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IAPF | Winter 2014
Citation preview
DC Decumulation pg 07
Pensions Ombudsman Update pg 21
Outsourced Investment pg 16
IRISH PENSIONS WINTER | 2014
Experience counts. Especially in difficult times.
For over 80 years, Pioneer Investments has been providing our clients with best in class, active investment solutions. During this time, we have faced many challenges and have leaned on our global experience to successfully navigate volatile and unchartered waters. As a recognised leader in active � xed income management, we are proud to now o� er our range of industry-leading solutions here in Ireland.
For more information on our services please contact us at 01 480 2000 or visit our website at:http://worldwide.pioneerinvestments.com/dubinst.jhtml
Dave SantryHead of Irish Institutional [email protected]
Alan O’DowdClient Executive,Irish Institutional [email protected]
Vice President,UK & Irish Institutional Business
IRISH PENSIONS MAGAZINE | WINTER 2014 | 3
CONTENTS
CONTENTSChairperson’s Message 4
Feature – DC Decumulation 7
Feature – Pensions Authority 14
Review – Outsourced Investment 16
Expert Opinion – Pension Ombudsman 21
Analysis – Global Pensions Index 26
Feature – Attitudes to Pensions 32
The IAPF does not make any representations or
warranties, express or implied, in relation to the
accuracy or completeness of information set out
in this publication (including articles published by
contributors). Professional advice should always be
taken before acting on any of the matters discussed
in this publication.
Any views or opinions expressed in articles published
in this magazine are not necessarily those of IAPF.
Suite 2, Slane House
25 Lower Mount Street
Dublin 2
Tel: +353 1 6612427
Email: [email protected]
www.iapf.ie
Outsourced Investment pg 16 Attitudes to Pensions pg 32
4 | IRISH PENSIONS MAGAZINE | WINTER 2014
Chairpersons Message
Welcome to the Winter Edition
of IAPF online magazine. As
we approach the end of the year,
2014 has, yet again, been an eventful
year for pensions policy. We have
had developments on the pensions
levy in budget since I last wrote in
our Autumn edition, we have made
progress on the ongoing trustee
training requirements, we have
engaged with Revenue on behalf of
our members and we have focused
on the simplification agenda.
Minister Noonan stated in the budget
speech that he is ending the 0.6%
Pension Levy at the end of 2014.
The additional 0.15% Pension Levy
introduced for 2014 and 2015 will
expire at the end of 2015. The IAPF
has been adamant in opposition to
the levy from the outset, and most
pension savers will be relieved that
the pensions levy will only be 0.15%
next year. While it will still take
¤135m from pension savings, it is
an improvement on the increase in
the levy this year which resulted in
¤700m being taken from pension
savings in 2014. In total, ¤2.3bn will
have been paid by pension savers
since the levy began in 2011.
Many had expected the levy to
continue at the current level and the
fact that it hasn’t is welcomed. The
confirmation that the levy will end
in 2015 is also welcomed and gives
pension savers some long awaited
certainty. The Government now needs
to start to seriously address the many
pension issues to ensure people in
Ireland can aspire to having pensions
that are secure, fair and simple.
Through the work of our committees,
we started to focus the simplification
agenda. We believe that the
deficiencies in the current system
need to be addressed prior to the
introduction of auto enrolment.
While we have publicly stated that
we are not against auto enrolment,
we believe there is a need to research
the profile of people who currently
don’t have a pension and to also
Rachael Ingle
IAPF CHAIRPERSON
IRISH PENSIONS MAGAZINE | WINTER 2014 | 5
Chairpersons Message
simplify the current system before
introduction.
We are also pleased that the Pensions
Authority has confirmed that
trustees can use their own judgment
to determine what constitutes
appropriate ongoing training. Our
events, which are designed to help
inform and educate trustees, can
form part of that appropriate training.
In order to help trustees to log their
training we will award Appropriate
Ongoing Training hours to our events,
in a similar way to CPD accreditation.
We have always been concerned
with the outcomes of Defined
Contribution schemes and more
than ever there is a need for focus.
Simplification in legislation is required
and engagement with participants to
ensure members have any chance
of receiving a reasonable level of
income at retirement. The IAPF is
committed to helping this happen
and will continue to be proactive in
shaping the DC landscape. Promoting
the Pensions Quality Standard
for DC schemes is important and
we believe this is of real value to
employers and trustees in being able
to demonstrate that their scheme is a
quality scheme. The PQS has enjoyed
great traction this year with eleven
further schemes being accredited.
The application is very simple and
can be completed on our website
http://www.iapf.ie/PQS/default.aspx
Hopefully there will soon be some
positive developments from last
year’s DC consultation that will help
our members.
We have been vocal on all of these
issues in various media channels
throughout the year and will continue
to do so in order to highlight the
issues that are important to you, our
members.
The Association has also been
focusing on our vision of the future
pensions landscape and how we can
best serve you. We have focused on
membership development and, as
an association; we are only as strong
as our membership. It is important
that we provide a valued service
that allows us to retain and grow our
membership. It is essential that we
continue to be relevant and heard on
your behalf.
As the year draws to a close I would
like to wish all our members a Happy
Christmas and best wishes for 2015.
Rachael Ingle
IAPF Chairperson
6 | IRISH PENSIONS MAGAZINE | WINTER 2014
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IRISH PENSIONS MAGAZINE | WINTER 2014 | 7
FEATURE
'Pound cost ravaging' in a Decumulation World!Defined Contribution continues to be at the forefront of people’s minds and rightly so. However, a lot of focus to date has been on the accumulation phase of a member’s investment lifecycle. The purpose of this article is to spend some time on the decumulation phase and the challenges facing individuals in the post retirement period.
We note in this paper that members’ investment choices for decumulation directly influence the choice in lifestyle investment strategy adopted for the period approaching retirement.
TEXT WRITTEN BY LIAM STACK Investment Director, Standard Life Investments
"
In the analysis below we model a
range of scenarios to underline how
decumulation investing presents a
more complex investment challenge
than accumulation investing. In
particular, we highlight the material
influence of volatility on investment
outcomes, owing to the effects of
“pound cost ravaging”. (I realise I said
“pound” but the message is the same
irrespective of the base currency!)
We also show how these effects are
greatly magnified when the amount
withdrawn is a significant portion of
the pension pot.
