals seek to access, or transfer for the purpose of accessing, their pension flexibilities applying to occupational pension schemes.

Sections 18 and 19 of the Financial Guidance and Claims Act 2018 provide the making of rules and regulations respectively to require scheme trustees and managers to refer individuals wishing to access or transfer their pension flexibilities to receive appropriate pensions guidance or to opt out of receiving such guidance prior to accessing or transferring their pension benefits.

The scope of this consultation relates to the draft Regulations to be made under Section 19 of the Financial Guidance and Claims Act 2018. The Financial Conduct Authority are responsible for consulting on the proposed rules to be made under Section 18 of the Financial Guidance and Claims Act 2018.

We wish to establish whether the draft Regulations achieve their intended purpose. We are seeking to understand and welcome views on any impacts and unintended consequences that the draft Regulations might have when implementing these regulations in practice. In particular, we are interested to find out what effect this may have on the customer journey, how the nudge would fit into existing provider communications and practices, and any foreseeable impacts that may surround this.

Scope of consultation

This consultation applies to England, Wales and Scotland.

Occupational pensions policy is a devolved matter for Northern Ireland. It is anticipated that Northern Ireland will make corresponding regulations

Duration of the consultation

The consultation period begins on 9 July 2021 and runs until 3 September 2021.

Please ensure your response reaches us by that date as any replies received after that date may not be taken into account.

How to respond to this consultation

Please send your response, highlighting that you are responding to this consultation, preferably by email to: pensionsguidance.consultation@dwp.gov.uk

When responding, please state whether you are doing so as an individual, or on behalf of a company or representing the views of an organisation. If you are responding on behalf of an organisation, please make sure you tell us who the organisation represents, and where applicable, how the views of the members were assembled.

Government response

We will publish the government response to the consultation on the GOV.UK website. The report will summarise the responses, and set out the Government’s proposed next steps.

Question 3

How we consult

Accepted Answer

Consultation principles

This consultation is being conducted in line with the revised Cabinet Office consultation principles published in March 2018. These principles give clear guidance to government departments on conducting consultations.

Feedback on the consultation process

We value your feedback on how well we consult. If you have any comments about the consultation process (as opposed to comments about the issues which are the subject of the consultation), please email them to the DWP Consultation Coordinator. These could include if you feel that the consultation does not adhere to the values expressed in the consultation principles or that the process could be improved.

DWP Consultation Coordinator
4th Floor
Caxton House
Tothill Street
London
SW1H 9NA

Email: caxtonhouse.legislation@dwp.gsi.gov.uk

Freedom of information

The information you send us may need to be passed to colleagues within the Department for Work and Pensions, published in a summary of responses received and referred to in the published consultation report.

All information contained in your response, including personal information, may be subject to publication or disclosure if requested under the Freedom of Information Act 2000. By providing personal information for the purposes of the public consultation exercise, it is understood that you consent to its disclosure and publication. If this is not the case, you should limit any personal information provided, or remove it completely. If you want the information in your response to the consultation to be kept confidential, you should explain why as part of your response, although we cannot guarantee to do this.

To find out more about the general principles of Freedom of Information and how it is applied within DWP, please contact the Central Freedom of Information Team, by email: freedom-of-information-request@dwp.gsi.gov.uk

The Central Freedom of Information team cannot advise on specific consultation exercises, only on Freedom of Information issues. Read more information about the Freedom of Information Act.

Question 4

Background

Accepted Answer

The Pensions Flexibilities, introduced in 2015, apply to occupational and personal pension schemes. They represented a significant change to the UK’s pensions system, giving people much more freedom and choice over options for accessing and using pension savings than before.

The pension flexibilities provisions mean that people can access their pension benefits (mainly defined contribution pension benefits) from age 55 and have a wider range of options as to what to do with their savings.

As part of the changes, the brand ‘Pension Wise’ guidance was launched. This service, which was transferred to the Money and Pensions Service (MaPS) provides free, impartial guidance to help individuals, aged 50 and over with a defined contribution pension, understand the options available to them. Pension Wise is funded through levies on the financial industry.

Current Provision

Currently, trustees and managers are required, under the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013, to provide to members a statement that free and impartial pensions guidance is available, that members should access this and consider taking independent advice, and to provide members with details on how they may access pensions guidance.

The trustees and managers of schemes in scope are required to do this when they contact a member in connection with what the member may do with their flexible benefits; when a member requests information from them about what the member may do with their flexible benefits or informs them that the member is considering or has made a decision in relation to what to do with their flexible benefits; and when a member has reached normal minimum pension age or meets the ill-health condition.

