Eleventh Standing Committee on Delegated Legislation

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Eleventh Standing Committee on Delegated Legislation

The Committee consisted of the following Members:

Chairman:

Mr. Bill O’Brien

†Atherton, Ms Candy (Falmouth and Camborne) (Lab)
Baird, Vera (Redcar) (Lab)
Beresford, Sir Paul (Mole Valley) (Con)
†Ennis, Jeff (Barnsley, East and Mexborough) (Lab)
Foster, Mr. Derek (Bishop Auckland) (Lab)
Holmes, Paul (Chesterfield) (LD)
†Laxton, Mr. Bob (Derby, North) (Lab)
†Mitchell, Mr. Austin (Great Grimsby) (Lab)
†Moran, Margaret (Luton, South) (Lab)
†Randall, Mr. John (Uxbridge) (Con)
†Smith, Mr. Chris (Islington, South and Finsbury) (Lab)
†Tredinnick, Mr. David (Bosworth) (Con)
†Wareing, Mr. Robert N. (Liverpool, West Derby) (Lab)
†Waterson, Mr. Nigel (Eastbourne) (Con)
†Webb, Mr. Steve (Northavon) (LD)
†Wicks, Malcolm (Minister for Pensions) (Lab)
Liam Laurence Smyth, Committee Clerk
† attended the Committee

 
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Wednesday 9 March 2005

[Mr. Bill O’Brien in the Chair]

Draft Pension Protection Fund (PPF Ombudsman) Order 2005

2.30 pm

The Minister for Pensions (Malcolm Wicks): I beg to move,

That the Committee has considered the draft Pension Protection Fund (PPF Ombudsman) Order 2005.

The Chairman: With this it will be convenient to consider the draft Pension Protection Fund (Pension Compensation Cap) Order 2005 and the draft Occupational Pension Schemes (Levies) Regulations 2005.

Malcolm Wicks: It is a pleasure to serve under your chairmanship, Mr. O’Brien. These statutory instruments are needed to give detailed effect to some important aspects of the Pension Protection Fund—the PPF as it has become known—and the Pension Protection Fund ombudsman, who I am sure will in due course become known as the PPF ombudsman. It may help the Committee if I begin by providing a brief recap on the PPF—which has now been established under the provisions of part 2 of the Pensions Act 2004—and why we created it.

The Government have made a major commitment to better protecting the defined benefits of occupational pension scheme members. The importance of such a commitment needs little explanation today. There has been well publicised and justified concern in recent years about the effects on members’ benefits when underfunded pension schemes are wound up following the insolvency of members’ employers. Many employees have paid into their occupational pension schemes for years, expecting to receive a set amount of pension in retirement, but may end up facing retirement with little to show for their hard-earned contributions.

Against that background the Government introduced a number of measures in the Pensions Act to protect the interests of members of occupational pension schemes. A key plank of the Government’s approach is the establishment of the Pension Protection Fund, which is a non-departmental public body governed by an independent board, in order to strengthen pension scheme members’ security. Following the Act receiving Royal Assent in November, the PPF board was formally established in December, and its members have now been appointed. Lawrence Churchill has been appointed chairman and Myra Kinghorn the chief executive of the new body.

So, from 6 April this year, if a company with a defined-benefit pension scheme becomes insolvent, and its pension fund is insufficiently funded to pay the
 
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PPF level of benefits, members can be reassured that in most cases they will still receive the core of the benefits that they were expecting. Broadly speaking, that will be achieved by providing 100 per cent. compensation for those members who have reached their scheme’s pension age; 90 per cent. compensation will be paid to those below pension age at the assessment date, subject to PPF rules.

Mr. Nigel Waterson (Eastbourne) (Con): I see that the word “core” has started to find its way into the vocabulary of pensions protection legislation. Can the Minister confirm that apart from any other restrictions, including the cap which we will come to shortly, the PPF will have the power to reduce benefits if the funds are not available? Will he define what he means by the core of the benefits?

Malcolm Wicks: Yes, in extremis, the 90 per cent. or the 100 per cent. could be reduced, but as the hon. Gentleman knows from our deliberations, we are giving power to the board to raise the levy by 25 per cent. in any one year—indeed, up to 100 per cent. of the original levy—before having to seek extra powers from the Secretary of State. There is considerable flexibility in the system, which I am confident will enable us to maintain the level of benefit that I have specified. We have deliberately set up a non-departmental public body, so the board will make the judgments and not, directly, the Secretary of State on a month-by-month basis.

