Transparency Task Force letter to Work and Pensions Committee

Written by Talya Misiri

The following was sent to Frank Field and numerous MPs, and regulatory professionals:

The Rt. Hon Frank Field MP
Chair, Work and Pensions Committee
House of Commons
London SW1 OAA

Dear Mr. Field,

We are writing to you as a group of independent individuals and organisations, motivated and united by the desire to help protect the interests of the UK’s saving public, through the better provision of transparent, consistent and straightforward disclosure of all the costs and charges they pay.

The issues raised in this letter affect Defined Benefit and Defined Contribution pension schemes and cannot be dealt with fully under the scope of your existing Defined Benefit pensions inquiry.

It is vital that we have transparent, consistent and straightforward costs disclosure because opacity and obfuscation on pension and investment costs leads to:

#1. Decision-makers, including consumers, being unable to exercise ‘informed choice’ properly: They find the market opaque, complex and confusing: It is difficult to identify value for money.

#2. The risk of future litigation: Consumers may argue they are not being treated fairly. Such action would severely damage confidence in the sector and its intermediaries.

#3. Seemingly impotent market forces: In this sector, the ‘invisible hand’ seems unable to work its ‘magic’ to create a healthy, competitive and efficient market.

#4. Poor consumer outcomes: If costs are 2% p.a. and gross market returns 5% p.a., a 20-year-old saving £100 per month until 65 will lose 42.55 % of his/her pension fund to costs.

#5. A marketplace where progressive, innovative and highly cost-effective offerings that do represent good value for money inexplicably struggle to get the market share they should.

#6. The risk that the success of the Government’s pensions policy is jeopardised: Those automatically enrolled might opt out if they are later disappointed by their net of costs returns.

#7. The risk that should the ‘high costs/low returns’ reality continue to prevail, belief in the wisdom of deferred gratification and confidence in long term savings will be undermined.

#8. Investment Governance Committees and Trustee Boards struggle with their duty to manage scheme’s costs properly: ‘You can’t measure, monitor or manage what you cannot see.’

#9. Bad publicity, falling trust and apathy: The public’s confidence in pensions is falling sharply and we want to stop it falling ‘below the point of no return’: This is a serious and systemic risk.

#10. The UK’s savings market, including pensions, not being seen to be well-governed, transparent and trustworthy: That’s a particularly important point in our post-Brexit world.

Furthermore, we believe that savers should not only know what their savings cost; they should also know where and how their money is invested. Greater transparency in investment holdings and the stewardship around those holdings is needed. On the basis that it is hard even for MPs to establish where and how their own Parliamentary Contribution Pension Fund is being invested, it follows that the public as a whole may be similarly challenged.

In general terms, we believe that:

• This is an important and widespread public interest issue; it has parallels with the known shortcomings that are affecting the energy sector’s opaque and complex regime of tariffs.

• Greater transparency on costs and investment holdings will help create the better-served, better-engaged and better-performing savings market we all want.

• There is merit in doing all we collectively can to help sustain the success of the Government’s automatic enrolment pensions policy.

• In a post-Brexit world, we shouldn’t underestimate the value to our economy of the potential for the UK becoming the world-leader in pensions and investing transparency.

• Your Committee is uniquely placed to lead an open enquiry that we are confident would be run in a constructive, forensic, inclusive, robust and non-partisan way, for the long-term benefit of all.

• There is excellent regulatory activity underway by DWP, FCA and TPR; your enquiry would support that work by ‘pulling it all together’, creating an even more cohesive approach.

To conclude: For reasons of social justice, market efficiency, good governance, national reputation and to help protect the ongoing success of the Government’s pensions policy, we would like your Committee to open an inquiry into the matters set out in this open ‘letter’.

I believe the Financial Times are publishing an article regarding this request online today and in their newspaper tomorrow.

If requested I would be happy to liaise with yourself and/or your Committee Clerk regarding this matter.

For administrative purposes (as it would not be practical to liaise with all the co-signatories) please reply to

We look forward to hearing from you.

Yours sincerely,

All those listed below, who are equal co-signatories in this endeavor.

First Name Last Name Position Organisation Website
Nick Boyes
Managing Director Able Governance Ltd

David Rich CEO Accurate Data Services Ltd

Phil Ninness Business Development Manager Accurate Data Services Ltd

Tracey Sharman Head of Operations Accurate Data Services Ltd

Aidan Dennis Managing Director Amaces

Ian Neale Director Aries Insight

Turner Co-Chair Association of Member-Nominated

Weeks Co-Chair Association of Member-Nominated

John Paradise Committee Member Association of Member-Nominated Trustees

Bob Scott Chairman Association of Consulting Actuaries

JB Beckett UK Representative, Author Association of Professional Fund Investors

Mark Miller Vice President, Employee Benefit Consultant Barclays Corporate & Employer Solutions

Stuart Barker Director Barker Coaching & Consulting
Pete Eggleston Founder Director BestX

Jo Thresher Director Better With Money

Valborg Lie Director Borg Consulting

Philip Meadowcroft Chairman of Trustees Brandmasters Ltd Executive Pension Scheme
Steve Lugg Project Manager, Finance & Procurement Consultancy Buckinghamshire County Council

Sunil Chadda Managing Director Cairn Consulting Ltd
Professor Andrew Clare Chair in Asset Management Cass Business School

Professor David Blake Director, Pensions Institute Cass Business School

Professor Steve Haberman Professor of Actuarial Science, Faculty of Actuarial Science and Insurance Cass Business School

