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Dealing with 2012 – Automatic Enrolment Hymans Robertson LLP and Hymans Robertson Financial Services LLP are authorised and regulated by the Financial Services Authority Eddie McAuley Hymans Robertson

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Page 1: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Dealing with 2012 –Automatic Enrolment

Hymans Robertson LLP and Hymans Robertson Financial Services LLP are

authorised and regulated by the Financial Services Authority

Eddie McAuley

Hymans Robertson

Page 2: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Auto-Enrolment – it’s easy...............

2

Page 3: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Why reform workplace pensions?A history lesson.....

2003 – 2005 Pensions Commission reviewed the

UK pension system and made recommendations.

Pension Commission found that:

Up to 12 million people are not saving enough for

3

Up to 12 million people are not saving enough for

retirement

State Pension could not meet this challenge

Taking no action was not an option

Page 4: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

The Pension Commission recommendations

Fairer, more generous state pension coverage.

System of automatic enrolment into pension

saving

Minimum employer contribution to workers

4

Minimum employer contribution to workers

pensions

New, national pension scheme designed to

provide a simple and low cost way of saving for

low to moderate earners.

PENSIONS ACT 2008

Page 5: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Target population pre 2012

Currently a Pension Scheme Member

Eligible for Auto-Enrolment in 2012 (Based on Pensions Act 2008)

Numbers 5 / 6 million 10 / 11 million

Household Wealth £300k median £130k median

5

Household Wealth £300k median £130k median

Employer Size 69% work for employers

with > 250 employees

33% work for employers

with < 19 employees

Page 6: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

6

NEST VIDEO

Page 7: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

What? - Minimum contribution levels

Minimum contribution of 8 per cent

of qualifying earnings (between

£5,035 and £33,540, Pensions Act

2008)

Employer must contribute at least

1%Tax relief

7

Employer must contribute at least

3 per cent

Can choose to contribute more if

they wish

Jobholder can also contribute more

DB: 1/80th contracted out or 1/120th

contracted in

4%Jobholder3%

Employer

Page 8: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

When? DC staging and phasing plans

1% employer contribution2%

employerSteady state

5% jobholder

2% total contribution 5% totalSteady state

3% employer

Phasing

3% employer

8% total

8

DB, Hybrid – autoenrolment Oct 2016, no phasing

Oct

2012

Aug

2014

Mar

2016

Oct

2016

Oct

2017

Large

employers

Medium

employersSmall/micro employers

New born

PAYEsStaging

Page 9: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Then the world changed.......

Financial crisis.

Change in political environment - Government

went from red to blue (and gold).

9

Despite the previous broad political consensus a

review of automatic enrolment was announced

on 24th June 2010.

Page 10: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Review objectives

“...scope of it (automatic enrolment) and whether

a new national pension scheme (NEST) needs to

be put in place for it to work.”

10

Review and conclusions addressed 4 broad

questions

Page 11: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Is there a case for excluding employees below a particular threshold?

Review rejected a big increase in earnings

threshold

Review concluded that auto-enrolment should apply to those over the tax threshold on

11

apply to those over the tax threshold on earnings above the NI primary threshold.

Page 12: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Is there a case for excluding any employers?

Higher costs for micro employers. However.....

Excluding 800,000 micro employers would be hard

Identifying via PAYE

Creates barriers to growth

12

Creates barriers to growth

Competitive distortions

Not gender neutral

Review also felt it had the potential to undermine the policy

Page 13: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Would any changes to proposed regulations, enhance the policy?

A range of regulatory issues identified

Flagging of NEST for small employers

Opt out before auto enrolment

13

Opt out before auto enrolment

Flexibility over enrolment dates

Re-enrolment

Waiting periods

Certification

Page 14: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Certification

14

Page 15: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Is NEST necessary for the successful implementation of automatic enrolment?

NEST would not be needed and the Market could provide if.........

Small employers excluded

Earnings threshold to at least £10k

15

Earnings threshold to at least £10k

More time available

Higher charges acceptable

.....but Review believes it is needed for the intended audience.

Page 16: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

15 Recommendations from the Review

• Accepted as a package

16

• Now with DWP

• To legislate this year

Page 17: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

So where will that leave us?

