Video Regulatory change – latest proposals from Government and regulators

(00:00): Hello, I'm Steven Cameron, Pensions Director at Aegon UK. I'm going to talk today about regulatory changes which are being proposed from both the government and the regulators. This session will qualify for 45 minutes of CPD. So at the end of the session, please just click on the survey, fill in the answers, and we'll send you your CPD certificate. So what am I going to be covering? I've picked out a few key themes, which I think are particularly relevant in 2024, but also looking beyond this year into the years ahead. First of all, I'm going to be covering investment for UK economic growth, something which is high on the current government's agenda. And I imagine on any future government's agenda, I look at that within two different approaches. One will be defined contribution pension scheme investments, and I'll then look at the recently proposed UK ISA.

(00:55): I'll then spend some time looking at a number of changing market dynamics within the pensions world. I'll come back to talk about value for money, small pots, pot for life trust-based pension freedoms, and also, while it's not specific to pensions, the advice guidance boundary review, which I think will be highly influential on our industry going forward. There are two, which I don't have slides on, which I'll touch on briefly right now. The first is automatic enrolment and the enhancements we're expecting to that it's incredible, and not in a good way, that the 2017 reforms still haven't been implemented, although the current government did commit to doing so. We've been expecting a consultation paper on the practicalities of introducing this change, but that hasn't yet appeared. It may be that government is concerned that with the current cost of living crisis, it doesn't want to put more burden on either individuals or on employers, but it is important that at some point we make these changes, which will first of all reduce the minimum age from 22 to 18, but making sure that individuals are starting their auto enrolment journey at a younger age when they've got longer to build up pensions and for their funds to grow.

(02:13): And secondly, is removing the current £6,240 salary offset so that in future auto enrolment contributions are based on all earnings, not just earnings above £6,240. And that will be particularly beneficial to lower earners. So I do hope that whoever's in power will advance that as a matter of urgency in in in the coming years. The other topic, which I'll touch on right now are pension dashboards. I've often heard people say, well, pension dashboards ever happen. I do believe that they will. I'm pretty sure that they will. In fact, because we've seen a flurry of activity recently, which suggests that things are really moving forward. First of all, being a pension dashboard service provider is now a regulated activity. Secondly, we've had the regulators informing schemes and providers like Aegon of the deadline for them to connect up to the pension dashboard ecosystem and for Aegon and other large schemes and providers, that will be April 2025.

(03:18): And the schedule then runs all the way through until September, 2026. The third development has been a consultation from the FCA around the regulation around becoming a pension dashboard service provider. And there's quite a lot in there which begins to bring to life how dashboards might influence the whole journey around informing individuals of their pensions and also for advisers to consider how to build that into their advice journeys. So fingers crossed, we will see these go live. And my best guess right now is that the go live date will be somewhere between April 2026 and October 2026.

(04:00): The other big thing, given time right now, is that we're fast approaching a general election and Aegon are certainly on manifesto watch right now. And two of the topics which we've been particularly vocal in terms of lobbying all parties on are state pensions and social care funding, both of which we think are very important topics to be included in manifestos on state pensions. The first big question is whether parties will commit to keep the triple lock for another five years, and if so, how will that be paid for? Could it put further pressure to increase the state pension age further and faster? The other topic is social care funding. You may recall that the Conservatives were to have implemented their plan, which split the funding between individuals in the States (pensions) last October. That was pushed back two years to October 2025. And we haven't heard much about that since. I very much hope that whoever's in power will take forward such a deal. I imagine Labour might want to take a slightly different approach if they were in power, but if we get a deal and if that includes a cap on how much individuals will have to pay for their care costs, then I think it will open up another key market for advisers to help in the at retirement space.

(05:22): So if I can move on to the first group of, of topics, which is around investment or UK economic growth, I'm going to start with what that might mean for workplace pensions. You may have seen that Aegon was one of the founding signatories to the Mansion House compact last July. Within that, we committed to invest 5% or more of our workplace default funds in private equity by 2030 with an important caveat that we would do that only if it remains in members' best interests. I should stress that the commitment is to private equity globally, not to private equity within the UK. One way of increasing your exposure to private equity is through using long-term asset funds, the new regulatory regime, which the FCA introduced, first of all to give confidence to institutional investors to explore investing in illiquid, but now being opened up to to retail investors.