We make the following assumptions:
• Retirement age 60
• £100,000 pension pot at
retirement
• Pension drawdown of £6,000
per annum, paid monthly with
inflation uplifts
8 | IRISH PENSIONS MAGAZINE | WINTER 2014
FEATUREFEATURE
remaining!!! Clearly the investor was
left with ample money to see out the
remaining years – to provide income,
pay for healthcare, leave a bequest
etc. Not unreasonable demands
and for this cohort a 100% equity
approach proved rewarding. By way
of comparison, the payout from cash
on deposit during this timeframe
would have totalled £138,000 and
lasted 17 years.
Period 2:For the 1961 cohort payments last less
than 23 years with total payments
of £311,000 for the initial £100,000
investment. Interestingly, over the
period, equity returns were at the
same level as the 1951 – 1980 cohort
of 11.1% but inflation was higher at
8.7% (remember payments are on an
inflation uplift)
Period 3:During the period 1971 – 2000,
payments totalled just £175,000 with
funds exhausted in less than 13 years.
Equity returns over the payment
period averaged an impressive 12.8%
p.a. However, inflation averaged 13%
p.a. too.
The outcomes from each period
are clearly significantly different.
Given that the outcomes cannot be
known in advance, it is clear why an
investor would prefer a more cautious
approach.
Scenario 1 – The perfect world:Assume smooth equity return of
9% per annum (p.a.) and inflation of
3.5% p.a. This is the level of return
you might expect from global equity
investing, judging by historical data.
In these hypothetical circumstances,
the increasing payments can be
sustained for around 35 years, with
the pot paying out a total of £408,000
to the investor for the initial 100k
investment. If you compare to cash,
assuming a return of 1% over inflation,
the pot would be exhausted within
18 years. Thus, investing in risk assets
would seem to be, on the face of it, a
good thing.
Scenario 2 – Real world experiences:Using the same payment assumptions
but with actual equity returns (taking
into account inflation, average
policy fees and assuming passive
management), we model this over
three different 30 year periods:
• Period 1: 1951 – 1980
• Period 2: 1961 – 1990
• Period 3: 1971 – 2000
Period 1: Global equities returned 11.1% p.a.
while inflation averaged 6.9%.
These conditions were sufficient to
sustain a 30-year payout totalling
£434,000, with assets of £758,000
IRISH PENSIONS MAGAZINE | WINTER 2014 | 9
FEATUREFEATURE
Scenario 3 – Real world using most recent 30-year market returnsPerhaps these differences are
explained by the 10-year difference
in starting points? We therefore
looked at the three most recent 30-
year cohorts (1984-2013, 1983-2012
and 1982-2011) to assess whether
there was greater consistency on
investment outcomes, given the high
degree of overlap for these periods.
We find that, even though there is
only one year’s difference between
the start periods for this drawdown
approach, the outcomes are markedly
different. The outcome for the
investor starting in 1982 is rosy, with
payments totalling £382,000 after 30
years and £221,000 remaining in the
pot.
By contrast, the investor starting in
1984 receives a total of £262,000
before funds are depleted after 25
years.
What is different? The investor
starting in 1982 benefitted from very
strong equity returns in the first two
years of drawdown. This mitigated
the subsequent financial impact of
inflation-related pension payments,
compared to the “unlucky” cohort of
1984.
So, here the incidence of volatility
and when in the investment cycle it
occurred made a material difference
to the drawdown outcome.
Observations and summary:
Our analyses suggest that investing
for returns during decumulation
is generally worthwhile. Positive
returns can be significantly beneficial
in extending the life of the pension
pot; taking investment risk is likely
to be rewarded.
However, the effects of volatility
can be significant, and arguably
catastrophic under particular
scenarios. Moreover, this effect is
amplified as wealth decreases, owing
to pound cost ravaging.
Managing volatilityManaging risk should clearly be a key
aim if we are to achieve good member
outcomes. Active investment
management in the form of multi-
asset risk controlled funds as well as
absolute return funds clearly have a
role to play here, given their risk and
return characteristics. Additionally
there are other techniques that can
be employed to improve outcomes,
such as variable income.
Variable income: Most damage is
done to a pension pot from which
income is being taken during down-
10 | IRISH PENSIONS MAGAZINE | WINTER 2014
FEATURE
ARTICLE AUTHOR Liam StackInvestment Director, Standard Life Investments
markets. To mitigate these impacts we
can design a simple pay mechanism.
For example,
The investor withdraws £4000 p.a.
equally over 12 months, adjusted for
inflation
In any month where equities rise,
the investor receives a 50% bonus
payment.
If equities were to rise every month,
the investor would withdraw £6,000
annual income, adjusted for inflation
[or say “the investor would receive
the 50% bonus”]. However, the
alternative approach shows that,
by withdrawing less when markets
are weak, pound cost ravaging can
be reduced and capital preserved.
Compared to the 6% initial payment
and inflation model, the total payout
for this variable approach is increased
by 13%, with payments lasting for an
additional 5 years.
ConclusionsAs our analysis using historical
data has shown, the continued
generation of returns in the period
following retirement can be powerful.
However, volatility has a significant
impact on member outcomes and
the sustainability of the drawdown
pension. In adverse market
environments, volatility combined
with withdrawals can result in cliff-
edge type positions, which are
virtually impossible to escape without
resorting to additional finance.
Therefore, delivering low-volatility
growth is a crucial objective for the
DC solution.
Absolute return funds are well
suited for this objective. However,
as demonstrated, traditional equity
growth funds can also be used by, for
example, imposing variable income
controls.
Used as part of a pension solution,
active management techniques such
as these can add substantial value to
members opting for decumulation,
more than justifying the costs of
active management compared to
passive approaches.
IRISH PENSIONS MAGAZINE | WINTER 2014 | 11
Benefits Conference
Ann Prendergast, Peter Wood, Kristi Mitchem (all SSgA) & Rachael Ingle (IAPF)
William Barry and David Pyne (Irish Shell Trust)
Kristi Mitchem (SSgA) Benefits Conference Delegates
Anna McIvor (SSgA)Mike Ainsworth & Sinead McEvoy (Zurich Life)
IAPF Photos
Make hay even when the sun doesn’t shine
Past performance is not a reliable guide to future performance. If your clientinvests in these funds they may lose some or all of the money they invest.The value of their investment may go down as well as up. This investmentmay be affected by changes in currency exchange rates.
If you want to give your clients a smoother investment journey, then absolute return investingcould be an ideal option. The Global Absolute Return Strategies Fund (GARS) has a target returnof cash* +5% per annum (gross of charges) over rolling 3 year periods.