Pensions Act 2008 Making AutomaticEnrolment Work

Eligible Jobholders Aged between 22 and

SPA and earnings in

excess of £5732 (in

today’s prices)

Aged between 22 and

SPA and earnings

above income tax

threshold (£7495 in

2011/12)

17

Auto Enrolment Day 1 After 3 months service

Contribution Level Phased in No Change

Contribution Band £5732 to £38185 (in

today’s prices)

£5715 (linked to NI

primary threshold) to

£38185 (in today’s

prices)

Staging Dates Start 1st November

2012

No change (except

largest can start w.e.f.

July 2012).

Page 18: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Getting ready for 2012

Defining a good outcome

Plan design and financial analysis

Assess delivery vehicle options

18

Assess delivery vehicle options

Design and testing of admin process

Communications

Page 19: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

2012 – Employer Options

Choices for employers

19

Existing

DB and DC

schemes

New DC

automatic

enrolment

schemes

Existing/new

NEST

NEST

Associate/entry level or base

scheme

Sole scheme

+

Page 20: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Plan design and financial analysis

Contribution structure

Current state – financial projections

Alternative designs

Design considerations

20

Design considerations

Uniformity of approach

Transitional period

Pensionable pay definition

Competitors / Unions

Ease of certification

Page 21: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Delivery vehicle assessment

Considerations

Efficient and scalable

Cost effective

Employer duties

DC Delivery

Unbundled Bundled

21

Employer duties

Member experience

Short-service refunds

Future proofing

Contract Trust

NESTMaster Trust

Trust

In-house Outsourced

Page 22: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

22

Page 23: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Admin process – design and testing

23

Page 24: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

24

Tom’s Story

Page 25: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Capability assessment

En

rolm

en

t

info

rmati

on

Op

t o

uts

On-line access

Policy documents and statements

Account and fund

management

Jobholders

PensionAdministrator

HR / Personnel

Employment

Contracts

25

New Joiner file

Monthly payment file

Opt out file

Opt out file

Payment file

New joiner data

Payroll

Jo

iners

& L

eav

ers

Sala

ry a

nd

wag

e

info

rmati

on

Ho

urs

wo

rked

/

ov

ert

ime e

tc.

Auto-enrolmentfunction

Page 26: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Administration considerations

Design of processes

Apportionment of process responsibility

Interface with providers

Timing

Tie in with communications

26

Tie in with communications

Record keeping requirements

System capabilities

Diary function

Record keeping

Reporting

Provider support

Page 27: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Communications

Compliance or benefit?

Branding?

Media?

27

Detailed content

Page 28: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Enabling good member outcomes in DC

Requires success in...

Contribution decisions

Investment decisions

28

Administration

Protection of assets

Value for money

Decumulation decisions

Page 29: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Market segmentation

Occupational

Large

Multi-employer

Small unbundled

Personal

Advised and engaged

employer

Advised and disengaged

29

Small unbundled

Small bundled

Advised and disengaged

employer

Unadvised employer

Accountability

Page 30: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Thank You

30

Any questions?

Page 31: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

ACA Regional Meeting - Glasgow

HuttonThe beginning of the end, or the end of the beginning?

March 2011

Graeme Muir FFA

Page 32: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Agenda

• Quick reminder

– Hutton’s remit

– Initial report

• Final report recommendations

www.barnett -waddingham.co.uk Slide 32

• Final report recommendations

• Some missed tricks?

• Questions and discussion

Page 33: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Hutton’s remit

• To conduct a fundamental review of public service pension provision and make recommendations on pension arrangements that are

www.barnett -waddingham.co.uk Slide 33

arrangements that are

• Sustainable and affordable in the long term

• Fair to workforce and taxpayers

• Consistent with the fiscal challenges

• Protect “accrued rights”

Page 34: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Have regard to

• Disparity with private sector (pensions envy)

• Assist in recruitment and retention

• Fair across the workforce

• How risks should be shared between

www.barnett -waddingham.co.uk Slide 34

• How risks should be shared between employee and tax payers

• Which employers allowed in

• Transition issues

• Encourage adequate saving and longer working lives

Page 35: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Initial report – key messages• Fairer balance required