(06:22): We do believe that a small proportion invested in private equity and illiquid can be in the interest of members. We think it can lead to higher investment returns even after higher charges. And we also believe that it creates a new form of diversification. Some people have said that pension schemes, DC pension schemes are such long-term investments that you don't need to worry about liquidity. I don't quite agree with that. I do think you need to think about liquidity at the individual member level because individuals do want to switch funds. They do want to transfer between schemes and they do want to retire and not have to wait for their money. So as part of the solution, we do need to keep an eye on making sure that there is sufficient liquidity to meet members' needs. One of the most recent developments in this topic was in the Chancellor's March Budget speech where he proposed a new form of disclosure for workplace pensions to disclose how much they were invested in UK equities and UK businesses alongside how much they were invested in international equities. That's still to be consulted on, but the plan is to have that in place by 2027. And the Chancellor went further and said that if he didn't see signs of a positive trajectory towards international best practice, that he would consider further action.

(07:47): Now, there are a number of advice opportunities in this space. First of all, if you are advising trustees, then they may be considering changes to their investment strategies and this is a specialist area that will need advice to support them. I mentioned long term asset funds opening up now to retail investors. So you may have clients who are interested in exploring that more generally. I think that the talk including in the media of private equity and higher returns might generate more interest in exploring this area. But this is a complex area. We're seeing LTA's being launched gradually. They're all a bit different. They will all need their own analysis. So I think that complexity means that there's even greater value in advisers supporting clients in this new world.

(08:40): So that's the workplace pension dimension. If we now move on to the UK. So this is perhaps the newest thing which appeared in the Chancellor's March Budget. You understand the aims of this. The Chancellor wants to encourage more investment in the UK and that's an admirable aim. So his proposal is that he'll encourage retail investors to buy British by allowing an extra £5,000 ISA allowance on top of the current £20,000 ISA allowance to be paid into a UK ISA, which meets certain criteria. We have a consultation which is ongoing right now. Some of the key questions within that first of all are around how do you define UK investments, what we'd be eligible to hold within a UK ISA, and there are proposals around that being ordinary shares in companies incorporated in and listed in the UK. It might also include collective investments if perhaps 75% of their underlying investments met those criteria.

(09:44): And it might also be allowable to hold corporate bonds issued from such companies within a UK ISA. But that's all still to be determined. I do hope that the definition is consistent with what's used within workplace pensions to disclose investment in UK and in UK equities. The other area within the consultation is around any new requirements for UK ISAs to avoid abuses. Now, for example, it wouldn't work if individuals could pump an extra £5,000 into their UK ISAs only to transfer it out the next day into another form of ISA. So it's highly likely, in fact, pretty much definite that you will not be allowed to transfer out of a UK ISA other than into another UK ISA. So that will create new restrictions which advisers will need to factor in to their advice.

(10:37): When Aegon first analysed the UK ISA, our first thoughts were, it's okay for the Chancellor to create a framework for a product of this nature that if we want to launch a product, a UK ISA, we need to consider the FCA's consumer duty. One aspect of that is that we need to design and develop products with a particular target market in mind. And we believe that the market here is really quite niche. It's likely to only appeal to those clients who've maxed out their current £20,000 ISA allowance and a stocks and shares ISA. So that immediately rules out quite a lot of the market in terms of diversification. Quite clearly, UK ISAs will not offer much diversification. One of the other aspects of the consumer duty is to avoid causing foreseeable harm. So I think that the lack of diversification will be something that needs to be considered as part of that.

