"Three necessary actions prior to launch of Ireland's auto-enrolment"

Brendan Burgess

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6th Ordinary Meeting of Session 176

& Annual General Meeting

Three Necessary Actions Prior to Launch of Ireland’s Auto-Enrolment Retirement Saving Plan

Hybrid Meeting
RDS Merrion Room
Thursday May 25th at 5.30pm
Register here

The Statistical & Social Inquiry Society of Ireland invites you to attend the 6th Ordinary Meeting of its 176th session. Shane Whelan and Maeve Hally (UCD School of Mathematics and Statistics) will present a paper entitled "Three Necessary Actions Prior to Launch of Ireland’s Auto-Enrolment Retirement Saving Plan". An abstract is given below and a draft paper is available www.ssisi.ie

Abstract: The proposed Automatic Enrolment Retirement Saving (AE) Plan will fail to make a significant impact on pensions in Ireland unless three actions precede its introduction. First, we show that the existing tax reliefs for other pension arrangements are considerably more valuable than the 33% subsidy to contributions to the AE Plan for higher rate taxpayers. To create a level playing field for the new AE Plan, we recommend qualifying contribution levels be equalised and that tax relief on contributions to other pension arrangements be abolished, replaced with the common 33% subsidy. Second, a key selling point of the AE Plan is its low charges, considerably lower than individual private plans. However, low charges are not a particularly strong force shaping the pension landscape, even though such efficiencies accumulate to deliver materially higher pensions over the long term of pension savings. We recommend that selling practices of pensions are better aligned to the interests of the pension saver. This can be achieved by banning commission on pension products and by requiring illustrations of the size of the pension fund at retirement to be explicitly compared with that expected from the AE Plan. Third, the new AE Plan has the potential to solve the legacy issues that the run-off of defined benefit schemes poses to the State and to sponsoring employers. We propose that the AE Plan be open to transfers from such schemes, to help manage the contingent liability of the State and to help build a partnership in pensions with employers. Indeed, the AE Plan should be open to transfers from any existing pension arrangement, if it is in the best interest of the individual. While these three reforms will assist in preventing the failure of the AE Plan, alone they may not be sufficient to ensure its success. The introduction of the AE Plan is obviously good for pension savers but it also has the potential for disruptive change in the pension industry, which to date has been successful in resisting reform.

The meeting will have a hybrid format, with an opportunity to attend physically at the RDS or online. The physical meeting will be held in the Merrion Room at the RDS, which you can access through the RDS Members Club (Merrion Road Entrance, Geo Code: 8QHC+86 Dublin). There is free parking for attendees. While the meeting will start at 5:30, please join us for Tea & Coffee 15 minutes beforehand.

As noted at our last meeting, this final meeting of the 176 session is also our AGM, and as such, the presentation will be preceded by the election of Council Members.

As ever, non-members are welcome to attend and participate in the discussion and we hope that you would circulate to others who may be interested so that they may also register their interest and attend on the day.



Kind regards,
John Evans (Honorary Secretary)
 
Attached is the submission from Woods and Fagan.
They focused on Whelan & Hally's first required action. That was to eliminate the 25% disadvantage that a 1 for 3 top-up has for a 40% taxpayer compared to the usual tax relief. Their required action was that tax relief on conventional plans should be scrapped and replaced with the 1 for 3 top-up. Pretty revolutionary and would in fact cut higher tax payers out of any pension plans, AE or conventional.
They discussed and dismissed the alternative which they said was to increase the 1 for 3 top-up on AE to 2 for 3.
Very conspicuous by its absence was the obvious solution which is to give AE 40% taxpayers the extra benefit of 40% relief through PAYE, a solution discussed by the Joint Oireachteas Committee in their report.
Last evening they explained that they had considered this obvious solution carefully but decided not to mention it as it would be too complicated for your average 40% tax-paying AE employee.
 

Attachments

  • Submission by Woods and Fagan.docx
    26.6 KB · Views: 135
So - are pensions about to become a lot less attractive for employees at the higher tax rate?
 
Hi @RMGC11
You're right. The proposal in the paper would be madness.
Here's part of what I said on the evening the paper was presented (supplementing the joint written response by Brian Woods and myself, which @Duke of Marmalade posted above)
"Shane and Maeve’s proposal that all pension tax reliefs be abolished and replaced with a 1 for 3 subsidy would be unfair to higher rate taxpayers in the private sector relative to their counterparts in the public sector. It would also be unfair to higher rate members of DC schemes relative to their counterparts in DB schemes. Their proposals for addressing these knock-on inequities in order to create a level playing field between public and private sector workers and between members of DB and DC schemes verge on the ridiculous and are completely unworkable in practice."
 
Does anyone else see the potential for absolute carnage in the management/administration of adding 750,000 eligible employees to a pension system that's being built from scratch?

Introducing it - fine - 'look at us, we now have xy% pension coverage'.

If it's an administrative nightmare, God help the Government/Minister.