In addition to this, trustees and managers are required to provide a statement informing members to note the importance of guidance alongside an application form, online access, or any other method of accessing flexible benefits.

For schemes in scope, the trustees and managers do not, at present, have to ensure that members have either opted out or received guidance and do not need to facilitate the booking of a guidance appointment.

The Case for Change

Pension Wise has been shown to be helpful to those considering how to access their pension pot. Nine in ten appointment customers (91%) agree that Pension Wise helped them to consider their pension access options more thoroughly. A similar proportion (89%) felt they learned something new from using the service^{[footnote 1]}.

The use of Pension Wise is increasing, with around 132,000 face-to-face and telephone appointments attended in 2019 to 2020, a 29% increase from 2018 to 2019^{[footnote 2]}. While use of the service is increasing, a significant number of DC pots are being accessed without the use of advice or guidance. The Financial Conduct Authority (FCA’s) Retirement Income Market Data 1 shows that in 2019 to 2020, 50% of all pots accessed in the contract-based retirement income market were accessed without advice or guidance.

During the passage of the Financial Guidance and Claims Act 2018, Parliamentarians tabled a number of amendments aimed at increasing take up of Pension Wise guidance. The Government committed to undertake trials to understand how best to nudge people to take Pension Wise guidance or regulated financial advice before accessing or transferring their defined contribution pension. The results of these trials led to the publishing of a statement of policy intent on 28 October 2020.

The Financial Guidance and Claims Act 2018

Section 19 of the Financial Guidance and Claims Act 2018 (which inserts a new section 113B in the Pension Schemes Act 1993), once brought into force, requires the Secretary of State to make regulations (via the negative resolution procedure) placing duties on trustees and managers of occupational pension schemes to:

where a scheme member (or other relevant beneficiary) makes an application to transfer pension rights or start receiving benefits, refer them to appropriate pensions guidance, and explain the nature and purpose of the guidance, and
before proceeding with an application, ensure the member (or other relevant beneficiary) has either received the guidance or opted out of receiving it

Section 19 permits regulations to:

specify what constitutes ‘appropriate pensions guidance’
make further provision about how trustees/managers must comply with their duties
specify how and to whom a beneficiary must opt out of receiving guidance
specify the duties of trustees/managers where a beneficiary does not respond to communications concerning whether the beneficiary has received or opted out of receiving guidance
make exceptions to the duties in specified cases, and
provide for guidance to be issued to which trustees/managers must have regard

Summary of Stronger Nudge Trials and Evaluation Results

The Money and Pensions Service (MaPS) commissioned the Behavioural Insights Team (BIT) to evaluate the impact of ‘Stronger Nudge’ interventions on the number of people who receive Pension Wise guidance before they access their pension savings. The key component of the Stronger Nudge was to increase the prominence of Pension Wise guidance during the call by offering it as a normal part of the pension access journey, presenting it as valuable, and making it easier for pension holders to book a Pension Wise appointment.

Key findings from the Trial

The approach was successful at increasing the number of pension holders booking and attending a Pension Wise appointment compared to business as usual. Approximately 14% of pension holders who did not report having had guidance before agreed to book an appointment. This was 11 percentage points more than the control group, where the proportion was 3%. Approximately 11% of pension holders attended a Pension Wise appointment, which was 8 percentage points more than in the control group.

The results were further analysed to assess whether there was a differential impact provided by a pension holder’s age, gender, retirement pot size or other characteristic. None of the characteristics tested showed a significant difference in outcome.

Question 5

What do we want to achieve?

Accepted Answer

The Stronger Nudge

It is proposed to amend the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013 (“the Disclosure Regulations 2013”) to introduce new requirements concerning the Stronger Nudge to pensions guidance. The Stronger Nudge to pensions guidance aims to increase take up of pensions guidance, by requiring trustees and managers to ensure that individuals have either received or opted out of receiving appropriate pensions guidance before proceeding with their application. The goal of this is to present taking pensions guidance as a normal part of the application process and to require members (and other relevant beneficiaries) to make an active choice to opt out of receiving guidance.

As part of this, we are proposing that trustees and managers explain the nature and purpose of Pension Wise guidance and facilitate the booking of a Pension Wise appointment for the customer as part of the application process, removing the inertia introduced by having to book their own appointment. We also propose introducing a separate opt out procedure to encourage relevant beneficiaries to seriously consider the value that guidance has and ensure that, where beneficiaries decline guidance, this is an active choice on their part.