(11:34): The third aspect is that there will be costs in developing a UK ISA, I've talked about some of the extra rules which will surround the UK ISA so the development will come at a cost. However, the market is relatively niche and the maximum contributions from any individual will be £5,000 per year. So it may be challenging to come up with charges which cover those costs, which also can be presented as offering value for money. So a number of consumer duty considerations there. So what about the advice opportunities here? Well, if you are an adviser thinking about this, you might want to consider which of your clients might this appeal to? How niche is the market? If you did have clients who are investing an extra £5,000 in the UK, might you want to rebalance their portfolio so that you continue to have a current diversification across the whole portfolio?

(12:32): Enough to say that I'm not convinced this is the right way to encourage retail investors generally to buy British. One other possibility would've been to include much more upfront disclosure of the percentage of investments which are in the UK at the front of all product literature. So whatever the product was, some kind of indication of what proportion is invested in the UK, might have allowed individuals who do want to buy British to make informed choices. One final comment on this is that shortly after the Chancellor's budget, we did hear suggestions from the treasury that it was unlikely that the UK ISA would launch in the 2024-25 tax year. That means that it will launch, if it launches, after the next general election. Labour hasn't to my knowledge said much on this, so I'm not sure if Labour would even take this forward. So who knows? We'll have to wait to see if this actually becomes a reality.

(13:36): I'd now like to move on to the range of pension market dynamics and the one that I'm going to cover first is the value for money framework. And the reason I'm covering this first is because I think this will be a building block on which many of the other initiatives which we're about to talk about will be built. Unless this is in place, I think the success of other initiatives will be less certain. This is a joint initiative from the DWP, from the pensions regulator and from the FCA. And I very much welcome any opportunity to see different parts of government and regulators working together rather than creating regulatory arbitrage between different regimes. The idea is that we will in future have a common value for money framework across all DC pensions. Initially, this will apply to workplace default funds. It will then extend to other workplace accumulation funds, then to decumulation.

(14:34): So ultimately a very much all encompassing the idea is to have standardisation, transparency and comparability. It's not that value for money is a concept we don't already have. For example, independent governance committees already have their own value for money testing, but this will create that consistency across the market. One of the recent developments, again announced in the Budget is that schemes will be required to publicly compare themselves with other schemes, including two large schemes with assets over £10 billion. And if they're found not to be stacking up, if they're not meeting the same standards, then that's when you need to take action. There are three mandatory elements within the value for money framework. The first is investment performance, the second is cost and charges. And the third used to be called quality of services. But I've recently seen it described as simply other metrics.

(15:33): I'm not sure if that suggests that the quality of service criteria are proving difficult to, to come up with on a standardised basis. One concern I have and something that will be watching carefully is that the consumer duty also has a number of value for money or good value tests. And we have the four outcomes there of products and services, price and value, consumer understanding and consumer support. Now, while there will inevitably be some commonality, the three criteria and the four outcomes don't have a nice neat match. The FCA is involved in this. So I very much hope that we won't end up with two value for money tests that are different in some regards.

(16:19): While the value for money framework has been positioned as there to deliver better member outcomes, it's equally about driving a scheme consolidation agenda. The current government, and I believe a future Labour government, if Labour were in power, is in favour of driving scheme consolidation. So the idea is that poorly performing schemes, would first of all be stopped from accepting new business from employers, and if they can't sort out any weaknesses, would then be forced to wind up and consolidate and the regulators will be given new powers to enforce that. Why is consolidation seen as so important? Well, one of the reasons is that the larger the scheme, the bigger the scale, then the greater is the likelihood that they can take on board new investment opportunities such as private equity. So it does all come back to the private equity debate In terms of advice opportunities here if you are again advising trustees, then they will want to understand how their scheme might stack up against the evolving value for money criteria. These are still under debate, but once these are published, I think that trustees will want to engage with advisers on that. But even if you're not advising in that area, once this goes live, there will be a raft of new data around about pension schemes, which will no doubt gives you new insights as part of your advice process.