A maximum or capped level of compensation will be set each year for those below pension age. In 2005 this will be set at £25,000. Although it is right to protect members’ defined benefits, it would be wrong to ask the taxpayer to pick up the cost. The PPF will therefore be funded by levies on occupational schemes whose members are potentially eligible for PPF compensation.

We have provided for a disputes process that will enable interested parties to seek a review of certain key decisions by the board—what we call “reviewable matters”, which are set out in schedule 9 to the Act. There is also a right of complaint against the board in cases of alleged maladministration. There will be a two-stage internal review process by the board, and if a party is still not content, he or she will have the option to refer the case to the newly established and independent PPF ombudsman. That ombudsman will be funded by a levy on schemes eligible for the PPF and will have the final say on disputes unless a party wishes to appeal to the High Court—or the Court of Session in Scotland—on a point of law.

I come now to the statutory instruments before us, which I am content are compatible with the articles of the European convention on human rights. The draft Occupational Pension Schemes (Levies) Regulations 2005 provide for the calculation, collection and recovery of the administration levy and the initial PPF levy, which are to be paid by the trustees or managers of occupational defined-benefits schemes and the defined-benefit elements of hybrid occupational pension schemes. The administration levy is charged by the Secretary of State to recoup costs of providing
 
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grants to fund the administrative costs of the PPF board. In the first few years, the Secretary of State will also recoup the costs of setting up the PPF via the administration levy.

The regulations provide for the administration levy to be charged at a per member rate, and the rate will be banded according to scheme size. That replicates the banding system used for the current Occupational Pensions Regulatory Authority general levy, and will be continued for the new general levy for the pensions regulator. The initial levy will enable the PPF to get up and running as quickly as possible, even if on 6 April this year the board will not have sufficient information to collect the risk-based and scheme-based pension protection levies.

The initial levy is charged for only a short period; that is defined in the regulations as beginning on 6 April this year and ending on 31 March next year, which is the last day of the board’s first financial year. An estimated £300 million will be needed annually for the PPF to cover the projected annual deficits of schemes brought in. However, only half the amount will be collected during the initial period, because for that period at least the PPF will not have sufficient information to charge a risk-related element.

The initial levy will be charged on a per member basis at a rate of £5 for each deferred member and £15 for each active and pensioner member. The same rates will apply to all eligible schemes, regardless of their size. That approach was decided on after studying similar organisations in the US, Japan and Germany. The approach attempts to strike a balance between fairness and affordability. The Government Actuary’s Department estimates that, on average per member, liabilities to deferred members are around one third of those to active and pensioner members. The 1:3 ratio of the £5 and £15 rates roughly reflects that.

The regulations provide for the reference day to be used in respect of each levy. That is the day on which scheme data with which to calculate the levies will be taken from the pension scheme register. For both the initial levy and the administration levy for 2005–06, the reference day will be 31 March 2005.

Where a scheme becomes eligible to pay the levy part way through the financial year, the trustees will be liable to pay a pro rata portion of the levies, beginning on the date that the scheme became registrable. However, where a scheme ceases to be eligible part way through a financial year, the trustees shall still be liable to pay the full amount of the levies for that year, and no refunds shall be paid. That carries forward the current policy of OPRA. Paying refunds would pose significant administrative problems. Furthermore, the board of the PPF will set the levies according to its prediction of the amount that will be needed for that year, so the unexpected payment of a large refund could lead to a deficit in the PPF’s funding.

The regulations make further provision for the application of the levies to schemes where only part of the scheme is eligible for the PPF. In the case of multi-employer schemes, hybrid schemes and schemes with a partial Crown guarantee, levies will be charged only in respect of those members or that part of the scheme
 
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that may become entitled to PPF compensation. The levy regulations extend to Great Britain only and a corresponding provision will be made to impose a levy in Northern Ireland. Therefore provision has been made to avoid the possibility of a double liability for schemes in Northern Ireland.