Since its launch in Ireland (September 2008) GARS has returned 7.2%** p.a. Find out how your customers could make hay even when the sun doesn’t shine.
* As measured by the six month European Interbank Offer Rate (Euribor)
** Source: Financial Express. Performance from 8 September 2008 to 1 October 2014.
Performance is net of Annual Management Charge.
Talk to your Standard Life Business Manager or visit www.brokerzone.ie
Standard Life Assurance Limited is authorised by the Prudential Regulation Authority in the UK and is regulated by the Central Bank of Ireland for conduct of business rules. Standard Life Assurance Limited is registered in Dublin, Ireland (905495) at 90 St Stephen’s Green, Dublin 2 and Edinburgh, Scotland (SC286833) at Standard Life House,30 Lothian Road, Edinburgh EH1 2DH.©2014 Standard Life, images reproduced under licence.
Pensions Savings and Investments since 1834brokerzone.ie
MakeHayA4BrokerAd_0914.qxp_Layout 1 06/10/2014 14:26 Page 1
IRISH PENSIONS MAGAZINE | WINTER 2014 | 13
IAPF Photos
Governance Conference
Christopher Bown (EY), Rob Heaton (EY),
Rachael Ingle (AON), Alan Broxson (Conference
Chair) & Ellen Gorman (EY)Stephen Donnelly TD
Brendan Kennedy (Pensions Authority)Thomas Brosnan & Noel Keogh (AA Ireland) and
Rachael Ingle (IAPF) receiving the PQS award
Peter Smith (SSgA), Lisa Dixon (FBD) & Ken Mortimer
Delegates at the Governance Conference
14 | IRISH PENSIONS MAGAZINE | WINTER 2014
FEATURE
Last year, the Pensions Authority held
a consultation on the future of defined
contribution (DC) pensions which
included questions on trusteeship,
regulation, investment, value for
money and disclosure. During the
consultation period, two public fora
were held to discuss the issues raised
in the consultation paper. Breakout
sessions were conducted to drill down
further into each topic. These were
very well attended and provided the
Authority with useful and practical
information.
Pensions Authority Model Disclosure Documents
"TEXT WRITTEN BY MARY BRODERICK PENSIONS AUTHORITY
Disclosure documents play a key part in informing members about important aspects of their pension savings. With this in mind, the Pensions Authority is producing a suite of model documents which aim to communicate as clearly and as meaningfully as possible the information required to be disclosed by the current disclosure framework. The first of these documents are now available on the Pensions Authority website and this article sets out the background to the project.
From the responses received to the
consultation relating to disclosure
of member information, and the
feedback from the disclosure break-
out groups, it was clear that the
majority of respondents felt the quality
of member information generally
needs to be improved and made
more user-friendly. Many said the
volume of information required is too
high and the language too legalistic.
There were several suggestions that
the disclosure regulations need to be
reviewed and simplified, with input
from stakeholders.
IRISH PENSIONS MAGAZINE | WINTER 2014 | 15
FEATURE
In the medium term, the Pensions
Authority intends to conduct a
review of the disclosure regulations.
This will of course involve getting
the views of those who provide
member statements and those
who receive them. A review will
also include consideration of what
information members would like to
see and how they would like that
information provided. We would also
be cognisant of the move from paper
based provision of information to
more electronic communications.
In the shorter term, an internal
working group was established
to produce model disclosure
documents that communicate
as clearly and as meaningfully as
possible the information required to
be disclosed to scheme members
by current disclosure regulations.
The group began by looking at the
personalised documents producing
a model benefit statement for a DC
scheme and a model statement of
reasonable projection (SRP), and
are about to publish a model benefit
statement for a defined benefit (DB)
scheme. The group are very grateful
to have received input from the IAPF
who reviewed these documents and
gave suggestions on how information
should be presented and additional
information that may be helpful.
The group has also commenced work
on model leaving service options
letters for a DC and a DB scheme.
The first of these is scheduled to
be published before the year end.
Following that, work will commence
on producing model retirement
options letters.
There is no requirement on schemes
to use the model documents,
however, we hope that they will be
useful in clarifying information that
is required, while presenting it in a
way that is more user-friendly. The
model documents are samples and
information will need to be tailored
for the scheme/member. Providers
may also wish to add additional
information they feel is particularly
useful for the member.
The published model documents are
available on the Authority’s website
www.pensionsauthority.ie under
publications.
ARTICLE AUTHOR Mary BroderickPensions Authority
16 | IRISH PENSIONS MAGAZINE | WINTER 2014
REVIEW
Trustee boards moving to outsourced
investment typically see an evolution
of their existing advisory model into a
fiduciary relationship. This transition
bears careful consideration, since a
fiduciary manager takes on greater
responsibility for asset performance
Outsourced Investment Selecting and Monitoring a Fiduciary Manager
"TEXT WRITTEN BY IAN MOYNIHAN Investment Consultant, PwC Pensions Group
than an advisor. Consequently, the
Trustees will be required to exercise
greater oversight of performance in
the new relationship.
Trustees will have been accustomed
to monitoring and evaluating
• Trustees should ensure that the providers they are considering have the right level of knowledge, expertise and experience to meet the needs of the Trustees. By distinguishing between offerings, Trustees can ensure that they select an appropriate governance model.
• The process of selecting a provider can be complicated by the fact that many consultancies advising on fiduciary management are themselves providers of outsourced investment services.
• With the right degree of outsourcing, Trustees will find that more time can be spent on strategic matters, and that their conversations with external providers will be more useful in steering the whole scheme, rather than focusing on asset class investment alone.
•
In part 1 of this series of two articles, we explored outsourced investment as an evolution of the traditional relationship between trustees and their advisors. In this article, we consider how Trustees might evaluate and compare the various providers in the market.
IRISH PENSIONS MAGAZINE | WINTER 2014 | 17
REVIEW
IT MAKES SENSE FOR TRUSTEES TO CONSIDER
THEIR NEEDS AND PRIORITIES, AND TO EVALUATE
THE OPTIONS AVAILABLE TO THEM BEFORE
DECIDING ON AN APPROPRIATE PROVIDER.
“
“
investment manager performance in
the past, but with the advantage of
clear support from their advisor. The
challenges are different with fiduciary
management, particularly as the
‘advisor role’ is less clear cut.
It makes sense for Trustees to
consider their needs and priorities,
and to evaluate the options available
to them before deciding on an
appropriate provider.