(17:46): I'd now like to move on to small deferred pension pots. Now we know that as a result of the success of auto-enrolment, we've got millions of tiny pension pots, which individuals leave behind on a deferred basis when they move from one employer scheme to another. And that's a challenge for the individuals. They can lose track of them and it's also a challenge for the industry and that it costs more to administer than is taken in charges. So this is a good initiative and the way that the government has proposed to solve it is to allow a small number of schemes to apply for and be approved as multiple consolidators, small scheme, small pot consolidators. And the idea is that they will manage and bring together the stock of small pension pots under £1,000 where there will be no contributions for at least 12 months. The government is expecting it to be current master trusts which apply to be authorised for this purpose. And certainly bearing in mind I've just been talking about the drive for consolidation and scale, this would be one way of building scale. However, you're building scale by taking on lots of what are currently small pots which are unprofitable to administer. So there will be commercial considerations as to whether or not you would want to take on board that particular task.

(19:12): Whatever happens, if we do have a small pot consolidator regime, then we're going to need some new infrastructure to make that work. And there's talk of developing a new clearing house. The clearing house would first of all identify where those small pots sit, identify the population of in scope small pots. It would then have to communicate with the individuals who have those small pots to ask them, "have you nominated your small pot consolidator or would you like us to nominate one for you?" And once that's been done, the clearing house would then carry out the transfers. It would take the small pots from where they are at the moment and transfer them into one of those, those multiple consolidators. So that's quite a major industry-wide infrastructure. And we're already building an infrastructure for pension dashboards. So there may be learnings from that to draw on. However, the purpose behind the dashboard pension dashboards and this clearing house would be quite different. So the learnings may be limited In terms of latest developments here where there's not been a lot of talk about this in, in public, the government is leading a range of working groups and, and workshops to explore specific issues which were identified as part of the consultation. And we're expecting further announcements on this before the end of the year.

(20:43): So small pot consolidators are designed to deal with the stock of pots under £1,000, which currently exists. On top of that, we've had a consultation on pots for life or sometimes called lifetime provider. And this is designed to tackle not the stock but the flow of future pots. And it's actually pots of all size, not just small pots. The idea is to try to create, to stop or to limit the creation of future multiple pots as individuals change jobs. The consultation talked about two phases within which this could could work. The first would be what's being called the member choice model, but ultimately the government is also exploring a pot for life as default. So what does this involve? Under the member choice model members would be given the choice that the right to instruct their employer to pay their auto enrolment pension contributions not into the employer's workplace scheme, but to the scheme or arrangement of their choice, which could be a set or it could be a workplace pension, which they were in previously.

(21:55): Now we do accept that there will be a small minority of engaged pension savers who this will very much appeal to. In fact, there may be some of your clients who already have arranged this with an employer or who regularly transfer the money in their workplace pension over into a sip of their choosing. So this could appeal to an engaged minority, but the question is, would it ever appeal to the majority? And this is where the pot for life is default comes in. The government is suggesting that all members would pick a pot for life and those who didn't, would have one allocated to them again, perhaps through some kind of clearing house.

(22:37): The question is, if that were the scenario in future, while employers would still be required to auto-enrol individuals and forward appropriate contributions from them and from the employer and from the employee, would they actually need to set up their own workplace scheme? Would they need to nominate one or could they just rely on the money going to the pot for life of, of each of their employees choice? Aegon has expressed some concerns about if this is the right way forward and our concerns centered around the fact that we see employers as being central to the success of automatic enrolment and we're concerned that employers would be less central to the the lifetime provider type model. And if they were less central, might they be less willing to go beyond the minimum? Many employers go well beyond the auto enrolment minimum at the moment, but might they weaken the resolve if the lifetime provider model in errors. One thing which they could think as well, "if many of my employees are not joining the workplace pension I put in place, do I want to promote that strongly?"

(23:50): They may currently be paying contributions well above the auto enrolment minimum, but again, if they're less central, might they decide to reduce the employer contributions to their scheme? Either of these would as likely lead to poor outcomes for all of the employees, but in particular the unengaged majority who weren't actively seeking out a pot for life for themselves. Our other fear is that at the moment if all of an employer's employees are within one scheme, you have economies of scale and also where charges are a fixed percentage of funds, you have cross subsidies between those who are paying in more and building up larger pots to those which are paying in less and building up smaller pots. If you suddenly didn't have all the employees within the one scheme, or if you found that it was your higher earners who were choosing their own pot for life, then you could lose those economies of scale. You could lose the cross subsidies and that could mean that charges within the residual workplace pension have to rise again, not, not good news for the unengaged majority. And yes, how would employers make those payments? We'd need another new infrastructure. We'd need another clearing house so that an employer could pay all of their contributions to one point and that one point would then forward onto all of the other pension schemes that individuals have chosen.