The levies regulations were laid, withdrawn for amendment and then relaid. That was because of the omission of provisions for hybrid schemes and not a change in policy. The omission was unfortunate, and we apologise, particularly to the Committee, for any confusion caused. However, the substance of the regulations remains unchanged and officials acted as quickly as possible to correct the error.

Mr. Steve Webb (Northavon) (LD): The regulations refer to hybrid schemes. As I understand it, they say that a hybrid scheme will be treated as if it were a defined-benefits scheme, pure and simple, regardless of any defined-contribution element. Is that an appropriate basis on which to impose the levy? Might that not encourage some hybrid schemes to become completely DC?

Malcolm Wicks: I am glad that the hon. Gentleman has asked for clarification. Hybrid schemes are often in part DB and in part DC, hence the name. It is important that that element which could come under the umbrella of the Pension Protection Fund is distinguished and a levy paid on it, but not on the whole. It would be unfair to pay into the PPF’s coffers for the DC element, because DC schemes are not covered by the PPF, as the hon. Gentleman knows. Therefore, the levy will be paid only on the DB element. I thought that I had made that clear when I said earlier—I am quoting myself, if that is not too arrogant—that levies will be charged only in respect of those members or that part of the scheme that may become entitled to PPF compensation.

Mr. Webb: Perhaps my intervention was not sufficiently clear. What I am saying is that someone with a scheme that is pure DB will understand that there is a lot of insurance, so they will want to be in the PPF and will not mind paying a levy; but someone with a hybrid scheme, a small part of which is DB, will not get much insurance of it. However, the levies in the regulations apply equally to hybrid and pure DB. Therefore, there might be an incentive for hybrid schemes to go pure DC, because they would pay the same levy as DB schemes.

Malcolm Wicks: They will not be paying the same levy. I am advised that the wording of the regulations might confuse, but I hope that I have clarified the position. The levy will reflect only the DB element. [Interruption.] That is the situation. Perhaps we shall return to the issue later in the debate.

I turn to the draft Pension Protection Fund (Pension Compensation Cap) Order 2005. Paragraph 26 of schedule 7 to the 2004 Act provides the Secretary of State with the power to specify by order the amount of the compensation cap. As previously noted, the compensation cap places a limit on the amount of compensation that certain individuals may receive in
 
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respect of their pension from the PPF. The compensation cap applies to those members who qualify for the 90 per cent. level of compensation—that is, those individuals who, immediately before the assessment date, are below their scheme’s normal pension age and are not already in receipt of an ill health pension or survivors’ pension.

The amount of the compensation cap is £27,777.78. That seems a slightly obscure figure, so I should explain. That amount, when applied to members who qualify for the 90 per cent. level of compensation, is effectively £25,000. That has been approved by Her Majesty’s Treasury, which I know will assure hon. Members on the arithmetic—my Department struggles to afford a calculator.

The compensation cap has two aims. The first aim is to control costs and therefore the amount of the PPF levies. The compensation cap provides the right balance between the amount of compensation payable and the burden on levy payers. The second aim is to guard against moral hazard—that is, companies becoming insolvent in order to take advantage of the PPF. The cap is especially aimed at those who have the greatest influence over funding levels, such as higher paid directors and decision makers, to ensure that they have an interest in keeping the scheme out of the PPF. The compensation cap will in real terms apply only to an estimated 2 per cent. of those below scheme pension age. PPF compensation will therefore still protect those least able to sustain a loss in their pension if their employer becomes insolvent.

I turn finally to the draft Pension Protection Fund (PPF Ombudsman) Order 2005, which makes further provision for the PPF ombudsman and any PPF deputy ombudsman. Section 209 of the Pensions Act provides for the Secretary of State to appoint an independent PPF ombudsman who will consider issues that remain unresolved after going through the PPF’s two-stage internal review process. The Secretary of State will initially fund the ombudsman and any deputy from money provided by Parliament. Such funding will, among other things, cover the remuneration of allowances and the reimbursement of expenses of the ombudsman. A levy will be raised by the Secretary of State to cover expenditure in respect of the ombudsman.

The provisions for the PPF ombudsman levy will broadly mirror those that are in place for the pensions ombudsman and those that will apply to the pensions regulator and the PPF administration levy. A similar banding system will be used, although the rate per member will be much less than that for the administration levy. For the financial year 2006–05, no PPF ombudsman levy will be raised, because the costs are likely to be very small during that initial period.