The regulation-making power in section 19 of the Financial Guidance and Claims Act 2018 Act allows us to define what is meant by the term ‘appropriate pensions guidance’. In regulation 18C(12)(a), We propose to define this as guidance provided by the Single Financial Guidance Body, known as the Money and Pension Service (MaPS), which is accessed during an appointment including the facility for real time, human interaction. Currently, we intend this to refer to Pension Wise guidance which is delivered via telephone, face to face, or online appointments but wish to allow for the possibility of changes to the service in future.

Who receives the Nudge?

We want the Stronger Nudge to pensions guidance to be delivered to all relevant beneficiaries, aged 50 or above, who contact a scheme to request to access their pension benefits or to transfer those benefits with the intention of accessing their pension flexibilities.

Schemes will not need to deliver the nudge to beneficiaries transferring for the sole purpose of consolidation, as we are seeking to ensure individuals either receive or opt out of appropriate pensions guidance before making a final decision about how to access their pension flexibilities. For these purposes, we have defined a relevant beneficiary as being a member aged 50 or above. Trustees and managers will not be required to nudge members aged under 50, as they may assume that a relevant beneficiary aged under 50 who wishes to transfer their pension benefits out of their existing scheme is doing so for the sole purpose of consolidation. This also ensures that only those who are eligible to receive Pension Wise guidance are nudged to receive it under these regulations, as age 50 is the eligible age for Pension Wise guidance. Where a member is over 50 but is transferring for the sole purpose of consolidation schemes will not be required to deliver the nudge.

Schemes will not have to deliver the nudge to those transferring their rights into a defined benefit scheme where they will be unable to access pensions flexibilities.

Trustees and managers will only have a duty to nudge relevant beneficiaries who wish to transfer their pension benefits out of their scheme. They will not need to deliver the nudge to those contacting them to transfer into the scheme.

The Stronger Nudge will not need to be redelivered to members who have already been nudged to obtain appropriate pensions guidance and have confirmed they have received Pension Wise guidance or opted out of receiving that guidance.

When is the Stronger Nudge delivered?

Draft regulation 3(6) of the draft Occupational and Personal Pension Schemes (Disclosure of Information) (Amendment) Regulations 2021 (“the draft Regulations”) seeks to insert new regulations 18C and 18D into the Disclosure Regulations 2013. Draft regulation 18C(2), read together with draft regulation 18C(4), is intended to reflect the policy intention that the Stronger Nudge should be delivered when an application to access or transfer pension benefits for the purpose of accessing pension flexibilities is received by the trustees or managers from a relevant beneficiary. Schemes in scope need to ensure they have received confirmation of attendance at a Pension Wise appointment, or an opt out, before proceeding with the application process.

We have not defined in the regulations what constitutes an application. We want to allow schemes to make decisions regarding exactly when this process is triggered, taking into account that members are likely to contact schemes at different points. However, we would like this to occur as early as practical within the process, and ideally members should be directed to Pension Wise guidance before they have made a final decision about accessing (or transferring with the intention of accessing).

Question 1. Do you agree with our proposed approach to defining when the Stronger Nudge should be delivered? If not, what changes do you consider necessary?

Booking a Pensions Guidance Appointment

Draft regulation 18C(6) proposes to require trustees and managers of occupational pension schemes to offer to book an appointment on relevant beneficiaries’ behalf. Where beneficiaries take up this offer we want trustees and managers to book this appointment for them. This can be implemented via different communication methods. When beneficiaries contact trustees or managers via phone, this should be done over the phone. For purely digital journeys, trustees and managers could embed the Pension Wise booking tool into their website, or provide a link to the online Pension Wise booking tool. For purely postal journeys, trustees and managers should provide details of how to book a Pension Wise appointment via post.

Where a relevant beneficiary wishes to book a Pension Wise appointment themselves, trustees and managers should provide them with details of how to book a Pension Wise appointment.

Question 2. Do you agree with our proposed approach to appointment bookings? If not, what changes do you consider necessary?

Opting Out of Guidance

We want taking pensions guidance to be presented as a normal part of the application process and for it to be an active choice to opt out of receiving pensions guidance. As such, in draft regulation 18C(7) we are also proposing that the opt-out process must be done through a separate, active communication with the trustees or managers if a specified exemption does not apply. This could be a phone call, email, letter, postal form, or digital form which is separate from the individual’s initial contact to access (or transfer for the purpose of accessing) their pension benefits and from the providers’ offer to book a Pension Wise appointment. The intention is to ensure that due thought is given to the benefits of pensions guidance before accessing pension benefits and that any decision to opt out of guidance is a considered one.

