| First name and last name: |
|
| Name of your organisation: |
|
Is your organisation included in the Transparency Register? (If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?) |
|
| If so, please indicate your Register ID number: |
|
| Type of organisation: |
|
| Please specify the type of organisation: |
|
| Type of public authority |
|
| Please specify the type of public authority: |
|
| Where are you based and/or where do you carry out your activity? |
|
| Please specify your country: |
|
| Field of activity or sector (if applicable): |
|
| Please specify your activity field(s) or sector(s): |
|
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published? (see specific privacy statement ) |
|
| 1. Do you offer personal pension products to consumers? |
|
| If yes, please specify in which Member States: |
|
2. What are the issues which limit the development of personal pensions in your Member State? (Please specify your answer below in maximum 500 characters. You may reply to one or several categories)
a. National legal requirements (e.g. prudential rules governing providers, administrative rules, tax regime for personal retirement saving, non-tax legal requirements, etc.) |
|
| b. Barriers to entry for providers (e.g. costs are too high to enter the market, competition is not strong enough on the market, the current low interest rates disincentivise providers to offer long-term products, etc.) |
|
| c. Insufficient demand from individuals for personal pensions (e.g. lack of information about pension savings, low level of individuals' financial literacy, lack of interest in pension savings, insufficient income for pensions savings purposes) |
|
| d. Insufficient public policy incentives to stimulate saving in personal pension products |
|
| e. Any other limitation |
|
3. What are the issues which limit the development of personal pensions across borders? (Please specify your answer below in maximum 500 characters. You may reply to one or several categories)
a. Varying national legal requirements (e.g. complexity of national legal frameworks, differing national tax requirements, difference in conduct of business rules, etc.) |
|
| b. Challenges for providers to operate cross-border (e.g. high set up costs, high operating costs in another Member State, language issues, unfamiliar customer base, branding issues, local dominant distribution channels, presence of conflicts of interest in the distribution channels, etc.) |
|
| c. Insufficient demand from individuals for cross-border pensions (e.g. uncertainties about cross-border providers, perception that a cross-border pension would only be relevant in case of mobility, etc.) |
|
| d. Any other limitation |
|
| 4. Should there be a default investment option in a personal pension product which would provide simplicity and safety catering for the needs of a majority of personal pension savers? |
|
| 5. Which type of protection should be attached to the default investment option ensuring simplicity and safety for investors in personal pensions? |
|
| Please specify: |
|
| 6. Should the number of alternative investment options be limited? |
|
| If yes, please specify the scope of the limitation and which type of protection they should feature: |
|
7. Should a personal pension product be portable? (Please tick the appropriate field, only one choice is allowed per category of reply) |
| Across Member States |
| Within the same Member State |
| Both within the same Member State and across Member States |
|
| 8. What are the main barriers for portability of existing personal pension products? |
|
| 9. The PRIIPs Key Information Document (KID) provides an example of pre-contractual information disclosure. Should the KID be used for the purposes of personal pensions disclosures? Alternatively, which KID elements could be directly used for disclosures regarding a potential EU personal pension and what are the elements that should be adapted (e.g. to take into account the long-term nature of the investment)? |
|
10. What information, in your opinion, is most relevant to individual savers before signing up to a product? (Please tick the appropriate field, only one choice is allowed per category of reply) |
| Available investment options |
| Different types of fees |
| Level of fees disclosed annually |
| The rate of return over the last two years |
| Level of protection provided |
| Information provided in a standardised format (similarly to the PRIIPs KID) |
| The tax regime for contributions, returns and pay-outs |
|
| Is there any other information that would be of importance for savers before signing up to a product? |
|
11. What information, in your opinion, is most relevant to individual savers during the lifetime of the product? (Please tick the appropriate field, only one choice is allowed per category of reply) |
| Current investment option |
| Available investment options |
| Level of fees |
| The rate of return |
| Level of protection provided |
| Accumulated benefits |
| Expected benefits at retirement |
| The tax treatment of savings |
|
| Any other information that would be of importance for savers during the product lifetime? |
|
| 12. As a provider, which types of distribution channels would you favour in order to maximise the benefits and efficiency gains of a Single Market for personal pensions (e.g. online/face-to-face, directly/via agents)? |
|
| 13. Would you consider that advice should be mandatory for the provision of personal pensions? |
|
| 14. Under what conditions should it be possible to switch personal pension providers? |
|
Please explain: (optional) |
|
15. Which forms of pay-out should be favoured? (Please provide an explanation of your choice) |
|
Please explain: (optional) |
|