A proven template for such a role exists in the pensions ombudsman, and we have sought to use that wherever possible in the Act and the order. That is one reason why we have appointed the pensions ombudsman, David Laverick, to perform the functions of the PPF ombudsman initially.

 
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Section 209(4) of the Act provides the power for the Secretary of State to make a range of provisions by order for the PPF ombudsman and any deputy. As that subsection and this order make clear, remuneration is only a part of what we need to provide for the ombudsman so that he may function effectively. The order enables the Secretary of State to provide the PPF ombudsman with the necessary staff and facilities. The Secretary of State may also delegate some functions to the ombudsman’s staff, although the ombudsman will remain solely responsible for performing his tasks, such as reaching key determinations on reviewable matters and cases of alleged maladministration.

Finally, I draw the Committee’s attention to articles 6 and 7 of the order, which deal with the PPF ombudsman’s powers to obtain information, and place restrictions on his disclosing that information to others. The ombudsman needs access to information relevant to the cases referred to him. Article 6 of the order therefore enables the ombudsman to require information and documents to be provided to him, provided that they are relevant to his investigations. Such power brings with it a responsibility to protect the privacy of information, so article 7 states that he can disclose the information obtained only to the bodies listed in the order and only if he considers that the disclosure will help them carry out their functions.

The statutory instruments ensure that the PPF is properly funded; they protect levy payers by ensuring that there is a limit to the compensation payable; and they set out the framework for the PPF ombudsman to fulfil his remit. I commend them to the Committee.

2.48 pm

Mr. Waterson: It is a great pleasure to have you presiding over our deliberations, Mr. O’Brien. I am delighted to have the chance to speak on these three statutory instruments.

Although we spent many hours, days and weeks in a not too dissimilar Committee Room debating the Pensions Bill, as it then was, it was always clear to us that the hard questions and difficult issues would end up in a Committee such as this. This week is no exception to that prediction, because we have a series of statutory instruments—and more to come—where the really difficult questions will be addressed.

We are mainly concerned about the operation of the PPF in its various manifestations. I have already taxed the Minister about the use of the word “core”, because it is important that people understand the nature of the underpinning that the PPF will or will not provide when they lose their pension rights. I am delighted to see that “guarantee” has disappeared from the jargon issued by the Government. I could not find it anywhere in the official guide to the PPF. That is a step forward.

At one stage, Ministers were propounding the notion that the PPF provided a guarantee in the sense that the Pension Benefit Guaranty Corporation in the USA provides a guarantee, but, of course, it does nothing of the sort. Apart from the fact that there is a 100 per cent. figure for people who are retired and a 90 per cent. figure for those still in work, we have
 
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changes to indexation and a cap, which I will come on to. Most importantly, the PPF has the power to cut benefits—an issue not lost on Mr. Lawrence Churchill in the first interview he gave after being appointed to run the PPF. Now, however, the Government have started to talk about the “core” benefits and expectations from people’s pension schemes. It will be interesting to see how that jargon starts to develop, particularly as we approach the election campaign.

The Minister, perhaps with unconscious irony, made the point that there is a power to increase the levy by up to 100 per cent. to build in what he called flexibility. Of course, the flexibility that he is talking about will be at the expense of those paying the levy. That brings me on to my main point, which we made consistently throughout the passage of the primary legislation and which I will take the opportunity to repeat now. As long as one starts with a flat-rate levy, one starts from a position in which the good are subsidising the bad—a version of the concept of moral hazard, of which we heard a great deal during the passage of the Pensions Bill. Those who have been running the PBGC in America for some 30 years advised that the one thing that we should do is start with a proper risk-based levy. That is not what is happening, which is a great shame.

Eccentrically, I shall deal with the draft orders and regulations in the opposite order to the Minister—in ascending order of importance. I shall start with the draft PPF ombudsman order, which is perfectly unexceptionable. It talks about paying remuneration expenses incurred by the ombudsman and any deputy PPF ombudsman. As I think the Minister said in his opening remarks, sections 213 and 214 of the Pensions Act provide for reviewable matters and complaints about maladministration to be dealt with, and section 210 states that the Secretary of State may appoint one or more deputies to the PPF ombudsman. It would be interesting to hear in the Minister’s winding-up speech whether he has already given some thought to whether, and when, any deputies are likely to be required.

