CP24/16 response form

We are asking for comments on this Consultation Paper by 17 October 2024.

Please use this online form or alternatively email us or write to: VFM Policy Team, FCA, 12 Endeavour Square, London E20 1JN.

We make all responses to formal consultation public unless you request otherwise. Responses will also be shared with the Pensions Regulator and the Government. Let us know below if you don't want your participation and/or response to be made public.

We will not regard a standard confidentiality statement in an email message as a request for non-disclosure.

We are obliged to list the names of respondents where those respondent have consented to the publication of their name, which is a matter separate from any request for the content of a response to be kept confidential.

Your response

Chapter 3: Scope and thresholds

Q1:Do you agree with the proposed scope, thresholds and exclusions? Why or why not? If not, what alternatives would you suggest?

Q2: Do you agree with the proposed application of the 80% threshold to determine whether legacy arrangements are quasi-defaults? Why or why not? If not, what would you propose?

Q3: Do you agree with the proposed 1,000 member threshold? Why or why not? Do you think there are risks around this level, for example excluding too many savers? If you don’t agree, what would you suggest?

Chapter 4: Investment performance

Q4: Do you agree with the proposed investment performance metrics? Why or why not? If not, what alternatives would you suggest?

Q5: Do you agree with the proposed calculation methodology? Why or why not? If not, what alternative methodology would you suggest?

Q6: Do you agree with the proposed requirement for chain-linking? Why or why not? If not, what would you propose?

Q7: Do you agree with the approach to in-scope legacy arrangement features? Why or why not? If not, what alternative approach would you suggest?

Q8: Do you have further feedback on the incorporation of forward-looking metrics within the Framework? If included, how prescriptive do you think we should be on assumptions and methodology, and what would you propose?

Chapter 5: Asset allocation disclosures

Q9: Do you agree with the approach to asset allocation disclosures? Why or why not? If not, what would you suggest? Do you think asset allocation disclosures will support better decisions in the interests of savers?

Q10: Do you agree that asset allocation disclosures should be limited to firm designed in scope arrangements only? Why or why not? If not, how would you broaden this requirement and to what arrangements?

Q11: Do you agree that we should require the disclosure of the overall asset allocation of the whole arrangement, as well as for the YTR points? Will this be of use to firms, and will it be an added burden to disclose?

Q12: Do you agree with the proposed definitions for UK assets? If not, what would you propose?

Q13: Do you think we should break out ‘Quoted but not listed’ (eg AIM) and if so, how would that be useful? Would there be additional cost to doing this and can you indicate how much?

Chapter 6: Costs and charges

Q14: Do you agree with the proposed costs and charges metrics? Why or why not? If not, what alternative metrics would you suggest?

Q15: Do you agree that historic costs and charges information should be calculated in the first year of implementation, rather than waiting for this data to build over time? Please explain your answer. If you do not agree with either approach, what alternative would you suggest?

Q16: Do you agree with our proposed approach to converting combination charging structures to annual percentage charges? Why or why not? If not, what alternative would you suggest?

Q17: Do you agree with the proposed approach to unbundling? Why or why not? If not, what alternative would you suggest?

Q18: Do you agree with the proposed approach to multi-employer cohorts? Why or why not? If not, what alternative would you suggest?

Chapter 7: Quality of services

Q19: Do you agree with the proposals on scope? If not, what alternative approach would you suggest?

Q20: Do you agree with the five proposed indicators of service quality? If not, what alternatives would you suggest, with metrics?

Q21: For each of the five proposed indicators, do you agree with the proposed metrics for measuring these? If not, what metrics would you suggest? We would particularly welcome views on these metrics.

Q22: Do you agree with our proposal to include a non-employer related email address and phone number when defining common data? If you don’t agree, please explain why not.

Q23: Do you agree with our proposals for an event-based member satisfaction survey? We would particularly welcome feedback on the trigger events and proposed questions.