(25:16): Aegon has been quite vocal in its concerns here, and so we were very pleased to see that in the Budget, where the government is continuing to explore this, they have said that they will slow down the pace of this so that they can research how employers and employees might react if this were to be introduced. In terms of what Labour government might do here, I don't think Labour have said much on this. And this is one of the initiatives which could be kicked into the long grass or indeed stopped entirely. And I want to look at another initiative. It was a consultation headed helping savers understand their pension choices. But what this was actually all about was offering trust-based members access to the full range of pension freedoms. At the moment, members of contract-based schemes are much more likely to receive a wide range of choice than members of trust-based schemes.

(26:14): There was quite a lot in this consultation and the way that we responded was to suggest to government that they should handle this in three stages. The first stage we're very keen is advanced urgently as a priority, and that is to for trustees to be required to offer all their members a range of choices including drawdown when they come to retire with appropriate support, whether that's guidance or ideally whether that would be full financial advice. Now, not all trust-based schemes would want to do this. Certainly small or single employer schemes are less likely to want to do this so they simply wouldn't have the expertise to do it. And the consultation does accept that. One way forward might be to enter a partnership, for example, with a master trust already offering drawdown so that the members could be referred to that so that they could then access those freedoms. And the likes of Aegon's

(27:13): Master trust already offers a drawdown facility, so we are in favour of that being moved forward relatively soon. The second proposal is one that we think needs a lot more time and thought, and this is around trustees having to put in place what's called a backstop decumulation strategy. Basically, there are members who will reach the point when they retire or want to start decumulating, but don't really engage with the process. So the idea is that trustees would come up with a backstop default, which they would then place individuals who've not engaged into. Now defaults are, we're familiar with defaults in accumulation, we've got default funds, and they kind of work because people don't have vastly different needs in the accumulation stage. But as soon as you start decumulating, things become much more personalised. What's appropriate for you will depend on your situation including whether you want to provide for a financial dependent.

(28:17): It will also depend on your preferences, whether you are keen for a guaranteed income, whether you want flexibility and if you're remaining invested what are your investment preferences and, and attitudes towards risk. Another big factor which trustees will need to think about is what might be right for the individual in terms of the pension that they have with those trustees will be affected by what other pensions that individual has, and the trustees are unlikely to know about that. When we responded, we suggested that a lot could be learned from the way that advisers go about advising clients here, and that might, for example, include advising to purchase a bit of annuity to cover basics alongside the state pension to cover the basics on a guaranteed basis, but to invest the rest and drawdown, to keep things flexible. If this were being taken forward on a non advised basis, that might need to be associated with investment pathways and also with a default percentage withdrawal to guide the individual not to withdraw too much too soon. The third proposal, and this is the one that's most out there if you like, is decumulation only CDC, trustees having to offer that as an option to their members.

(29:41): Now the problem is that these don't exist right now and they're some way off existing. So we definitely think that's one that should be part for the moment, but come back to as and when decumulation only CDC becomes a reality. Again, we see advice opportunities here. We think there will be some trustees who even before regulation goes live might be seeking to to, to step up their game and might want to consider how they could offer access to a wider range of, of pension freedoms. And that might include signposting to advice or to a specific adviser firm to, to offer that advice in the slightly longer term. We think that trustees will definitely need support in designing those backstop decumulation strategies and again, we think advisers will be well placed to help advise in that area.

