income drawdown the good the bad and the ugly · the good the bad and the ugly learning objectives...
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INCOME DRAWDOWN THE GOOD THE BAD AND THE UGLY
INCOME DRAWDOWN THE GOOD THE BAD AND THE UGLY
Learning objectives
• Identify the risk factors associated with income drawdown
• Be able to list the regulator’s main concerns with income drawdown
• Identify how you can review your client’s drawdown plan compliantly and cost effectively
PENSION FREEDOMS CHANGING MARKET
FREEDOM & CHOICE THE STORY SO FAR
Source: FCA data bulletin issue September 2018
FREEDOM & CHOICE THE STORY SO FAR
Source: FCA data bulletin issue September 2018 (October 2017 to March 2018)
FREEDOM & CHOICE THE STORY SO FAR
Source: FCA data bulletin issue September 2018
INCOME DRAWDOWN THE GOOD THE BAD AND THE UGLY
4.7% - FCA average
withdrawal rate 2016/17.
5.9% - FCA average
withdrawal rate 2017/18.
6% - Royal London median
withdrawal rate 2016/17
7% - Royal London median
withdrawal rate 2017/18.
Source: FCA data bulletin issue September 2018
INCOME DRAWDOWN COHORT LIFE EXPECTANCY
Life expectancy of a male age 65 today is 86
Source – Past and projected data from the period and cohort life tables, 2016-based, UK: 1981 to 2066
INCOME DRAWDOWN COHORT LIFE EXPECTANCY
Source – Past and projected data from the period and cohort life tables, 2016-based, UK: 1981 to 2066
Life expectancy of a female age 65 today is 88
NUMBER OF PEOPLE REACHING AGE 65
65 in 2018
Source: ONS Analysis of population estimates tool June 2018
RETIREMENT OUTCOMES REVIEW FINAL REPORT
RETIREMENT OUTCOMES REVIEW FINAL REPORT
Protecting consumers from poor outcomes • Preventing consumers being defaulted
into cash
• Default investment pathways for non-advised clients
• Transparency of charges
Source: FCA Retirement Outcomes Review Final Report June 2018
Improving engagement with retirement income decisions • Earlier and clearer wake up packs
and risk warnings
• Improving guidance for consumers
• Improving shopping around for annuities
• Early access to savings without having to enter drawdown
RETIREMENT OUTCOMES REVIEW FINAL REPORT
Source: FCA Retirement Outcomes Review Final Report June 2018
Promoting competition by making the cost of drawdown clearer and more comparable for consumers • Clearer information when a consumer
enters drawdown
• Enabling the introduction of a drawdown comparator
RETIREMENT OUTCOMES REVIEW FINAL REPORT
Source: FCA Retirement Outcomes Review Final Report June 2018
INCOME DRAWDOWN A RISKY PRODUCT
FCA CONCERNS
Source: FSA Retail Conduct Risk Outlook 2012
Risk
Risk
Risk
Risk
Risk
Sustainability
Sustainability
Sustainability
Capacity for loss
Capacity for loss
Complex
Lack of understanding
FCA CONCERNS
Source: FSA Retail Conduct Risk Outlook 2012
‘potential for mis-selling income drawdown products, as advisers are likely to need to consider other variables (capacity for loss, risk, higher costs, etc) that are not typically considered when an annuity is purchased...’
‘Consumers have the potential to suffer detriment if they are sold an income drawdown type product when an annuity would have been more appropriate to their circumstances. This risk has the potential to affect all those people entering retirement in the near future..’
FACT FIND INCOME DRAWDOWN
FACT FIND AND RESEARCH
UNDERSTANDING YOUR CLIENT
When is your client looking to retire?
Do your clients…
• want to continue working full-time/part-time?
• have any health issues?
• want to protect their income from inflation?
• want the option of changing their income in the future?
• consider their pension wealth to be joint assets or individually owned?
UNDERSTANDING YOUR CLIENT
Best practice from the FCA
• Clearly establishing their goals and matching the recommendation to them
• Identifying their previous investment experience
• Prioritising his goals – some may be more important than others
• Identifying the client’s attitude to investment fluctuation and capacity for loss
YOUR ANALYSIS
INCOME SUSTAINABILITY INCOME DRAWDOWN
INCOME PLANNING AND SUSTAINABILITY MODELLING
• Income & expenditure questionnaire
• Understand limitations & explain
• Realistic growth rates
• Large planned expenses
• Revisit regularly
SEQUENCE RISK FLAT RETURNS
-10%
-5%
0%
5%
10%
15%
20%
1 2 3 4 5 6 7 8 9 10
Year
Scenario Fund Value after 10 years
4% flat return
£80,000
Source: Royal London, August 2018 Assumes £5k withdrawal, increasing 2% pa, from £100k pot
Ne
t g
row
th r
ate
(%
pa
)
SEQUENCE RISK INITIAL POSITIVE RETURNS
Scenario Fund Value after 10 years
4% flat return
£80,000
Initial positive returns
£89,800
-10%
-5%
0%
5%
10%
15%
20%
1 2 3 4 5 6 7 8 9 10 Year
Source: Royal London Assumes £5k withdrawal, increasing 2% pa, from £100k pot
Ne
t g
row
th r
ate
(%
pa
)
SEQUENCE RISK INITIAL NEGATIVE RETURNS
Scenario Fund Value after 10 years
4% flat return
£80,000
Initial positive returns
£89,800
Initial negative returns
£58,800
-10%
-5%
0%
5%
10%
15%
20%
1 2 3 4 5 6 7 8 9 10
Year
All scenarios return 4% on average, but can provide significantly different outcomes
Source: Royal London Assumes £5k withdrawal, increasing 2% pa, from £100k pot
Ne
t g
row
th r
ate
(%
pa
)
MODELLING OUTCOMES STOCHASTIC
Range of outcomes
Source: Royal London, August 2018, showing stochastic modelling outcomes
INCOME SUSTAINABILITY HEAT MAP
Highly Sustainable 85%-100%
Reasonably Sustainable 75% - 84.9%
Moderately Sustainable 50% - 74.9%
Not Sustainable 0 - 49.5%
Source: Royal London, December 2018
“Our current view is that a 4% withdrawal rate
is highly sustainable.”