Where a relevant beneficiary declines the offer to have a Pension Wise appointment booked for them, we want the trustees or managers to provide them with details of how to book a Pension Wise appointment themselves, and details on how to complete the opt out.

Where a member contacts trustees or managers after having been nudged but has not yet opted out of receiving appropriate pensions guidance and does not state they have received appropriate pensions guidance, we want the scheme to offer to book a Pension Wise appointment again and reiterate that if a customer wishes to opt out they will need to do so in a separate interaction.

Question 3. Do you agree with proposed approach to requiring an opt out in a separate interaction? If not, what changes do you consider necessary?

Trustees and Managers Cannot Proceed with the Application until Members Have Opted Out or Received Guidance

In draft regulation 18C(5), we propose to ensure trustees and managers do not proceed with the application until they have received confirmation that a relevant beneficiary has either opted out or received appropriate pensions guidance.

This means that, until a beneficiary confirms they have received Pension Wise guidance or opts out of receiving such guidance, trustees and managers should not take additional steps to progress their application. We believe this would prevent trustees and managers from sending out an application form or giving a quote. We do not believe this would prevent trustees and managers from sending out additional information packs or giving generic information on decumulation options.

Question 4. Do you agree with our proposed approach to prevent trustees and managers proceeding with the application until they are in receipt of confirmation that the individual has opted-out or received appropriate pensions guidance? If not, what changes do you consider necessary?

Exemptions

We wish to exempt, in draft regulation 18C(11)(a) those who have already received Pension Wise guidance within the last 12 months, or received regulated financial advice on the proposed transaction, from the requirement to opt out in a separate interaction.

We also propose to exempt, in draft regulation 18C(11)(b) those who are applying to access their pension benefits as a Serious Ill Health Lump Sum, as defined in the Finance Act 2004. We believe that trustees and managers will be aware if a beneficiary intends to access their pension benefits as a Serious Ill Health Lump Sum at an early stage in the application process, and so will not be required to ask this as proposed in our draft regulations.

In both of the above cases, we want trustees and managers to accept self-reported evidence of meeting an exemption, such as the beneficiary providing written or oral confirmation that they believe they meet one of these criteria.

We do not propose to include an exemption for small pots. We do not want to set a level at which we imply appropriate pensions guidance would not be beneficial. A small pot may also not be a beneficiary’s only pension provision, and Pension Wise could help a beneficiary to understand their options for their overall pension wealth. We are interested to hear if stakeholders believe such an exemption is necessary, why it is necessary, and at what level this should be set.

Question 5. Are the proposed exemptions sufficient? If not, what changes do you consider necessary?

Question 6. Is an exemption for small pots necessary? If so, how should a small pot be defined?

Question 7. Will our proposed exemption for those accessing their pension benefits as a Serious Ill Health Lump Sum cover all those who should be exempted from the enhanced opt out on ill health grounds? If not, what changes do you consider necessary?

Record Keeping

Draft regulation 18D provides for trustees’ and managers’ record keeping duties. The proposal is to require trustees and managers to record when a relevant beneficiary confirms they have received appropriate pensions guidance, after having being nudged. The proposal is also to place a duty on them to record when beneficiaries) opt out of receiving appropriate pensions guidance. We wish them to record the opt out in two ways. Firstly, when they receive a separate opt out notification after an individual has been nudged. Secondly, we wish trustees and managers to record when they accept an immediate opt out, due to an individual being exempt from the requirement to opt out in a separate interaction. We do not propose to require trustees and managers to record the reason why the individuals in question are exempt.

Question 8. Do you believe our proposed approach to record keeping is proportionate? If not, what changes do you consider necessary?

The Nudge and Scams Guidance

The government is currently consulting on draft regulations on transfer of pension benefits between schemes which will, if brought into force, place a duty on the trustees and managers of schemes in scope to refer customers to a scams guidance appointment, provided by MaPS, if a proposed transfer is deemed to be a potential scam risk. Under the proposed Stronger Nudge regulations, because we have not specified exactly when the Stronger Nudge must occur, it is possible that members will be directed to MaPS for a scams appointment and a Pension Wise appointment within the same transaction. We have considered options to avoid this by placing more rigid requirements on when the Stronger Nudge must be delivered. However, we believe it is better to give trustees and managers freedom to consider how they can appropriately explain the two guidance appointments to the member, rather than proposing to use regulations to achieve this.