Malcolm Wicks: I should like to be helpful on that point. Today, we publicly announced the appointment of the deputy pensions ombudsman, who will also serve as the deputy PPF ombudsman. He is Charles Gordon.

Mr. Waterson: I am grateful for that and we wish Charles Gordon well. The Minister unaccountably failed to mention that we on the Conservative Benches tabled amendments that called for the existing pensions ombudsman to take on the role, at least initially, of the PPF ombudsman. Left to themselves, the Government were going to set up a wholly separate bureaucratic structure involving the PPF ombudsman. In Committee, we argued the case—for once successfully—that Mr. David Laverick, who had built up a sound and good reputation as the pensions ombudsman, should, at least to begin with, take on both roles. I am delighted that that is what happened, although the process of which we were slightly nervous seems to have already started in the sense that he is already getting a deputy. None the less, we hope that
 
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the Government, in the time that remains, can keep the bureaucracy to a minimum and build on the strengths and experience of Mr. Laverick. Therefore, we have no difficulties at all with the draft PPF ombudsman order.

We also debated the issues relating to the pension compensation cap order at great length in Committee. It was interesting that there came a point during the Committee stage when the reason for a cap changed from the need to restrict the liabilities falling on the PPF to the one set out in paragraph 7.4 of the explanatory memorandum, which states that a cap

“is intended to help prevent potential abuse of the PPF by ensuring that those higher earners, who may have influence over the management of a defined benefit pension scheme, are encouraged, by the amount of the compensation cap, to do all they can to ensure that their scheme remains out of the Pension Protection Fund.”

That is not exactly where we started from. I believe that the Government later discovered that as a possible excuse for having a cap. The explanatory memorandum goes on to state:

“The imposition of the cap will mean incentives to manipulate or take less care of the pension scheme will be significantly diminished.”

My party has never entirely accepted that as a good reason for the cap. We started from the point at which we believe the Government started: intending simply to limit the liabilities falling on the PPF.

Perhaps I might press the Minister a little further on the level of the cap. The explanatory memorandum states that, following consultation with the industry and after various representations were received, a proposal was made for

“a compensation cap ranging from £15,000 to £50,000.”

Then come the magic words:

“The amount of the compensation cap has been approved by HM Treasury.”

If the Minister is not in a position to deal with the matter today, perhaps he will write to me to explain how premiums would be affected, according to his calculations, if the cap were raised to a more realistic level of, perhaps, £50,000, which was the top end of the scale that came out of the consultations. That would be worth knowing.

The Government have an obsession with fat cats and high earners, but they should be aware—I am sure that they are—that there is only a loose correlation between high pensions and high earnings. Many long-service middle managers will be caught by the cap, while short-service fat cats may not be. Someone on £100,000 a year could serve more than 16 years before being caught by it. It will not have been lost on the Minister that another cliff edge is the scheme’s normal retirement age, as the benefit will be uncapped above it. The reactions of politicians and the media the first time a six-figure pension is paid by the PPF will be interesting.

The explanatory memorandum states:

“A Regulatory Impact Assessment has not been prepared for this instrument as it has no impact on business, charities or voluntary bodies.”

Surely the original purpose of the cap was to save the PPF—and, therefore, levy payers—money. Some in the industry have been unkind enough to describe the
 
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£300 million estimate of the cost of the levy as flaky, but to say that the cap has no impact on business costs is wrong. I would be grateful if the Minister touched on that in his final remarks.

Moving on to the draft Occupational Pension Schemes (Levies) Regulations 2005, I reiterate our starting point that a flat-rate levy is not a good idea. It certainly is not designed to engender confidence in the system. Again, some experts unkindly say that the calculations underlying the cost of the PPF seem to have been done on the back of a fag packet by a single actuary at the Government Actuary’s Department, not by the GAD itself—I would be grateful if the Minister confirmed that—that they have not been published in full, and that they have not been subjected to professional scrutiny. There is a great deal of professional and expert evidence that the predicted likely cost of the levy is too low.

In a written answer to the hon. Member for Northavon (Mr. Webb), the Minister gave at least some details of the calculations:

“The original cost of £340 million to £375 million is the difference between the assets and the liabilities of the schemes taken over by the PPF in a year.”