16. Overall, in your opinion, what factors would encourage competition to offer high quality, affordable personal pension products? (Please tick the appropriate field, only one choice is allowed per category of reply) |
| Level of fees and returns |
| Transparency on fees and costs |
| Type of investment policy (active vs passive) |
| Ease of distribution |
| Consumer awareness of the availability of retirement products |
| A benchmark to assess the product's performance, safety and simplicity |
| Tax and other financial incentives to personal pension savings |
|
17. In your experience, to what extent are tax incentives important for the uptake of personal pension products by savers? Please explain: |
|
| 18. If you are a provider offering personal pension products in other Member States, how do you accommodate differing national tax regimes? |
|
| Please specify: |
|
19. In your opinion, what are the most significant benefits of providing personal pensions on an EU scale? (Please tick the appropriate field, only one choice is allowed per category of reply) |
| Larger pools of assets due to a wider reach |
| Opens up the market to other providers |
| Improved asset allocation |
| Product innovation |
| Improved returns |
| Lower operating costs |
| Attractive to mobile customers |
| Attractive to regular (non-mobile) customers |
| Encourages a level playing field between providers |
|
| Others? Please specify: |
|
20. The EU could foster cooperation between stakeholders (Member States, providers, consumers) around a common approach to providing personal pension products. This would imply designing together with the national authorities, pension industry and consumers a series of recommendations which providers could follow when offering personal pensions.
Fostering cooperation among stakeholders would... |
| Enhance the take-up of personal pensions by consumers in the EU |
| Enhance cross border offer of personal pension products by providers in the EU |
| Widen the range of providers |
| Enhance efficiency, asset allocation and returns when offering personal pension products |
| Contribute to innovation within the personal pension product market |
|
| Other (please specify): |
|
21. A European personal pension account could be established, similarly to the Individual Retirement Account (IRA) offered in the United States. An IRA is a personal savings plan that gives individuals tax advantages when saving for retirement. It encompasses different types of plans, depending on the income or employment status of an individual, their tax circumstances and the investment options they choose. There can be many different types of providers: an IRA can be opened with banks, credit unions, insurance companies, mutual fund companies and brokerage firms. Most IRA providers offer a broad variety of investment options, including stocks and bonds, money market funds and mutual funds.
Would such an approach address the challenges below?
A personal pension account would... |
| Enhance the take-up of personal pensions by consumers in the EU |
| Enhance cross border offer of personal pension products by providers within the EU |
| Widen the range of providers |
| Enhance the efficiency, asset allocation and returns when offering personal pension products |
| Contribute to innovation within the personal pension product offer |
|
| Other (please specify): |
|
22. A European personal pension product could be established on a voluntary basis, based on a set of common and flexible features, in order to provide pension income in retirement. Such features could include transparency and disclosure requirements, investment options, accumulation and decumulation options, distribution specificities, guarantees on the product, and fees and charges levied. The main difference between a personal pension account (described under question 36) and a personal pension product is that a personal pension account does not pre-define investment options. The role of tax advantages would be similar for the personal pension account and the personal pension product. This approach could take inspiration from the Undertakings for Collective Investment in Transferable Securities (UCITS), European Long Term Investment Funds (ELTIF), the EuVECA and EuSEF funds, the European company statute and the EIOPA advice on the development of a Pan-European Personal Pension Product.
A European personal pension product would... |
| Enhance the take-up of personal pension products by consumers in the EU |
| Enhance cross border offer of personal pension products by providers within the EU |
| Widen the range of providers |
| Enhance the efficiency, asset allocation and returns when offering personal pension products |
| Contribute to innovation within the personal pension product offer |
|
| Other (please specify): |
|
23. The EU could consider harmonising national personal pension regimes, in particular on the aspects of prudential supervision, possible providers, maximum costs, disclosure requirements, distribution models etc. but excluding tax requirements. Would such an approach address the challenges below?
Harmonising national personal pension regimes would... |
| Enhance the take-up of personal pension products by consumers within the EU |
| Enhance cross border offering of personal pension products by providers within the EU |
| Contribute to a wide range of providers to offer personal pension products |
| Contribute to enhancing the efficiency, asset allocation and returns when offering personal pension products |
| Contribute to innovation within the personal pension product offer |
|
| Other (please specify): |
|
24. Would you favour an alternative EU approach? Please provide details. |
|
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here: |
|