1. Know what you are looking for The varieties of outsourced
investment available range from the
management of a single asset class,
to the full delegation of the asset
strategy towards a funding goal. One
end of the market looks more like a
traditional fund of funds or multi-
asset product. At the full delegation
end, the provider has a role in the
management of the scheme’s balance
sheet – and must proactively advise
the scheme on revising strategic
policy, risk management and
investment policy in light of changing
market conditions.
The key starting point is to identify
the Trustees’ preferred investment
structure. It is important to choose
the right partner to fit the desired
structure. One consideration will be
how Trustees feel their time can best
be used, and from this to identify the
elements of Scheme management
where outsourcing could bring the
biggest benefits.
2. Identify and differentiate between providersIt is important to acknowledge the
variety in operating models, and
the relatively short time over which
outsourced investment services have
been provided. Relative performance
cannot directly be compared, since
the potential level of outsourcing
goes far beyond the management of
assets relative to a benchmark.
In part 1 of this series of two articles, we explored outsourced investment as an evolution of the traditional relationship between trustees and their advisors. In this article, we consider how Trustees might evaluate and compare the various providers in the market.
18 | IRISH PENSIONS MAGAZINE | WINTER 2014
REVIEW
Based on the degree of outsourcing,
competing players will have different
advantages. In many ways, rather
than selecting one provider to do one
thing, you are selecting one provider
to carry out multiple individual
services – and they must demonstrate
their capacity to excel at them all. This
also goes to the heart of evaluating
an outsourced investment provider
after their appointment – rather
than the comparison of performance
versus benchmark, Trustees need to
set a range of goals against which
their provider will be scored.
Aside from the providers’ track
records on offering outsourced
investment services, and the extent
to which they can demonstrate
expertise in asset allocation, de-
risking and manager selection,
other elements of outsourced
investment require evaluation. We
would suggest that such a process
should also examine providers’ cost
effectiveness, risk management and
reporting structures, to ensure that
the Trustees will benefit from a cost-
effective model with appropriate
reporting complexity, and a strong
commitment to risk controls.
3. Implementation Setting goals and agreeing accountability:The decision of who to appoint as an
outsourced investment provider is just
the start of a process. It is not unusual
for the implementation process to be
drawn out as both parties need to
take the time to ensure that they are
satisfied with how expectations are
set, and where responsibilities lie. The
range of services potentially covered
under the banner of ‘outsourced
investment’ is wide, so it pays to
ensure that the contract reflects only
the elements that the Trustees want
to outsource.
IRISH PENSIONS MAGAZINE | WINTER 2014 | 19
REVIEW
Accountability should be clearly
assigned across all services, so that
both parties should have a clearly
expressed and agreed understanding
of the areas for which the outsourced
provider has sole responsibility; those
for which there is joint responsibility
with the Trustees; and the areas
for which the Trustees will retain
responsibility.
As part of the appointment process,
we recommend that Trustees set a
range of key performance indicators
against which their provider will
regularly be evaluated, under such
headings as quality of advice,
proactivity, timeliness, accuracy
and relevance. These will set clear
reference points for the Trustees to
review and challenge the provider-
not by second guessing investment
decisions, but through the lens of
whether key objectives are being
delivered, and in a manner which is
in line with what was promised at the
outset.
Conclusion:In making a decision to appoint
a fiduciary manager, there are
significant principles and approaches
that need to be learned, reviewed
and applied by Trustees. These cover
not only investment strategy, but the
profile of industry participants, the
philosophy of outsourcing which fits
best with Trustees, understanding
the roles of all participants during
the relationship, and how to exit if it
goes wrong.
Where a fiduciary manager is being
appointed, an open and competitive
tender process is the best way to gain
an understanding of the models in the
market, and to compare them to the
Trustees’ objectives and preferred
governance model. Equally, such a
process can challenge Trustees’ own
requirements to evolve in light of
what is available – whether this ends
in a reduced degree of outsourcing
or a greater one.
Undertaking such a process is
worthwhile. With the right degree of
outsourcing, and the right provider,
Trustees will be empowered to have
more meaningful and more strategic
discussions. Conversations both
within the Trustee board, and also
with external providers, will become
more valuable because they will be
about steering the whole scheme,
rather than reviewing individual
elements with different providers.
ARTICLE AUTHOR Ian MoynihanInvestment Consultant PwC Pensions Group
IRISH PENSIONS MAGAZINE | WINTER 2014 | 21
FEATUREEXPERT OPINION
As we reach the end of 2014, the biggest news from the Office of the Pensions Ombudsman is that a Steering Group is actively working to achieve the Government’s stated policy of merging the Office with that of the Financial Services Ombudsman.There are many logistical issues to be addressed, as well as the fundamental job of drafting the legislation to give effect to the merger.
Pensions Ombudsman Article
"TEXT WRITTEN BY PAUL KENNY Pensions Ombudsman
Plans have been made for the
physical integration of the offices
early in the New Year. Although we
will be co-located, the two offices will
operate as separate legal entities until
the necessary legislation has been
enacted. That is likely to happen in the
latter part of 2015. In the meantime, I
will comment on a couple of issues
that have occupied us during 2014.
22 | IRISH PENSIONS MAGAZINE | WINTER 2014
EXPERT OPINION
were included in a bulk transfer where
the scheme assets were surrendered
and transferred to a new investment
manager. Sometimes finding these
assets is actually impossible. In
one recent case, a firm which had
administered a scheme for a period
of years destroyed its records after
six years as it believed it is required to
do under Data Protection Legislation.
The Consumer Protection Code
obliges them to retain records for
six years from the date of the last
transaction.
This is not good for people who are
trying to trace their pensions and I
believe that the combined effect of
the Consumer Protection Code and
the Data Protection Acts can work
against the interest of pension scheme
members. Mistakes are inevitable in
pension scheme administration. They
become irretrievable when there is a
gap of this kind in the record.
That said, I want to express my
personal thanks to the pensions
community at large – including
trustees, administrators, investment
managers and consultants, for
the cooperation which this Office
receives in the course of trying to
unite unfortunate individuals with
benefits which have been mislaid.
Finding your pension.The OPO has received quite a few
queries from people who cannot
locate a pension entitlement. In some
cases, these do not exist at all. An
individual who worked for a company
many years ago and participated in
a scheme, whether contributory or
non-contributory, goes back to try
to trace their benefits. Often, the
companies have gone out of business,
merged with others, been struck
off or just abandoned. As a result,
their pension schemes have either
been wound up or amalgamated or,
in the worst cases, left high and dry
because nobody has bothered to
wind them up.
