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TISA comments on the FCA’s CP21/32: Improving outcomes in non-workplace pensions consultation

February 18, 2022

Renny Biggins, Head of Retirement at The Investing and Saving Alliance said: “TISA welcomes the FCA’s efforts to improve outcomes for consumers saving into non-workplace pensions. There has recently been a strong focus on the accumulation phase of workplace pensions, with new regulation designed to improve Value for Money for scheme members. Although there are distinct differences, it is important that there remains a focus on non-workplace schemes, to ensure that similar protections and support are provided to the non-advised, where potential harms are identified.

“Given the outputs from FCA research commissioned for this purpose, we fully support the fundamental principles of simplifying the investment decision-making process and we believe that ideally, consumer journeys should be product agnostic as the need for guidance on investments is not determined by the tax wrapper the money is invested in.  

“We do need to be mindful that pension schemes and specific pension products attract different types of consumers. The typical client profile is therefore likely to vary significantly across all non-workplace schemes. While the concurrent new Consumer Duty proposals cannot be considered a panacea for good consumer outcomes, they should provide the confidence to policymakers to enable complimentary proposals to recognise these profile differences and be less prescriptive in nature.  

“We need to build on existing momentum alongside other engagement and support initiatives. The development of an enhanced guidance framework within the regulatory regime, alongside other initiatives, would help to ensure retirees are motivated and aware of their options. This will help make sure they have a sufficient pension pot when they reach retirement.” 

Contact:  

Kuba Stawiski 

Cicero/AMO   

07856031906    

kuba.stawiski@cicero-group.com   

Notes for Editors

tisa@cicero-group.com

07856031906


The Investing and Saving Alliance (TISA) is a unique, rapidly growing membership organisation for UK financial services.   

Our ambition is to improve the financial wellbeing of all UK consumers. We do this by focusing the convening the power of our broad industry membership base around the key issues to deliver practical solutionsand devise innovative, evidence-based strategic proposals for government, policy makers and regulators that address major consumer issues.   

TISA membership is representative of all sectors of the financial services industry.   We have over 200-member firms involved in the supply and distribution of savings, investment products and associated services, including the UK’s major investment managers, retail banks, online platforms, insurance companies, pension providers, distributors, building societies, wealth managers, third party administrators, Fintech businesses, financial consultants, financial advisers, industry infrastructure providers and stockbrokers.   

As consumers, the financial services industry and the economy react to and recover from the effects of the pandemic, the importance of the three key pillars of work that TISA prioritises has never been more apparent:  

  • Strategic policy initiatives that influence policymakers regarding the financial wellbeing of UK consumers & thereby enhancing the environment within which the industry operates in the key areas of consumer guidance, retirement planning, later lifetime lending, vulnerable customers, financial education, savings and investments.  
  • TISA is recognised for the expert technical support provided to members on a range of operational and regulatory issues targeted at improving infrastructure and processes, establishing standards of good practice and the interpretation and implementation of new rules and regulations covering MiFID II, CASS, ESG/RSI, operational resilience, Cyber Risk, SM&CR and a range of other areas.  
  • Digital transformation initiatives that are driving ground-breaking innovation and the development of industry infrastructure for greater operational effectiveness and revenue promoting opportunity for firms.  TISA has become a major industry delivery organisation for consumer focused, digital industry infrastructure initiatives – TISAtech (a digital marketplace that brings together financial institutions and FinTechs for greater collaboration and innovation) and TURN (TISA Universal Reporting Network – a digital platform providing a secure data exchange for financial services using blockchain technology) – alongside projects Digital ID and Open Savings & Investment. This reflects TISA’s commitment to open standards and independent governance.