– current taxpayers and public sector employees– current and future generations

• Increase in member contribution rates– Targeted at high earners

www.barnett -waddingham.co.uk Slide 35

– Targeted at high earners

• Public sector pensions are not gold plated

• No race to the bottom– Public service pensions should become

benchmark for the private sector to aim for

• Final salary pensions are no longer a robust and fair mechanism

Page 36: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Initial report – key messages• Need model that provides

– A fair sharing of risk between the employer and employee

– And adequate pensions for members

• DC is not the answer

www.barnett -waddingham.co.uk Slide 36

• DC is not the answer

• Future pension ages need to reflect longevity changes

• Retain unfunded nature of existing schemes

• No reason to de-fund existing funded schemes such as the LGPS

• Final report is to consider alternative structures such as career average, collective DC and hybrids

Page 37: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Final report – call for evidence

• 25 Questions

• Key themes

– Risk sharing

www.barnett -waddingham.co.uk Slide 37

– Adequacy of benefits

– Employee Understanding and Choice

– Transferability

– Costs and efficiency

– Plurality of schemes

– Transition

Page 38: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Some of final report’s 27 recommendations

• Career Average for future service– Earnings revaluation rather than CPI

• Maintain final salary basis for past service

• Single benefit design across income range

www.barnett -waddingham.co.uk Slide 38

• Single benefit design across income range

• Pay more as you earn more

• Pension age linked to State Pension Age

• “Public service staff” only

• Disappointingly no real risk sharing– Continue with cap and share

• Improved governance and transparency

Page 39: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Key challenge (for Government)• Employees to pay more for less

– Lower pensions for most

– Higher employee contributions

• Enormous care required to avoid opt out

www.barnett -waddingham.co.uk Slide 39

– Increase Government cost for unfunded schemes

– Increase burden on future tax payers

• LGPS already had earnings related contributions

– The more you earn the more you pay

– Ahead of the game

• Chancellor decides an extra 3% required

– Why?

Page 40: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Unfunded Scheme Cashflows

www.barnett -waddingham.co.uk Slide 40

Page 41: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Unfunded Scheme Cashflows

www.barnett -waddingham.co.uk Slide 41

Page 42: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

What does this mean for LGPS?

www.barnett -waddingham.co.uk Slide 42

Page 43: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

What does this mean for LGPS?

• Typical LGPS Fund

100%

Cumulative Pay DistributionPercentile FTE PTE

10% £14,309 £3,486

25% £16,393 £8,285

www.barnett -waddingham.co.uk Slide 43

0%

25%

50%

75%

25% £16,393 £8,285

50% £20,647 £16,718

75% £28,636 £25,557

90% £37,685 £35,718

Average £23,961 £18,555

Median £20,647 £16,718

• If £24k is starting point then extra 3% to be funded by

just over a third of membership

Page 44: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

What does this mean for LGPS?

0%

2%

4%

6%

8%

10%

12%

14%

16%

Contribution Scales

www.barnett -waddingham.co.uk Slide 44

• Too much to ask?

• Other ways?

– Increasing retirement age to 66 would reduce 3% to extra

1.5% ish

• Lower threshold to £18k?

0%

Current Possible?

Page 45: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Hutton missed a trick or two?

• Average earnings revaluation– Bigger pensions for low flyers

– Lower pensions for high fliers

– Consistent with GDP and affordability

www.barnett -waddingham.co.uk Slide 45

– Consistent with GDP and affordability

• CPI revaluation (with higher accrual rate)– Bigger pensions for leavers

– Lower pensions for stayers

– Equal treatment of leavers and stayers

– More pension (initially) for more contribution

Page 46: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Hutton missed a trick or two?• Accrued rights

• Maintaining final salary link– “Safe” definition of accrued rights– More complexity

• Average earnings or CPI increase?

www.barnett -waddingham.co.uk Slide 46

• Average earnings or CPI increase?– More than pay increases short term– Simpler– Less costly long term if CPI

• Really tricky stuff to follow– Agreeing the detail.....– ...by 2015?

Page 47: Dealing with 2012 – Automatic Enrolment · Dealing with 2012 – Automatic Enrolment ... 1% employer contribution 2% employer Steady state 5% jobholder ... Joiners & Leavers Salary

Questions and DiscussionQuestions and Discussion

Graeme Muir FFA