A good many enquiries are brought
by people who think they have an
entitlement. Prior to the Pensions
Act, preservation was by no means
universal, although vested rights rules
had become more common during
the 1980’s.
We have had cases where scheme
members did actually have rights,
but where those rights were lost by
scheme administrators and trustees
in the course of amalgamation of the
schemes or changes of administrator
or provider. It is, unfortunately, not
uncommon to find that individuals
who had paidup insured benefits
IRISH PENSIONS MAGAZINE | WINTER 2014 | 23
EXPERT OPINION
Early Retirement.This was the subject of a good many
approaches to the Office this year.
Trustees of defined benefit schemes
in deficit routinely refuse requests
for early retirement in normal health,
and members sometimes claim that
they have an unqualified right to
retire early. In one or two cases, the
members were right in principle, but
trustees would then invoke Section
59G of the Pensions Act to withhold
consent.
With regard to ill health retirement
in the Public Service, there was
a suspicion in some areas that it
was being used in the past as a
management tool, getting rid of the
individual rather than tackling the
problem. This was an enormously
costly practice, given the “added
years” entitlements that come with
ill-health retirement in Public Service
Schemes. The incidence of ill-health
retirement in the Public Service seems
to have declined somewhat recently,
though we still receive complaints
when it is refused.
Where ill health retirement is being
considered, independent medical
examination of the member is often
required. We have discovered a
number of cases where the medical
examiner was not properly briefed
on the scheme’s requirements for ill-
24 | IRISH PENSIONS MAGAZINE | WINTER 2014
EXPERT OPINION
health retirement. It is important that
all medical records are made available,
but even more important that the
medical examiner knows exactly what
he or she needs to consider – in other
words, the meaning of the scheme’s
early retirement rule.
We have had cases where trustees and
Public Service scheme administrators
provided doctors with their own
interpretation of the early retirement
provisions of a scheme, which proved
on examination to be inaccurate. In
one case trustees decided that their
rule meant that the member was
permanently prevented from ever
working again in any capacity, even
though another rule gave them the
right to suspend the pension in the
event of recovery!
Occupational health physicians
recognise that, even where the
rules state that the illness should be
permanent, what this actually means
in practice in all ill-health cases is
that the condition from which the
member suffers is likely to persist
until normal pension age – after that,
it is no longer relevant.
Trustees need to exercise great care
in communicating with medical
practitioners in these cases, and
copies of the text of the relevant
scheme rules should always be
forwarded to them.
It’s been another busy year at OPO –
the last full year of separate existence
of the Office. Complaints continue
to flow, but I am happy that lessons
are learned from them, and numbers
are certainly lower than they were a
couple of years ago. I am grateful for
the cooperation that I have received
from the IAPF and its members, this
year and over the past eleven years.
ARTICLE AUTHOR Paul KennyPensions Ombudsman
This ad is for Professional Clients only and is not for consumer use. 1There is no guarantee that this will be achieved. Fund performance figures are shown in sterling on a mid-to-mid basis, inclusive of reinvested income and gross of the Ongoing Charge and portfolio transaction costs from launch on 9 September 2013 to 30 September 2014. The figures do not reflect the entry charge paid by individual investors. Source: Invesco Perpetual. Index performance is total return in sterling. Source: Datastream. The value of investments and any income will fluctuate (this may partly be the result of exchange rate fluctuations) and investors may not get back the full amount invested. Where Invesco Perpetual has expressed views and opinions, these may change. The fund makes significant use of financial derivatives (complex instruments) which will result in the fund being leveraged and may result in large fluctuations in the value of the fund. Leverage on certain types of transactions including derivatives may impair the fund’s liquidity, cause it to liquidate positions at unfavourable times or otherwise cause the fund not to achieve its intended objective. Leverage occurs when the economic exposure created by the use of derivatives is greater than the amount invested resulting in the fund being exposed to a greater loss than the initial investment. The fund may be exposed to counterparty risk should an entity with which the fund does business become insolvent resulting in financial loss. This counterparty risk is reduced by the Manager, through the use of collateral management. The securities that the fund invests in may not always make interest and other payments nor is the solvency of the issuers guaranteed. Market conditions, such as a decrease in market liquidity, may mean that it is not easy to buy or sell securities. These risks increase where the fund invests in high yield or lower credit quality bonds and where we use derivatives. For the most up to date information on our funds, please refer to the relevant fund and share class-specific Key Investor Information Documents, the Supplementary Information Document, the Annual or Interim Short Reports and the Prospectus, which are available using the contact details shown. Invesco Perpetual is a business name of Invesco Fund Managers Limited, Perpetual Park, Perpetual Park Drive, Henley-on-Thames, Oxfordshire, RG9 1HH, UK. Authorised and regulated by the Financial Conduct Authority.
One year on and we’re exactly where we hoped to beThe Invesco Perpetual Global Targeted Returns Fund
Our fund aims to deliver positive returns with less than half the volatility of global equities over a rolling, three-year period.1 One year in and we’re on course to achieve this.
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See the results at invescoperpetual.co.uk/investinginideas
IAPF WINTER 14/15
26 | IRISH PENSIONS MAGAZINE | WINTER 2014
ANALYSIS
Many countries are grappling with
the social and economic effects
of ageing populations. Global
comparisons can lead to lessons for
government, industry and academia
as they debate how best to tackle this
issue. The Melbourne Mercer Global
Pension Index (MMGPI) is the most
comprehensive global comparison
of retirement income systems
currently available and a key tool in
addressing the challenges facing
both policymakers and individual
savers.
The MMGPI covers 25 countries and
nearly 60% of the world’s population,
How does Ireland’s retirement system rank on the global stage?
"TEXT WRITTEN BY BY PETER BURKE DC Consultant, Mercer
The 2014 Melbourne Mercer Global Pension Index (MMGPI) was presented at the IAPF Annual Benefits Conference in October. This is the first time that Ireland has participated in the MMGPI and the results suggest that a number of areas require significant improvement. Peter Burke, DC consultant at Mercer, outlines the results and discusses some challenges common to many retirement systems around the world.
having grown from 11 countries in
2009. Participant countries are
ranked by measuring more than 40
indicators under three sub-indices:
adequacy, sustainability and integrity.