Question 9. Do you agree with our proposed approach for coordinating the Stronger Nudge and Scams Guidance appointments? If not, what changes do you consider necessary?

The Nudge and Existing Signposting Provisions

In draft regulation 3, paragraphs (4) – (5), our proposal is to disapply the requirement to signpost to Pension Wise guidance in regulations 18A and 18B of the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013, where the stronger nudge provisions in draft regulation 18C applies. We believe that the nudge to Pension Wise guidance satisfies the requirement to signpost to Pension Wise described in part 1 of Schedule 10 to the Disclosure Regulations 2013, and want to prevent trustees and managers from having to nudge to Pension Wise guidance and signpost to Pension Wise guidance in the same interaction. Trustees and managers will still have a duty to signpost to Pension Wise guidance in all other cases set out in the Disclosure Regulations 2013, such as when a member reaches retirement age or normal minimum pension age, or any other case where draft regulation 18C does not apply. We believe our proposed approach outlined in the draft Regulations achieves this goal.

We are proposing an additional amendment to regulation 4(7) of the Disclosure Regulations 2013 to disapply the requirement to provide a postal or electronic address for further communication, when the nudge to pension guidance is delivered orally.

Schemes currently have a duty, under regulation 6 of the Disclosure Regulations 2013 and outlined in paragraph 4A of schedule 2, that provides for schemes to provide a statement explaining the circumstances in which flexible benefits can be transferred out of the scheme. If the draft Regulations are adopted, schemes may need to update the information they give under this regulation, to reflect that a transfer for the purpose of accessing flexible benefits cannot proceed until the beneficiary has received or opted out of receiving appropriate pensions guidance.

Question 10. Do you foresee any problems with the interaction between the Stronger Nudge and existing signposting provisions? If so, what changes do you consider necessary?

Pensions Guidance

We also propose to use the draft Regulations to update the definition of the term ‘pensions guidance’ set out in regulation 2 of the Disclosure Regulations 2013 (see draft regulation 3(2)). Currently the Disclosure Regulations 2013 define that term ‘pensions guidance’ to mean guidance given by a designated guidance provider. Our proposal is to define the term ‘pensions guidance’ as information or guidance provided by any person in pursuance of the requirements mentioned in section 4 of the Financial Guidance and Claims Act 2018.

The Nudge and Statutory Right to Transfer

Currently, trustees and managers are required to fulfil a request to transfer pension benefits from one scheme to another within 6 months of receipt of the member’s transfer application. However, we do not want trustees and managers to proceed with an application unless the proposed requirements to nudge to guidance set out in the draft Regulations have been fulfilled. Draft regulation 2 proposes an amendment to the Pension Schemes Act 1993 and Financial Services and Markets Act 2000, such that trustees and managers would be unable to proceed with a transfer application to which the Nudge requirements apply until requirements specified in draft regulation 18C have been fulfilled.

Question 11. Are you content that regulation 2 successfully achieves its purpose? If not, what problems do you foresee and what changes do you consider necessary?

Costs of Transition

We are mindful of the need to strike a balance between encouraging scheme members to receive guidance on their pension benefits before they access to ensure they are informed on their options, without placing unnecessary burdens on pension trustees and managers which may impact on members through increased administration costs.

We anticipate that additional costs will be incurred in the time for trustees and managers to deliver the stronger nudge and then either book a beneficiary an appointment or receive the opt-out for those who aren’t exempt. There may also be additional costs to record a beneficiary’s decision. We anticipate these costs may vary depending on the size of a scheme and the number of members.

To help inform this consultation we would therefore welcome information on the following questions:

Question 12. What do you anticipate will be the one-off impact of implementing the Stronger Nudge in to each channel (phone/post/digital) you offer? Where costs are incurred, please provide an estimate and any information you feel would be useful to us in understanding these costs.

Question 13. What do you anticipate will be the on-going impact of implementing the Stronger Nudge in to each channel (phone/post/digital) you offer? Where costs are incurred, please provide an estimate and any information you feel would be useful to us in understanding these costs.

Question 14. Where costs are incurred, would you expect the cost to be absorbed, passed on to employers, or passed on to individual members?

Question 15. Do you anticipate any benefits to your business from implementing the Stronger Nudge? Please provide a monetary value where possible.

Question 16. Do you anticipate any wider non-monetised impacts from the Stronger Nudge?