(30:34): The next topic is moving away from the specific pensions level and it's the advice guidance boundary review. And as you know, this is a collaboration between the treasury and the FCA with an aim to make sure that individuals have the right support at the right time, at the right cost to make informed decisions. And I was pleased to see the FCA accept that tweaking or trying to amend the current regulated advice definition wouldn't in itself solve the problem, the advice gap, the support gap that we currently have. So I'm very enthusiastic about some of what's been proposed within this review. There were three key proposals. The first was to further clarify the advice guidance boundary. Now, the FCA has tried this before and it hasn't really moved the dial much, so I'm not sure that this further attempt will do much more than where we are today.

(31:31): However, the proposal which we made in our response was that perhaps the FCA could draft some template letters, which were designed to guide individuals in particular scenarios. And if they did that, then compliance departments might feel more comfortable with their firms offering those template letters without testing them against the advice definition. The next one I'll cover is actually the third and the call for evidence, and that's on simplified advice. Again, we have simplified advice today. We've got various forms of that today. It hasn't been particularly widely used and that's likely to be because of the commercial feasibility of offering this. So I think the question is could this be offered in a more commercially feasible manner, perhaps through a more digital approach. Another question is what would the training and competence requirements be for someone offering simplified advice?

(32:32): I think that depends on what the simplified advice is covering and that in itself we determine the extent to which you could reduce the T&C requirements and therefore save costs. Another big challenge always with simplified advice is, is how do you ring fence? Can you see that this individual had a particular need and therefore I didn't need to ask about a range of other aspects of the finances? There aren't that many scenarios where you can do that with confidence, but again, perhaps if the FCA were to go further to set out where it felt ring fencing could work, that might encourage more of the market to go down this path.

(33:15): I mentioned retirement advice on this slide and that's because in the consultation the FCA proposed or suggested that they didn't think that simplified advice would work in the at and in retirement space because the advice requirements there are so complex. Now, I do have sympathy with that, however, it's in the at retirement space, that was the greatest advice or support gap. So I do hope that the FCA will consider, continue to explore whether they can make that work. I've kept what I think is the best for last, which is targeted support. The industry has been calling for or what we were calling a more personalised form of guidance, but for a number of years now to sit somewhere between the current information, which can often be pretty bland and the fuel holistic advice offering that advisers are so good at offering.

(34:13): And so I'm very pleased that this is being consulted on. I think it could be offered and it could be made to work in two different ways. The first is that individuals could proactively ask for it. If they were aware that it was available alongside information and full advice, then they could opt for targeted support and ask for it. But I think that the most likely use would be for firms to identify that they have groups of clients perhaps who exhibit characteristics that suggest that maybe they would be better supported by doing something different or considering a different course of action. And this is what targeted support would allow firms to go out and say to to customers, people like you might find it beneficial to do X, Y, or Z. And I think that could be quite a game changer in the market. I also think that the more that individuals saw this kind of support, the more that they would understand the benefits of seeking full advice at some later stage. In terms of advice opportunities here quite clearly the way that this this review develops could have a major impact on different parts of the advice market. I don't think it will stop advisers who wish to continue as this

(35:37): to do so, but for those who want to reach parts of the market they can't currently reach with holistic regulated advice, I do think it opens up new opportunities. I also think another key area where it could work is in the workplace. Now we've got 11 million individuals who've been automatically enrolled and the vast majority of of them have not seen an adviser. So it could be that for example, EBCs or corporate advisers could be active in this area in helping members of workplace pension schemes consider things such as whether or not they're paying in enough to generate an adequate income in retirement. Consider alternatives to the default fund for investment. Start thinking about consolidation, bringing together small pots aided by the dashboard perhaps, and also start in preparing earlier for what options they might follow at retirement. Because the sooner that individuals engage with that, the more that advisers can help them have appropriate investment strategies in place.

(36:44): So I think we've covered quite a lot already today. And I'm not planning to talk for too much longer, but if you look at each of the topics that I've covered so far, I think each of them in their own rights are complex. I think what's even more complex in some ways, mind bogglingly so, is if you add them all together. And what we can't have is for any government or regulator to be trying to advance all of this all at once. We absolutely need to have a structure. We need to have an order. And this is something which we've been making very clear to regulators and to government. We've been encouraging them to come up with a priority order and we think that should be based first of all on what would make the biggest difference to member outcomes. But then secondly, which ones should be developed first to be building blocks to hopefully make future initiatives more successful.