Global results Denmark continued to hold onto the
top position in 2014, with an overall
score of 82.4. Denmark has a well-
funded pension system with good
coverage, a high level of assets and
contributions, and adequate benefits
and a private pension system with
well-developed regulations.
The MMGPI found again that there is
IRISH PENSIONS MAGAZINE | WINTER 2014 | 27
ANALYSIS
no perfect system that can be applied
universally around the world, but
many common features can be shared
for better outcomes for individuals.
Some of the positive actions taken by
countries to improve the adequacy
and long-term sustainability of their
benefit systems are:
• Increasing retirement age to
reflect increasing life expectancy.
• Promoting higher labour force
participation, particularly at older
ages.
• Increasing coverage of the private
pension system with an element
of compulsion or auto-enrolment.
• Limiting access to savings before
retirement.
• Improving member confidence by
requiring greater transparency.
It is encouraging to see that average
scores within the MMGPI have
increased over time, suggesting that
pension reform is having a positive
effect. The average score for the 14
countries in 2010 was 61.7, compared
with 64.3 for the same countries in
2014.
How did Ireland score?The MMGPI gives Ireland an overall
score of 62.2, which is middle of
the pack with an opening grade of
‘C+’. It is clear that there is a need
28 | IRISH PENSIONS MAGAZINE | WINTER 2014
ANALYSIS
for improvement before our pension
system can be considered among the
best in Europe.
Although Ireland’s overall debut
ranking was 11th, we scored much
higher than average in terms of
adequacy. In fact, the MMGPI ranked
our system second only to Australia
in terms of the level of benefits
targeted.
In any pension system, there is a
classic tension between the level of
benefits promised and the likelihood
that these benefits will be delivered.
A well-balanced system targets an
average retirement income that is
enough to provide an acceptable
lifestyle yet also affordable over the
long term. Unfortunately, our score in
terms of sustainability placed Ireland
20th out of 25 countries. This reflects
the fact that many Irish people will
rely on the state pension for income
needs in retirement. Given future
expected increases in life expectancy
and our current economic status, the
MMGPI calls the sustainability of the
Irish retirement income system into
serious question.
The shift to defined contributionOne of the most fundamental
changes in pension systems around
the world in recent years has been
the ongoing shift from employer-
sponsored defined benefit (DB)
schemes to defined contribution
(DC) arrangements. In Ireland, as
in many other countries, DB plans
are under significant pressure, with
unprecedentedly low bond yields
driving up liability valuations and
increasing contribution rates. Many
private sector employers are turning
to DC arrangements to help alleviate
this strain on their businesses’
finances.
In a DC retirement savings system,
individuals carry the risks and
responsibilities for decisions about
investments, contribution levels
and the ultimate benefit format.
As such, trustees and sponsors
have a responsibility to ensure that
sufficient information is provided to
allow individuals to make informed
decisions, particularly about the level
of savings they make and the impact
on their retirement outcome.
Irish people are not saving enough for retirementDespite tax benefits, less than half
of the working population in Ireland
has private pension provision.
Further, only 15% of DC pension
scheme members make additional
contributions above those required
under the rules of their particular
arrangement. Based on current
IRISH PENSIONS MAGAZINE | WINTER 2014 | 29
ANALYSIS
average contribution rates, a member
of a typical DC scheme can expect
their retirement fund to replace
roughly 25% of their working income
when they reach normal retirement.
This drop in income could have severe
implications for individuals’ lifestyles
in retirement, particularly given the
sustainability issue surrounding the
state pension. By 2050, there are
expected to be just two workers for
every person in retirement, compared
with five workers per pensioner
today. This will have a profound
impact on the quality of life enjoyed
by pensioners in the future and
may push many into poverty unless
corrective action is taken.
Information is fundamental People need to understand the
retirement challenge they face,
both in terms of the level of savings
required and the extent to which
they can rely on the state pension.
Pension plans must provide relevant
and timely information to improve
members’ understanding, which will
in turn increase engagement with the
system. Clear, relevant information
will also lead to a stronger emotional
connection as members realistically
consider their future financial needs.
Pension plans can help members
using both technological tools
and lessons from psychology and
behavioural finance. Ireland can learn
30 | IRISH PENSIONS MAGAZINE | WINTER 2014
ANALYSIS
from experience around the world
about the best ways to express the
uncertainties confronting members
and the associated risks.
How can Ireland’s retirement savings system improve?The government now has an
opportunity to reform the pension
system to a world-class standard.
There is already a proposal in place
to introduce an auto-enrolment
system that will automatically
include employees in an occupational
pension scheme unless they opt
out. We should learn from the auto-
enrolment systems implemented
elsewhere (mostly notably in the UK)
and ensure that we avoid the same
pitfalls.
However, in order to maximise the
effect of any new proposal, the first
step must be to simplify the existing
system. At present, there are nine
different types of DC arrangement,
each with their own rules and
requirements. This complexity
increases costs, reduces member
understanding and acts as a barrier
to people saving for retirement.
Any system introduced must be easy
to understand if we are to ensure
that all members have adequate
pension savings. Ultimately, the more
accessible it is, the more members
will engage with it, resulting in
improved and sustainable retirement
outcomes for all.
ARTICLE AUTHOR Peter BurkeDC Consultant, Mercer
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Did you know... all IAPF events qualify for CPD?
reference numbers are included in the relevant event page of the IAPF Website.
www.iapf.ie/events
IAPF Events
32 | IRISH PENSIONS MAGAZINE | WINTER 2014
FEATURE
Well 2014 is drawing to a close, and
it has been a busy one for pensions
and the IAPF. Next year will also be
as busy as we work hard to convince
government to earn back the trust
lost in the pension system via the
pensions levy. We plan to ratchet
up our efforts to address the three
major issues that will determine the
success of planning for retirement
in Ireland: coverage, adequacy and
sustainability. One of the assets in our
efforts will be our yearlong project
looking into Employee Attitudes to
Pensions and Retirement.
You may remember I mentioned in
the summer edition of Irish Pensions
that I had completed over 4,500kms
getting out around the country
to meet and engage with IAPF
members. The most common concern
I heard related to engagement and
communication about the company
pension scheme. Trustees and HR
Employee Attitudes to Pensions"
TEXT WRITTEN BY BY GILL BRENNAN IAPF
managers were concerned that
employees did not value the benefit
of having access to such an efficient
and economic savings vehicle which
the pension scheme provides. I
became increasingly worried myself
when I read the Hudson Salary
Survey for 2013 which revealed that
a Contributory Pension Scheme did
not feature among the Top 4 Most
Valued Benefits For Employees, yet
featured as the number one Top Most
Offered Benefit from an employer.