Regulatory burden and costs to Industry

We have considered the inclusion of a statutory review clause. A statutory review clause will often be appropriate when there is expected to be a significant annualised net impact on business (greater than +/- £5 million net annualised). We currently believe a statutory review provision would be inappropriate given current evidence on the expected cost to business impacts of the proposed regulations. We also do not believe there are other factors that would make a statutory review clause particularly appropriate. However, we are conducting an impact assessment, consulting with stakeholders to improve our evidence, and will take into account information on costs provided by the consultation, and will review this decision if necessary.

Question 17. Do you believe there are reasons to include a statutory review provision in the proposed regulations?

Additional Questions

Question 18. Do you consider the proposed regulations achieve the policy intent?

Question 19. Do you foresee any unintended consequences in our proposed approach?

Further evidence, analysis and research

We would welcome any further evidence or analysis which you would like to share about the issues under discussion in this consultation.

Equality Duty

Under the Equality Act 2010, public bodies have a duty to give due regard to the needs of people with ‘protected characteristics’. The Equality Duty covers the protected characteristics of:

age
disability
gender reassignment
pregnancy and maternity
race
religion or belief
sex
sexual orientation
marriage and civil partnership – in respect of eliminating unlawful discrimination only

Paying ‘due regard’ means that, in our roles as policy makers, we are required to consciously think about the three aims of the Equality Duty:

eliminate unlawful direct or indirect discrimination, harassment and victimisation and other conduct prohibited by the Act
advance equality of opportunity between people who share a protected characteristic and those who do not share it
foster good relations between people who share a protected characteristic and those who do not share it

As part of this consultation we would therefore welcome views on the impact of these proposals on protected groups, and how any negative effects may be mitigated, including the impact on disabled people and the provision of information in alternative formats.

Question 20. Do you have any comments on the impact of our proposals on protected groups and/or views on how any negative effects may be mitigated?

Question 6

List of consultation questions

Accepted Answer

Question 1

Do you agree with our proposed approach to defining when the Stronger Nudge should be delivered? If not, what changes do you consider necessary?

Question 2

Do you agree with our proposed approach to appointment bookings? If not, what changes do you consider necessary?

Question 3

Do you agree with our proposed approach to requiring an opt out in a separate interaction? If not, what changes do you consider necessary?

Question 4

Do you agree with our proposed approach to prevent trustees and managers proceeding with the application until they are in receipt of confirmation that the individual has opted-out or received appropriate pensions guidance? If not, what changes do you consider necessary?

Question 5

Are the proposed exemptions sufficient? If not, what changes do you consider necessary?

Question 6

Is an exemption for small pots necessary? If so, how should a small pot be defined?

Question 7

Will our proposed exemption for those accessing their pension as a Serious Ill Health Lump Sum cover all those who should be exempted from the enhanced opt out on health grounds? If not, what changes do you consider necessary?

Question 8

Do you believe our proposed approach to record keeping is proportionate? If not, what changes do you consider necessary?

Question 9

Do you agree with our proposed approach for coordinating the Stronger Nudge and Scams Guidance appointments? If not, what changes do you consider necessary?

Question 10

Do you foresee any problems with the interaction between the Stronger Nudge and existing signposting provisions? If so, what changes do you consider necessary?

Question 11

Are you content that regulation 2 successfully achieves its purpose? If not, what problems do you foresee and what changes do you consider necessary?

Question 12

What do you anticipate will be the one-off impact of implementing the Stronger Nudge in to each channel (phone/post/digital) you offer? Where costs are incurred, please provide an estimate and any information you feel would be useful to us in understanding these costs.

Question 13

What do you anticipate will be the on-going impact of implementing the Stronger Nudge in to each channel (phone/post/digital) you offer? Where costs are incurred, please provide an estimate and any information you feel would be useful to us in understanding these costs.

Question 14

Where costs are incurred, would you expect the cost to be absorbed, passed on to employers, or passed on to individual members?

Question 15

Do you anticipate any benefits to your business from implementing the Stronger Nudge? Please provide a monetary value where possible.

Question 16

Do you anticipate any wider non-monetised impacts from the Stronger Nudge?

Question 17

Do you believe there are reasons to include a statutory review provision in the proposed regulations?

Question 18

Do you consider the proposed regulations achieve the policy intent?

Question 19

Do you foresee any unintended consequences in our proposed approach?

Question 20

Do you have any comments on the impact of our proposals on protected groups and/or views on how any negative effects may be mitigated?

MaPS: Pension Wise Service Evaluation 2019/20 ↩
MaPS Pensions Guidance Data Interim Report February 2021 ↩

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