Q24: Do you think that a firm should be able to provide a saver specific view of access to tools and saver use across its digital offerings? If not, what metric would you suggest?

Chapter 8: Assessment and outcomes

Q25: Do you agree with our proposed conditions for the selection of comparator arrangements? If not, what would you suggest?

Q26: Do you agree with the assessment process we have outlined above? Do you have views on what should be considered a material difference in value relative to comparator arrangements? If you think that RAG ratings will not be sufficiently comparable, what refinements would you suggest?

Q27: Do you agree that a multi-employer arrangement should be rated amber if it fails to deliver value for a material number of savers in relation to at least one employer cohort? If not, what would you suggest?

Q28: Do you have any concerns about our proposals for assessing bespoke in-scope arrangements? If you do have concerns, please explain them. If you anticipate negative effects, what can be done to address those?

Q29: Do you agree that IGCs should consider and report on whether their firm’s current scale may prevent it from offering value to savers? If not, what would you propose?

Q30: Do you agree that IGCs should consider how ESG considerations have been taken into account across firm-designed in-scope arrangement? Do you think this is sufficient and if not, what would you suggest?

Chapter 9: Actions for arrangements offering poor value

Q31: Do you agree that firms should inform employers of amber and red ratings and proposed steps to address the poor value, where an employer’s current and past employees are at risk? If not, why not and what would you suggest?

Q32: Do you agree that firms should not be allowed to accept business from new employers into an arrangement rated amber or red? If not, why not and what would you suggest?

Q33: Do you agree with our proposed actions and timings for firms with arrangements rated amber or red? If not, what alternative approach would you suggest?

Q34: Do you think that we should require firms to transfer savers out of red-rated arrangements, subject to enabling legislative changes? What are the costs associated with the proposed actions and are they proportionate? If you don’t agree with our proposed actions, what would you suggest?

Q35: Do you think that requiring transfer from arrangements could benefit one group of savers to the potential detriment of others? If so, please explain and can you suggest an approach that doesn’t risk detriment to some savers?

Chapter 10: Disclosure requirements

Q36: Do you agree with our proposals for how Chair’s annual reports should be expanded to include the results of VFM assessments? Are there any proposed elements that in practice would not be useful?

Q37: Do you agree with requiring a narrative explanation for the RAG rating for all firm-designed in-scope arrangements including those rated green? Do you think this requirement should be limited to amber and red ratings?

Q38: Should IGC Chairs be required to produce a plain-language summary of their reports?

Q39: Do you agree with the need for a features table and the contents we are proposing? Are there changes we should consider? Do you think that the disclosure requirements for bespoke arrangements should be different and if so, in what way?

Q40: Do you agree with our proposed approach to publication including requiring publication of a flat file? What other solutions would best support the aims of the Framework in due course?

Q41: Do you think we should require machine-readable RAG ratings and potentially other information from IGC Chair’s annual report? What do you think are the benefits and costs or possible negative effects of this?

Chapter 11: Amendments to current Handbook requirements

Q42: Do you agree that the proposed new rules should be under existing requirements for IGCs, with carve outs as appropriate? If not, what alternative approach would you suggest?

Q43: Do you have suggestions for further amendments to existing requirements for IGCs and if so, why do you think these are needed?

Q44: Do you agree that we should exempt “accidental workplace SIPPs” from COBS 19.5 and the requirement for an IGC or GAA? If not, what would you propose?

Chapter 12: Future development

Q45: How do you think the use of data will evolve and what other measures may be needed?

Q46: We invite views on the roll out, evolution and future phases of the framework, over what time periods, and on the correct sequencing of these developments.

Contact us

What we do

How we regulate

How we operate

Who we are

Join us

Firms overview

Regulated firms

Tasks for firms

Primary markets

Markets policy

Regulated markets

Market abuse

Short selling

Transaction reporting

Our Consumer section

Your rights

Complaints

Scams

Report a firm

Sign up to receive daily alerts on the warnings we issue

Media centre