To paraphrase, it appeared from the
Hudson survey that “What we got
here is failure to communicate”. If
this was indeed true the implications
for our mission to lobby government
to increase coverage, adequacy and
sustainability and to make pensions
secure, fair and simple just got harder.
But is that really the case? Do
employees really not value access
to a Contributory Pension Scheme?
The only way to find out was to carry
IRISH PENSIONS MAGAZINE | WINTER 2014 | 33
FEATURE
out our own survey. We invited our
member schemes to contribute and
add the weight of their members to
our efforts to call on government to
drive for positive retirement planning
over the coming years. Over the
summer of 2014 an invitation was
sent to member organisations of
the IAPF asking them if they would
be willing for their employees to
participate in a ten question survey to
learn more about employee attitudes
to pensions and retirement. We asked
if the survey could be distributed to
all employees regardless of whether
they were members of the company
pension scheme or not. As of 31st
October 2014 eleven IAPF member
organisations had distributed the
survey across their workforce. 858
employees have taken the survey
which equates to approximately a
15% response rate of the estimated
combined workforces of these
members.
The survey was divided into three
sections and set out to learn as
much about employees’ knowledge
of pensions and the Irish pension
system as it could. Section 1 covered
“Understanding”, just what do
employees know about pensions
and saving for retirement? Section
2 covered “Value”, how much do
employees value the pension scheme
in relation to the other elements of
their overall comp. & bens. package?
and Section 3 covered “Engagement”,
how successful have pension
information campaigns, both within
organisations and from government,
been in encouraging greater
engagement with and ownership of
34 | IRISH PENSIONS MAGAZINE | WINTER 2014
FEATURE
an individual's retirement planning?
The results to date are of huge
value and will help to frame the next
iteration of the survey in Q1 of 2015.
Of the 858 that took the survey, 86.6%
were members of their company
pension scheme while 13.4% were
not. Three of the organisations that
took part had a compulsory pension
scheme. So it was very encouraging
to learn that overall a pension as a
benefit of employment was, albeit
slightly, valued ahead of a bonus. This
stands contrary to the Hudson Salary
survey mentioned above. The Top 4
Most Valued Benefits for Employees
in our survey were: 1. Pension Scheme
@ 93.38%, 2. Monetary Bonus @
93.25%, 3. Insurance @ 89.77%, and
4. Increased Annual Leave @ 77.40%.
It was greatly encouraging to see that
for over 75% of our survey participants
the word ‘pension’ was associated
with ‘Saving for the Future’ and that
the word ‘retirement’ meant to most
the opportunity to do things that
they might not get the chance to do
while working. Of course that is all
well and good if one has the means
to pay to enjoy all the ‘Free Time’ one
envisages themselves having when
they stop working. Pensions surveys
to date have shown that a large
portion of the population will depend
on the State Pension to provide
salary replacement in retirement. We
were keen therefore to learn how
much employees taking our survey
know about the State Pension. The
results revealed that over 75% of 20
to 45 year olds did not know when
they would get the State Pension.
This is of concern when considered
alongside the fact that approximately
59% of the workforce is not enrolled
in a private pension scheme and are
presumably thinking that they can
rely and survive on the State Pension
in retirement. It goes without saying
but the State Pension is not going to
pay for the activities people image
themselves being able to do when
they retire – it will at most keep a
person just above the poverty line.
As a result it was therefore interesting
to learn that while most people would
like to retire between the ages of sixty
and sixty-five, when they are faced
with the harsh reality of thinking about
how much they will need to fund that
retirement, over 30% of participants
now saw themselves working up
to and past 69 years of age! This
understanding was prevalent across
gender and age. Salary tended to
affect the extremes of the data, and
perhaps understandably those on
the lower end of the salary scale
saw themselves working past 69,
with those one the higher end of the
salary scale indicating a higher level
of confidence in being able to still
retire at 65.
IRISH PENSIONS MAGAZINE | WINTER 2014 | 35
FEATURE
Our survey told us that over 78% of
employees want to know more about
how to save for retirement and the
best ways to do so. But people still
find pension information Confusing
and Hard to Understand. So it would
appear that we really do have a “…
failure to communicate!” The results
of our survey would suggest that
the message is far from simple. With
Government seriously considering
the implementation of some form
of Auto-Enrolment over the next
decade, communication is going to
be a key factor in ease of adoption.
Our survey did enquire as to attitudes
to Auto-Enrolment and it would
appear from the data returned
to date that indeed the majority
of individuals would prefer to be
automatically enrolled in a pension
scheme on the commencement of
employment. Over 50% of this cohort
would also prefer to have some input
into how much they can contribute
and how their savings are invested
for the long-term. This is encouraging
as it is would appear that the majority
of Irish employees are starting to
think again about how they can save
to provide an income for themselves
in retirement that will go some way
to paying for the type of lifestyle
they would aspire to after a lifetime
of work.
The full survey report can be accessed
via the IAPF website. If you would like
your pension scheme to participate in
this survey in 2015 please contact Gill
Brennan in the IAPF on 01-613 0874 or
ARTICLE AUTHOR Gill BrennanIAPF
The Irish Association of Pension Funds Annual Dinner 2015
The IAPF Annual Dinner will take place on Thursday 26th February 2015 in the
Double Tree hotel, Burlington Road, Dublin 4.
You are invited to book for what has proven to be one of the biggest events in the pension’s calendar in Ireland.
The IAPF Annual Dinner brings together over 700 of our members and guests and promises to be an evening of great food and entertainment, as well as a superb opportunity to
catch up with friends and acquaintances.
BOOKINGS: Click HERE to book your placeCompany Table: €155pp (Tables of 10 and 12 available) | Individual Place: €170pp (Individual Place Price Includes Wine). This is a black tie event.
IAPFAnnual Dinner
2015
IRISH PENSIONS MAGAZINE | WINTER 2014 | 37
FEATURE
The Irish Association of Pension Funds Annual Dinner 2015
The IAPF Annual Dinner will take place on Thursday 26th February 2015 in the
Double Tree hotel, Burlington Road, Dublin 4.
You are invited to book for what has proven to be one of the biggest events in the pension’s calendar in Ireland.
The IAPF Annual Dinner brings together over 700 of our members and guests and promises to be an evening of great food and entertainment, as well as a superb opportunity to
catch up with friends and acquaintances.