*Depending on a term of 25 yrs, invested in GRIP3, assumes a 1% total charge.
Source: Royal London
INCOME DRAWDOWN CHALLENGE
• More people using income drawdown
• Greater regulatory focus on evidencing income sustainability
• Regular reviews and governance are critical
• Providing a review service can be time-consuming and costly
ONGOING REVIEWS
• Provide ongoing advice and/or service
Ensure
• Their health hasn’t changed
• Their attitude to risk hasn’t changed
• The level of income they receive still supports their needs
• Personal circumstances haven’t changed
RETIREMENT INCOME ONGOING REVIEWS
• …, there is no real guidance as to what should be included in a drawdown review beyond the HMRC requirements. This factor will almost inevitably lead to failings in processes
• Based on this fact, and the absence of specific rules around the review process, the drawdown review must be treated very much in the same way as the original recommendation to utilise a drawdown solution.
Source: PFS Thinkpiece Number 109 November 2014
RETIREMENT INCOME ONGOING REVIEWS
Source: COBS 9.3.3
• COBS 9.3.3 states:
• When a firm is making a personal recommendation to a retail client about income withdrawals, … it should consider all the relevant circumstances including:
(1) the client's investment objectives, need for tax-free cash and state of health;
(2) current and future income requirements, existing pension assets and the relative importance of the plan, given the client’s financial circumstances;
(3) the client’s attitude to risk, ensuring that any discrepancy is clearly explained between his or her attitude to an income withdrawal, … and other investments.
RETIREMENT INCOME ONGOING REVIEWS
• Age 75
• Scenario positioning
• Capacity for loss
• Review triggers – Brexit? Heightened volatility
• Some providers have tools which can alert you to this. Saves you time, money and potential complaints
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
55%
60%
65%
70%
75%
80%
85%
90%
95%
100%
81.5%
IMPACT OF A 10% FALL ON INCOME SUSTAINABILITY
SU
STA
IN
AB
ILIT
Y S
CO
RE
92.6%
Source: Royal London, September 2018 *Depending on a term of 25 yrs, invested in GRIP3, assumes a 1% total charge.
Before After
Before After
4% income
5% income
100K
INVESTMENT
WITH DIFFERENT
INCOME LEVELS
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
55%
60%
65%
70%
75%
80%
85%
90%
95%
100%
81.5%
IMPACT OF A 10% FALL ON INCOME SUSTAINABILITY
SU
STA
IN
AB
ILIT
Y S
CO
RE
92.6%
Source: Royal London, September 2018 *Depending on a term of 25 yrs, invested in GRIP3, assumes a 1% total charge.
55.1%
28.0%
Before After
Before After
4% income
5% income
100K
INVESTMENT
WITH DIFFERENT
INCOME LEVELS
A TRACK RECORD IN
• Track record in growing and delivering an opportunity for sustainable income in challenging market conditions
• Starting with £100K pot, taking 4% monthly income since launch (28 August 2012 - 31 December 2018)
SUSTAINABLE INCOME
Name
Annual income level
£4,000 £4,500 £5,000 £5,500 £6,000
ABI Mixed Investment 20%-60% Shares - pen
£104,896.47 £101,442.72 £97,988.96 £94,536.04 £91,082.29
GRIP 1 £102,135.71 £98,592.49 £95,049.26 £91,506.89 £87,963.66
GRIP 2 £110,016.65 £106,398.96 £102,781.26 £99,164.43 £95,546.73
GRIP 3 £118,003.11 £114,317.04 £110,630.97 £106,945.79 £103,259.71
GRIP 4 £127,568.00 £123,798.18 £120,028.36 £116,259.44 £112,489.62
GRIP 5 £133,357.10 £129,536.39 £125,715.68 £121,895.88 £118,075.17
Source: Lipper, 31 December 2018. Past performance is not a guide to the future. Prices
can go down as well as up. Investment returns may fluctuate and are not guaranteed so
you could get back less than the amount paid in.
INCOME DRAWDOWN THE GOOD THE BAD AND THE UGLY
Learning objectives
• Identify the risk factors associated with income drawdown
• Be able to list the regulator’s main concerns with income drawdown
• Identify how you can review your client’s drawdown plan compliantly and cost effectively
THANK YOU
The Royal London Mutual Insurance Society Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The firm is on the Financial Services Register, registration number 117672. It provides life assurance and pensions. Registered in England and Wales
number 99064. Registered office: 55 Gracechurch Street, London, EC3V 0RL. Royal London Marketing Limited is authorised and regulated by the Financial Conduct Authority and introduces Royal London’s customers to other insurance companies. The firm is on the Financial Services Register, registration number 302391. Registered in
England and Wales number 4414137. Registered office: 55 Gracechurch Street, London, EC3V 0RL. Royal London Corporate Pension Services Limited. Registered in England and Wales number 5817049. Registered office: 55 Gracechurch Street, London, EC3V 0RL.
February 2019 PR P8 PN 0121