Maurice Frankel Director Campaign for Freedom of Information

Tony Filbin Chairman Capital Cranfield Holdings Ltd

Edward Bushnell Compliance Director Cavendish Medical

Graham Cook Board Member CFA Society of the UK

Alice Garton Senior Lawyer Client Earth

Jeremy Coller CIO Coller Capital

Consumer Insights Ltd

Alan Salamon Managing Director Corpias

David Stripp Principal David Stripp Consulting
Andrew Penketh Partner, Head of Pension Funds Crowe Clark Whitehill LLP

Emma Gleaves Employee Benefits Consultant
Niall Ferguson Principal Consultant Engaging Reward
Ben Faulkner Communications Director EQ Investors

Chris Connelly Lead Business Solutions Architect Equiniti

Luis Rivera Co-Founder & CEO ETFmatic Ltd

Jan Lambert Independent Consultant
Chris Hewett Head of Advocate Programme Finance Innovation Lab

Robert Young BSc FIA Consulting Actuary Gordon Dadds

Nick Keppel-Palmer Head of Strategy Husky Finance

Fiona McDonagh Senior Scheme Secretary Inside Pensions

SV Rangan Director IFG Worldwide Ltd
Jane Marshall Consulting LLP

James Meenan Principal JNM Investment Governance

Mike Hopwood Head of Pensions Kier Business Services

Vidya Nathan Aspiring Investment Consultant
Mike Barrett Consulting Director The Lang Cat

Jeff Houston Head of Pensions Local Government Association

Francisco Gomes Professor of Finance London Business School

Philip Brown Head of Policy LV=

Terence Prideaux Managing Director Morley Hall Ltd
Tim Walton Manager, Data and Research Strategy Morningstar

Barry Mack Client Director Muse Advisory

Alan Browne CEO MyFutureNow

Malcolm Booth Chief Executive Officer
National Federation of Occupational Pensioners

Alex Noble Director Noble & Associates Ltd

JB Beckett Consulting Chie Investment Officer and Author New Fund Order Consulting
Derek Bradley Founder & CEO Panacea Adviser

Callum Mayor Associate
Partner PEN Partnership LLP

Henry Tapper Founder Pension PlayPen

Philip Miller Founder Pensions Focus

Tim Middleton Technical Consultant Pensions Management Institute

Daniel Godfrey co-Founder The People’s Trust.

Rohan Sivajoti Director, Postcard Planning

Jon A Collins Director Professional Pensions and Investments Ltd.

Andy Scott Principal Punter Southall

Paul Trickett Chair Railpen Investment

Malcolm Small Executive Chairman Retirement Income Alliance Ltd

Rob Lake Responsible Investment Advisor Rob Lake Advisors

Nick Greenwood Pension Fund Manager The Royal Borough of Windsor & Maidenhead

Tony Greenham Director of Economy, Enterprise and Manufacturing Royal Society of Arts, Manufactures and Commerce

David Pitt-Watson Leader The RSA’s Tomorrow’s Investor Project

Dr. Hari Mann Director The RSA’s Tomorrow’s Investor Project

Adam French Co-founder & Managing Director Scalable Capital Ltd Error! Hyperlink reference not valid.

Shazia Afghan Litigation and Contentious Regulatory Lawyer/Institute Fellow Seven Pillars Institute for Global Finance and Ethics

Catherine Howarth Chief Executive ShareAction

James Lead Adviser & Co-Director
Simplified Money

Sarah Hutchinson Consultant S J Hutchinson Ltd
Andrew Evans Chief Executive Officer Smart Pension

Gerry Wright Partner Smith & Williamson Investment Management

Dr. Daniela Carosio Senior Partner Sustainable Value Investors

Graham Wrightson Partner Stephenson Harwood LLP

John Serocold Principal Studio Serocold
Dan Norman CEO TCF Investment

Mark Goyder Founder & Chief Executive Tomorrow’s Company

Andy Agathangelou Founding Chair Transparency Task Force

Nic Round Client Strategist & Wealth Adviser Treowe Wealth Partners

Tim Sharp Policy Officer TUC

Alex Letts Chief Unbanking Officer U

Michelle Baddeley Professor in Economics & Finance UCL Bartlett Faculty of Built Environment
University College London

Markus Krebsz Interim CRO Member of UNECE GRM www.unece.grm

Steve Kenzie Executive Director United Nations Global Compact UK

Noel Whiteside Professor of Comparative Public Policy University of Warwick

Paul Hewitt Senior Business Development Manager Vigeo Eiris

Michael Cotter Solicitor Advocate & Partner Waterside Legal LLP

Geik Drever Strategic Director of Pensions West Midlands Pension Fund

Stuart Travers Director Winterbourne Trustee Services Limited.

Steve Conley Managing Director Workplace Pensions Direct

In addition to the above, the individuals listed below from outside the UK also wish the UK’s Work & Pensions Committee to open an inquiry into costs and charges in pensions and investments on the basis that doing so will help shine a light on what is a very international problem; and perhaps help the international community coalescing around this issue to develop some international best practice. The UK can help to lead the way.
First Name Last Name Position Organisation Website Country
Sam Instone CEO AES International
United Arab Emirates (DIFC)
Managing Partner Fiduciary Wealth Partners www.FWP.Partners
Ronan O’Houlihan Founder Calm Financial Care
Stephen Davis Associate Director and Senior Fellow, Programs on Corporate Governance and Institutional Investors Harvard Law School

Richard Field Founder Institute for Financial Transparency
Paul M. Secunda Professor of Law and Director, Labor and Employment Law Program Marquette University Law School
Phil Stockton FHKSI MCSI Director Private Capital Ltd
Hong Kong
Dr. Kara Tan Bhala President and Founder Seven Pillars Institute for Global Finance and Ethics

Oren Kaplan Co-Founder Sharing Alpha
Nicholas Morris Adjunct Professor, Faculty of Law
University of New South Wales, Sydney, Australia
Erik Conley Founder ZenInvestor

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