The FCA has urged pension providers to do more to ensure customers who have invested in older pension and savings products receive fair value. The call follows a review of unit-linked non-workplace pensions and savings products, which found that some customers holding legacy products could be receiving poorer value than those invested in newer alternatives.
The review also pointed to complex charging structures, older product designs and weaknesses in firms’ data as factors contributing to those concerns. These findings are especially relevant in the context of the Consumer Duty, which requires firms to assess whether their products and services are delivering good outcomes for customers.
Legacy products remain under scrutiny
Price and value assessments within unit-linked pensions and savings products were a central theme of the FCA’s review. While examples of good practice were identified, the findings also highlighted areas where firms need to do more. In particular, the regulator raised concerns about customers invested in older products, many of which are now closed to new savers but continue to hold significant numbers of customers. The FCA found that some customers in these legacy arrangements could be receiving poorer value than those invested in newer products, citing complex charging structures, older product designs and weaknesses in firms’ data as contributing factors. The regulator also noted that where data is incomplete or of poor quality, it becomes more difficult for firms to assess whether customers are receiving fair value and to identify opportunities for improvement.
What good practice looks like
The review also highlighted examples of firms taking positive action to improve customer outcomes.
These included:
Simplifying or rationalising legacy products and funds
Developing plans to simplify older product ranges
Capping or reducing charges for customers invested in legacy products
Comparing outcomes across different customer groups and products
Moving customers into alternative arrangements that offer better value
A focus on customer value
This sits within the FCA’s wider work on pensions and long-term savings. Engagement with firms is now focused on the barriers they face when seeking to improve value for customers, particularly within closed books.The work also supports broader pensions reforms, including targeted support and pensions dashboards –and forms part of the FCA’swider programme to modernise pensions and long-term savings.
What firms should consider
For firms, the findings createa timely opportunity to look again at how value is assessed across older pension and savings products.Key questions include whether current approaches reflectthe good practice identifiedin the review, whether firms have the data needed to assess customer outcomes effectively and where there may be scope to improve value for customers invested in legacy products.As firms are encouraged to take forward the practices identified during the review, legacy pension books are likely to remain firmly on the regulatory agenda.