BOOKINGS: Click HERE to book your placeCompany Table: €155pp (Tables of 10 and 12 available) | Individual Place: €170pp (Individual Place Price Includes Wine). This is a black tie event.
IAPFAnnual Dinner
2015
NEW MEMBERS
AvantCard Ireland Pension SchemeAvantCard Ireland is based in Carrick-
on-Shannon, Co. Leitrim. Avant
Tarjeta, Establicimiento Financiero de
Credito S.A.U. trading as AvantCard
entered the Irish market following
the sale of MBNA Europe Bank
Limited (now MBNA Limited) in
2012. Avant Tarjeta, Establecimiento
Financiero de Crédito, SAU trading
as AvantCard, is authorised by the
Banco de España in Spain and is
regulated by the Central Bank of
Ireland for conduct of business rules.
GAM (UK) LimitedGAM is an independent, active investment manager and a member of the GAM
Holding Group. Our aim is to deliver strong, long-term results for our clients using a
selection of the world’s most talented investment professionals. We seek to achieve
and – wherever possible – outperform investment objectives through an exceptional
focus on both producing returns and managing risk. Our perspective is global.
Our insights run deep and our methods are transparent. We actively embrace new
and emerging approaches when we think they’ll give our clients better and more
enduring returns.
Deutsche Asset & Wealth ManagementDeutsche Asset & Wealth
Management (Deutsche AWM)
offers traditional and alternative
investments across all major asset
classes. Deutsche AWM also provides
wealth management solutions and
private banking services to HNW
clients and family offices and is part
of the Deutsche Bank Group, one of
the world’s leading financial services
companies. Deutsche AWM had ¤955
billion in invested assets at June 30,
2014
• Connecting • Growing• Evolving
We are delighted to welcome the following new
members to the IAPF
38 | IRISH PENSIONS MAGAZINE | WINTER 2014
NEW MEMBERS
Governance Matters LimitedGovernance Matters Limited is an
independent consultancy business
offering executive support services
to the financial services industry.
Headed by Seamus Hughes who
has over 30 years’ experience,
Governance Matters approach is to
take ownership of the specific issue /
project and to ensure a demonstrable
business benefit for the client.
OPDU LtdOPDU protects pension schemes by
providing unique Pension Trustee
Liability Insurance cover for trustees,
administrators and sponsoring
employers. Members of OPDU have
approximately £210 billion fund
assets in trust and over 800 schemes
insured. Our success is due to a
thorough knowledge of our clients’
businesses and the issues facing
them.
KAS BANKKAS BANK is a specialist European
custodian bank, connecting
institutional investors both within
Europe and globally. KAS BANK
pursues a ‘pure play’ strategy,
undertaking no proprietary trading,
investment banking nor asset
management-related activities.
This aids us in maintaining absolute
independence and neutrality for
the benefit of our clients. A low-risk
profile is integral to our services and is
reflected in the quality of our balance
sheet and high solvency ratio. At KAS
BANK we have won awards for our
recent work with pension schemes,
in addition to high recognition for
innovative pension monitoring tools,
empowering investors to remain in
control of their assets.
TMF GroupTMF International Pensions is the
leading independent overseas
pension provider for the international,
expatriate and corporate community.
We deliver innovative, bespoke
international pension solutions to
provide employers, high net worth
clients and professional advisors
with options to maximise pension
scheme benefits, value and return.
We provide a range of International
Pension Plans (IPPs), for Corporates
and Individual clients. As part
of TMF Group, we provide truly
global and customised pension
management plans to serve the
international community in a variety
of jurisdictions.
For all your IAPF membership needs,
please contact Gill Brennan,
Membership Manager
T: +353 1613 0874
M: +353 876 555 900
The PQS gained great traction in 2014 with many employers, of all sizes, applying for the standard. A further 11 schemes were accredited bring the total number of PQS recipients to 23. Congratulations to the following 2014 recipients:
Does your scheme meet the standard?
— The PQS demonstrates that
appropriate Investment,
Governance and Communication
policies are adhered to in your
scheme
— It highlights the value of your
scheme in the recruitment and
retention of staff
— It demonstrates the commitment
employers have to providing
adequate retirement benefits
— It highlights best practice in DC
schemes
Apply here now!
PQS PQS with Merit
Citibank Ireland The AA Ireland
Oracle Airbus Ireland
Kraft Foods Aughinish Alumina
BASF Bausch & Lomb
Petroceltic
Roadbridge
Shannon Engine Support
Jerry Moriarty, CEO IAPF (centre) accepting the Pensions Personality of the Year Award at
the Irish Pension Awards from Colm O’Regan, host (left) and Bill Kyle (right), CEO Irish Life.
Tel: +353 1 6612427 Email: [email protected]
IAPF DATES FOR YOUR DIARY 2014 -2015
Event Date Venue
Breakfast Seminar Wednesday 21 January 15 Chartered Accountants House
Trustee Essential Training Thursday 22 January 15 Chartered Accountants House
Trustee Refresher Training Friday 30 January 15 Chartered Accountants House
Trustee Investment Training Thursday 5 February 15 Chartered Accountants House
Trustee Network Thursday 12 February 15 Chartered Accountants House
Annual Dinner Thursday 26 February 15 Double Tree Hotel
Breakfast Seminar Thursday 5 March 15 Chartered Accountants House
Investment Conference Thursday 26 March 15 Print Works, Dublin Castle
Trustee Essential Training Wednesday 15 April 15 Chartered Accountants House
Trustee Network Wednesday 15 April 15 Chartered Accountants House
IAPF Annual Golf Outing Thursday 16 April 15 Carton House
Trustee Refresher Training Thursday 23 April 15 Chartered Accountants House
Seminar (AGM & Seminar) Thursday 30 April 15 Chartered Accountants House
DC Conference Thursday 14 May 15 Print Works, Dublin Castle
Breakfast Seminar Thursday 11 June 15 Chartered Accountants House
IAPF Trustee TrainingAll new trustees now require training within 6 months of appointment. All trustees require training every 2 years. Failure to do this means the employer is breaking the law.
����� ���� ���� �������� ��� ����� �������� ���������Comprehensive courses in the areas of DB, DC and Investment available in full and half day formatsA newly developed Refresher course is also available for experienced TrusteesFace to face interaction with trainers�����������������������������������Completion of course enables Trustee to meet their legal requirementsOpportunity to meet & discuss issues with other Trustees���������������������������������������������������Independently run
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