He went on to reiterate four assumptions. The first was that

“Data on the MFR funding levels of just over 1,000 schemes”

were used, with adjustments made. Secondly,

“The value of the liabilities if such schemes were to fall within the responsibility of the pensions protection fund were estimated on a basis equivalent to midway between the current MFR basis and the full insurance buyout costs for the liabilities.”

Thirdly,

“The cost will obviously depend on the number of firms going insolvent.”

We could have worked that out for ourselves. The third assumption continues:

“Allowance was made for the possibility of normal, poor and extreme years as far as bankruptcies are concerned, but on average over a 20-year period, the probabilities of a scheme becoming a liability of the PPF were assumed to be between about 0.3 per cent. a year for large schemes and 1 per cent. a year for small schemes. This assumed level of bankruptcy is cautious, especially given that it is very rare for large companies to go bankrupt.”

Does the Minister have any thoughts about reassessing that assumption? The fourth assumption is that

“Allowance was made for the impact of the suggested salary cap using data on the earnings of occupational schemes members from the Family Resources Survey.”

The answer was given in March last year—a year ago. The Minister went on to say:

“These costs were recently recalculated at £300 million, using the same methodology, but updated to take account of current market conditions and the decisions taken on the precise nature of the PPF compensation payable.”—[Official Report, House of Commons, 15 March 2004; Vol. 419; c. 92–93W.]

It would be helpful if, in his final remarks, the Minister revisited those estimates and told us whether there have been any thoughts about revisiting them in the 12 months that have elapsed since they were produced in that written answer.

I move on to the strange business of the withdrawn regulations. Of course anyone can get things wrong. The Government can get things wrong. So can any
 
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Government. However, it is perhaps a measure of not only the complexity involved in the legislation but the confusion that surrounds it, that the regulations have been laid, withdrawn and relaid. I quote from Pensions Week. On 14 February, it said:

“Confusion reigns over the government flagship Pension Protection Fund as the levy regulations were chopped from the Department for Work and Pensions website two days after its release on 4 February . . . it became clear that errors were made over the eligibility of hybrid schemes to pay the levy.”

The hon. Member for Northavon has already intervened and no doubt he will speak about the matter at greater length when he makes his contribution. There is still a lack of clarity about how the rules are meant to work.

The article in Pensions Week continued:

“The regulations were then put back up on the website on 10 February, three days after being removed, stating that the DC element of hybrid schemes would not have to pay the levy.

However, it still remains unclear whether money purchase schemes, which provide death benefits on a DB basis, will be exempt from a levy. Joanne Livingstone, principal at the consulting actuaries, Punter Southall, said: ‘The mistakes are a sign of panic and it’s part and parcel of the regulation being rushed through . . . The government has been changing it up to the last minute. We know less about it than we did at the start of the bill’”.

Fortunately, a DWP spokesperson was on hand to assure us:

“The regulations weren’t as clear as they could have been. This is extremely unfortunate and we apologise for any confusion caused.”

The problem is that if, despite all its resources, the DWP cannot get these matters right, how on earth are people in the real world to deal with them? Should we not listen to experts such as Joanne Livingstone, who are so concerned about the sloppiness of the drafting of the regulations?

I conclude with a factual question. Glancing through the draft regulations, I noticed that part 3, regulation 9 says:

“The initial levy is payable on 6th April 2005.”

According to my arithmetic, that is less than a month away. I ask the Minister to reassure the Committee, and you, Mr. O’Brien, that, assuming that things go as planned this afternoon, everything is in place to invoice everyone who is liable to pay the levy and to do so on the correct basis and in time to collect the levy according to that time scale.

We have already had confusion over the hybrid schemes, about which we have spoken. The explanatory memorandum says that

“no refund of the levies paid in respect of that financial year will be made.”

I think that that is unfortunate. Why should that be the case if it turns out that a scheme ceases to be eligible part way through a financial year? It is also said that the collection of the levy is to be outsourced. To whom is it to be outsourced? Again, perhaps the Minister could tell us a little about that.

Members of this Committee and those of us who served our penance on the Pensions Bill Committee would like to know that, no matter how ill-judged or ill-considered some of these matters are, in the real world they will work. I hope that the Minister will feel able to answer that series of questions.

 
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3.6 pm

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Prepared 11 March 2005