(37:47): We also believe that every time one of those initiatives is developed, it would be appropriate to step back and decide if it has solved the problem that others might have been seeking to address. The only figure I'd like to pull out in this is the one in the final row, which shows that we think that some of the implementation of this shouldn't happen until about 2040. So that's not just the end of this decade, it's the end of next decade. So a lot for us as an industry to keep thinking about as as time goes by.

(38:25): But of course in the meantime we'll have not just one general election, but a whole range of general elections. So I'd like to finish by saying a few words about the approaching election, the 2024 as I imagine it will be election, and in particular what might a Labour government mean for financial services? And the document, which I've found most helpful in helping me paint a picture of this is a document called Financing Growth Labour's Plan for Financial Services, which they launched at the very end of January this year. It's well worth the read not least because Rachel Reeves and Tulip Sadik in their introduction said that a Labour government would unashamedly champion the financial services sector. So that would be nice, wouldn't it? So a few points I'd like to pick out from this. First of all a Labour government would continue to see financial services as a source of economic growth.

(39:27): They would want to continue to encourage investment in the UK and in private assets and they see the sector as key to delivering climate transition and green technology. So there are lots of similarities there to where the current government, the current Conservative government is focusing. If we look next at regulation, I'm very pleased, not surprised, but really pleased to see Labour supporting the advice guidance boundary review. And there were members of of the Labour party who did speak up in favour of this in Parliament. So I'm really pleased to see that this document continuing to support all aspects of the advice guidance boundary review. I'm also very pleased to see that the cross party support of automatic enrolment hasn't weakened. It continues to be strong. The document says that Labour will encourage scheme consolidation with new powers from the pensions regulator.

(40:24): So again, similar to things like the value for money framework, which I was talking about earlier. An interesting one is that they say that while they would respect the independence of the FCA, they would direct it to consult with industry to identify regulations in the FCA's current 10,000 page rule book, which may no longer be necessary as a result of the consumer duty. And having identified those go through our transparent process for working out which of those should be removed from the rule book. So that's one that you might ponder at some point. Other parts of the FCA rule book that you think aren't needed and you'd like to see go keep a note of these because if there's a Labour government you might get asked to provide your views. Labour also say they'll look across regulators, so across the likes of the PRA, the FCA and the pensions regulator to identify overlaps and also gaps.

(41:23): Now I haven't mentioned something which is probably at the top of all adviser's worry list right now when the pension shrunk, which is about whether or not if Labour are in power, they will reintroduce the lifetime allowance. Unfortunately, this document does not touch on that particular point. So no new insights there personally having seen the horrendous complexity of removing the lifetime allowance, would or should a Labour government prioritise this particularly in the early years? Surely there are other things with greater impact that they would want to focus on, but time will tell. What is talked about again under pensions is, and this is quite a wide ranging topic, that the Labour party or Labour government would review the pensions landscape as it's developed since 2000. And it would focus on whether or not the current regime, current environment, is producing sustainable retirement incomes in the best possible returns from members. So that could be very wide ranging. I'll look forward to seeing more detail of that. And finally, on retail investments, they talk about ISA simplification, so that might clash with the UK ISA, but they do say that they would like to encourage retail investors to buy British and they refer to a 'Tell Sid' campaign. I have to say that I think the 'Tell Sid' campaign from whenever it was 1984 probably wouldn't meet FCA requirements, but who knows? We'll see where that goes.

(43:00): So I think we've covered a lot of material today. I think we've got a very interesting period ahead of us, whoever is in power as we move through 2024 and also in years ahead. I also think that with these developments come a whole range of, of advice opportunities. So all it remains for me to to say is first of all hopefully you will explore more of the information and and materials that we have on our CPD adviser hub. And finally, thank you for joining me. And remember to fill in your survey, fill in your questionnaire, and claim your CPD points. Thank you very much.