Factsheet: Annuity comparator PS17/12
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- Loreen Benson
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1 Factsheet: Annuity comparator PS17/12 1 March 2018 brings the introduction of the FCA s annuity comparator requirements, following its policy statement PS17/12. It aims to help people shop around and get the best deal. However, while the aim is laudable, the implementation of the comparator has flaws, which will have an impact not just on consumers and providers, but on adviser firms as well. What is it? From 1 March, any guaranteed annuity illustration will include one of three new prescribed templates. An example of each template is shown at the end of this factsheet. These templates will either: show the annuity income quoted is the best in the market, or; Our quote Market quote indicate the customer could get a higher annual income elsewhere, or; Our quote Market quote highlight the customer hasn t consented to the use of their data for a comparison to be made. These regulations do not apply to non-guaranteed illustrations. What consent is needed? Our quote? Market quote To enable a comparison to be done, an adviser must obtain confirmation from the customer they are happy with their Personal Data being used to provide a comparison. Portals and providers will ask for this before a quote is done to ensure they are using the correct template. The Retirement Health Form will also include this consent. If no consent is given, template 3 (which contains no comparison) is used. Who needs to provide the information prompt? The Conduct of Business rules mean the requirement to provide this information prompt applies to any firm providing a guaranteed annuity quote to a retail client. This means, where a consumer uses an adviser, both the intermediary firm and the relevant annuity provider will be required to provide the information. However, the adviser firm is able to rely on the information prompt given by the annuity provider, if it is satisfied that it is appropriate to do so. Requirement for a like-for-like comparison Figures must be shown on a like-for-like basis which, on first reflection, sounds entirely appropriate. However, this may not help customers understand the true benefit to be gained from shopping around. Let s say the holding provider offers annuities based on postcode alone and doesn t take wider health or lifestyle considerations into account. The comparator within their illustration will show the best income available using postcode only. This may lead a customer to think the potential benefit of moving isn t worth the hassle. But, if they have various health and lifestyle issues, they could gain many thousands of pounds by shopping around. This may be less of a concern for advised customers. Advisers will help people consider their individual circumstances including health and lifestyle, so their customers should end up with the best deal, even if that isn t shown on the comparator. However they may receive illustrations with varying comparator figures from different providers, so it is easy to see confusion occurring. For financial adviser use only - not for retail customers
2 And it s important to remember that if multiple quotes are given from one provider (as they often are showing a variety of different attaching benefits) then an information prompt has to be shown in each case, increasing the information a customer has to digest. How does it affect quotes provided by portals? Many advisers will use a portal as a first step to compare annuity income available. If viewed on screen there is no change to the process. But advisers will notice a difference if details are printed as, at that stage, one of the three templates will be included. It s also worth being aware there may be inconsistencies across the industry. Different providers may use different portals to source the best rate and subtle differences between portals could mean what was seen as the best rate on one portal may not be on another. Potential issue once preferred provider chosen Problems may also arise once a decision has been made to purchase an annuity. There is likely to be a delay of a few weeks before the funds are received by the chosen annuity provider. As the amount received will inevitably be different to what was originally quoted, the provider will prepare a final illustration showing the actual income the customer will get. This illustration also needs to include a comparator, and as the annuity market is constantly changing, it may show this provider no longer offers the best rate. It is crucial advisory firms document what happens in this situation. They could invoke cancellation rights, re-broke the case and pass it to the new best provider. But by the time that happens the same issue could arise again, and adviser and client could be caught in a never-ending loop. Clients may also be unhappy with further delays as they need the income. An alternative would be to have some form of de minimis limit, going ahead with the original quote if the difference is minimal, and only re-broking if it is a larger amount. Best rate in market secured Application to provider Funds received Not best rate anymore Minimal difference PROCEED? Larger difference START AGAIN? How does PS17/12 affect annuities written within The Retirement Account (TRA)? Retirement Advantage s drawdown, The Retirement Account, can include a mix of Pension Savings (uncrystallised), Pension Drawdown and Guaranteed Annuity. All assets within TRA, including annuities, are protected by its tax-advantaged wrapper, written under drawdown rules. This means that a TRA annuity provides significant advantages over a Traditional Lifetime Annuity. 1. Reduce income tax payable on death - Pension death benefits are taxable if the client dies on or after age 75. Because TRA is held in a tax-advantaged wrapper beneficiaries can shelter money inside until is suits them. 2. Control income and save tax - Income can be reinvested seamlessly and tax-efficiently into Pension Drawdown or be left to accumulate in cash. 3. Commute income guarantee - Unlike a Traditional Lifetime Annuity any income guarantee can be commuted to a lump sum. As there are these significant differences between an annuity held within a drawdown wrapper and a Traditional Lifetime Annuity, there are differences to how PS17/12 impacts on quotes. TRA is a unique contract and as there is currently no direct competitor all TRA quotes which contain an annuity element will use: Template 2 (the income shown is the highest in the market for that particular option) - if consent has been given, or Template 3 if no consent has been provided.
3 Template 1: For cases where the guaranteed quote doesn t show the highest income
4 Template 2: For cases where the guaranteed quote shows the highest income
5 Template 3: For cases where the customer doesn t give consent to allow the provider to find the market-leading rate
6 Telephone calls may be recorded for training and quality monitoring purposes. Retirement Advantage is a trading name of MGM Advantage Life Limited. Registered no Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Retirement Advantage and the Retirement Advantage logo are trademarks of MGM Advantage Holdings Limited. Registered in England and Wales. Registered office 110 Cannon Street, London EC4N 6EU /18
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