Gerard

www.prsa.ie
 
Does anyone else see the potential for absolute carnage in the management/administration of adding 750,000 eligible employees to a pension system that's being built from scratch?
You're right, @GSheehy. It could be absolute carnage - if it's done the way the Department of Social Protection (DSP) is proposing.
DSP expects ordinary workers, the vast bulk of whom have never bought an investment in their lives, who never heard of unit-linked funds, who would run a mile if they thought their capital was at risk, to understand the benefits of buying "risky" assets because they outperform "safe" assets in the long-term. Workers are expected to decide - without getting independent advice - whether to invest in a low-risk but low return fund, or a high-risk but expected higher return fund, or to leave the decision to "experts" who'll put them into high-risk funds when they're young and gradually transfer them into lower-risk funds when they're older, before kicking them out at retirement, when their funds have their highest earning power (but are earning the lowest returns) and leaving them completely to their own devices. It's madness.
That's why I'm proposing a scheme where members' accounts just look like high-interest deposit accounts, which are invested entirely in "high-risk" assets but with returns smoothed to eliminate the short-term volatility. Very importantly, members don't have to worry about what to do at retirement: they just start drawing from their accounts rather than accumulating them. Everyone (big or small account, old or young, active or retired) gets exactly the same return every month. What a contrast with the scheme proposed by the DSP, where two people working side by side in the same business, who both choose the Default Fund (singular! - what a misnomer, given that there'll be around 50 of them) will get different returns just because there's a small difference in their ages. It's a recipe for total confusion.
Brian Woods' suggestion (above) for ensuring equal tax treatment of contributions to AE and "normal" pensions removes another possible source of confusion.
 
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Not the point I was making.

It doesn't matter if it's a DSP version, or your proposal, if the structure isn't there to support it then it's not going to be successful.

I haven't seen anyone question the administrative structure as a 'necessary action prior to launch'. It's somehow taken as a given that it'll be grand.


Gerard

www.prsa.ie
 
Apart from the investment options, building a system from scratch that will accommodate:
Individuals joining
Individuals opting out
Salary (contribution) increases
Reduced contributions
Switching funds
Switching fund managers
lump sum contributions (?)
Changing Employers
Parental leave
etc, etc
Insurance Companies have taken years to develop systems that work (mostly). The DSP thinking that they can develop a similar system in months, is (well let’s be kind) ……optimistic.
If they did adopt Colm‘s investment proposal, it would certainly ease some of the admin burden, but offering a choice of fund managers each with a choice of fund options……..well it won’t make the admin any easier (apart from the confusion it will cause amongst a cohort probably unfamiliar with the investment funds world).
But I wish them well.
 
Apart from the investment options, building a system from scratch that will accommodate:
Individuals joining
Individuals opting out
Salary (contribution) increases
Reduced contributions
Switching funds
Switching fund managers
lump sum contributions (?)
Changing Employers
Parental leave
etc, etc
Insurance Companies have taken years to develop systems that work (mostly). The DSP thinking that they can develop a similar system in months, is (well let’s be kind) ……optimistic.
If they did adopt Colm‘s investment proposal, it would certainly ease some of the admin burden, but offering a choice of fund managers each with a choice of fund options……..well it won’t make the admin any easier (apart from the confusion it will cause amongst a cohort probably unfamiliar with the investment funds world).
But I wish them well.
Yes, this is going to be some task.
However, it won't be the DSP setting this up from scratch. The CPA will outsource to existing competencies. the Revenue for example are dab hands at extracting money through the PAYE system which is tuned to the ebb and flow of the employee situation and the AE contribution rate is considerably simpler than the PAYE tax deductions. The opting out bit would be new (Revenue don't allow their "customers" to opt out:mad:).
My read is that there will not be the concept of punters switching fund managers. There will be a choice of a few funds but the investment management will be outsourced by the CPA in the wholesale market - this will not be a scramble by pension companies for retail investors and changing jobs will not entail changing to some new fund manager chosen by the employer.
The allocation and de-allocation of units could be the trickiest part especially if there is a fetish for doing such transactions on the precise market price on the day of the transaction. Colm's approach will certainly address that . But if it was a real deal breaker they could revert to the earlier days of unit linking where unit prices where only calculated monthly. With no ability to game the system (no switches or single premiums) this should be totally acceptable on practical grounds.
 
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I pointed out the nuts and bolts issue of collecting the pension contributions. Currently DSP plan on having their own system written, which will go out to tender...

Revenue's system was designed with Auto Enrollment in mind, it would only be a matter of adding a few fields to employees RPN and Payroll Submissions. The RPN needs a Collect T/F flag and at some point in the future AVC amount/percentage fields. Then the actual EE, AVC and ER amount paid is sent in each Submission. Revenue then treats the pension contributions the same as another tax.
This saves greatly on admin and enforcement.
 
Hi @TheJackal
Thanks for posting the video.
@Duke of Marmalade has already posted the written response from Brian Woods and myself.
Attached is what I said on the evening - not on the video you posted.
 

Attachments

  • Comments on W&H paper 25 May 2023 final.pdf
    118.8 KB · Views: 96
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