Memorandum submitted by engage Mutual
Assurance
BACKGROUND
Firstly, we would like to note our thorough
support for the CTF initiative. We believe that CTFs will significantly
encourage the provision by parents for their children's future,
and present a superb means for increasing the financial education
and capability of both children and their parents. This is particularly
true of children from low to middle income earning families who
in the future will have the opportunity to benefit from the kind
of start-of-adulthood assets that have until now been the preserve
of higher-earning families. We hope that CTFs will make a significant
contribution to the growth in a "savings habit", which
many feel is not prevalent enough in the UK.
This is not just the view of engage but also
of the vast majority of parents and children. Our own research
has shown that 70% of parents, and 68% of current 17-19 year-olds,
agree that having a lump sum paid at 18 years would have a positive
impact on their child's/their life. Also, 65% of parents agree
that CTFs will encourage them to save for their child's future.
[13]
1. ABOUT ENGAGE
MUTUAL ASSURANCE
1.1 engage Mutual Assurance is the trading
name of Homeowners Friendly Society Limited (HFSL) and its wholly-owned
subsidiary Homeowners Investment Fund Managers Limited.
1.2 engage Mutual Assurance is an enthusiastic
provider of CTFs and has actively supported the Government's efforts
to establish and promote the initiative from its earliest days.
1.3 engage Mutual Assurance is one of the
most well-established direct to consumer providers of CTFs, with
a market share of over 5%.
1.4 engage Mutual Assurance is based on
strong values of consumer trust; being on the side of hard working
families and delivering value for money financial products. We
are a leading CTF product provider with the following distribution
partners:
ASDAYorkshire Building SocietySkipton Building SocietyNAAFI FinancialScarborough Building SocietyAlliance and LeicesterCommunication Workers Friendly SocietyNational Deposit Friendly SocietyDarlington Building SocietyTeachers Friendly Society
| Access Matrix (providing CTF distribution to Housing Associations)Cambridge Building SocietyKingston Unity Friendly SocietyWanadooCatholic Building Society, Mercantile Building Society, Monmouthshire Building Society, Chorley Building Society, Scottish Building Society and Marsden Building Societyall are part of a group called Mutual One.
|
| |
1.5 Our partnerships are an important means of reaching
a wide range of customers through a variety of means. For example,
our partnership with ASDA has ensured that we now provide CTF
accounts for more than half of their eligible customers. These
parents tend to be younger, less affluent and with fewer other
forms of investments and insurance than other customersmeaning
engage is reaching the kinds of customers the CTF was designed
for and ensuring that all families have the chance to make some
provision for their children.
1.6 Through our relationship with NAAFI Financial, we
are able to provide Child Trust Funds to members of the armed
forces, including those overseas.
1.7 Last year's All-Party Parliamentary Group for Building
Societies and Financial Mutuals report noted that "Mutuals
are well placed to provide financial services to citizens on lower
incomes and the financially excluded. The importance of low value
but consistent savings and investment policies should not be underestimated".
1.8 engage Mutual Assurance is dedicated to helping people
understand the benefits of simple financial planning. This is
continued through our provision of the CTF, and as we believe
passionately in the benefits of modern mutuality, we strive ensure
that our products are made as accessible as possible for those
on lower-incomes.
2. OUR EXPERIENCE
AS A
PROVIDER
2.1 With CTFs it is important that Government payments
are seen as the starting pointso that parents and other
family members actively contribute as well. This is obviously
important for the final monetary significance of the CTF at maturity,
but we also believe it is an important opportunity to help families
start or develop the "savings habit".
2.2 That is why engage Mutual Assurance allows contributions
from £5 per month; which could be especially important to
parents with more than one eligible child. Other providers may
not offer this due to cost implications, highlighting the importance
of modern mutuals such as engage and our commitment to improving
hard-working families access to simple, value for money products
that could preserve, protect or enhance their welfare.
2.3 50%[14]
of engage Mutual Assurance's Child Trust Fund customers are making
regular contributions to their accountsnearly double the
survey average of 26%, according to recent independent research
from BDRC. [15]
2.4 By offering the option to make regular Direct Debit
contributions from just £5 per month, engage believes that
it is helping many parents who are busy adjusting to the financial
impact of a new arrival to kick-start their child's savings, especially
those who have more than one child eligible for a CTF.
2.5 engage is committed to making regular saving to CTFs
as accessible as possible and has therefore been a leading provider
of web-based access to CTFs.
2.6 According to the BDRC[16]
research only 6% of parents applied for their child's account
online, this compares with 65% of engage customers. [17]We
believe this is a particularly important avenue of account application
as parents of young children may not have the time available to
visit a provider's branch. Equally online application can reduce
some of the inertia that has caused some parents to not yet open
an account.
3. WHAT WE
WOULD LIKE
TO SEE
IN THE
FUTURE
Voucher use
3.1 While the CTF has been an undoubted success, there
are unfortunately too many parents not proactively choosing the
provider of their child's account. We believe that this could
be alleviated by reforms to the voucher system and more focused
Government advertising.
3.2 We would like to see the Government considering the
use of electronic vouchers rather than the current paper system.
To open an account at present parents need to present their chosen
provider with the paper voucher. This can often slow the application
process and could even contribute to the inertia that has stopped
some parents from proactively using their voucher. Electronic
vouchers would facilitate internet application, an approach that
we have already proved could be much more successful in generating
e-take up of CTF.
3.3 Vouchers could still continue to be sent in paper
form to parents, but we feel the parent should have the chance
to register the voucher, and therefore an account, online without
having to send the provider the paper voucher. This would increase
the ease of account opening for parents during what is a particularly
hectic period.
3.4 engage welcomes the Government's recent advertising
drives regarding CTFs and we believe they have been successful
in increasing take-up. However, we feel that this may have been
further increased had the adverts made more explicit to parents
the potential loss to their children if they do not proactively
chose an account and investment option. We would also suggest
that the Inland Revenue accompany each voucher with an independent
action/decision tree that makes it clear to parents what the next
steps are.
Stakeholder accounts
3.5 engage shares the concerns of others that too many
parents are not giving due consideration to opting for an investment
account rather than a savings based one. Independent research[18]
notes that 53% of parents are opting for a savings account CTF
rather than an investment based one. This could have serious implications
for the fund growth within these children's accounts. When investing
money for a long time, accounts that invest in equities almost
always produce a better return than savings accounts; this is
true for every 18-year period in the last 40 years. [19]
3.6 We understand that for some parents there are very
sensible reasons for not opting for an investment account, such
as bad previous experiences of investment returns. However, we
feel that too many parents are not making an active decision in
this area. Research has noted that only 54% of parents were offered
an account choice when they applied to their chosen provider.
[20]
3.7 Very few parents take advice when choosing a CTF
account so it is important to ensure that parents make as informed
a choice as possible through independent information. Government
advertising needs to highlight that a CTF can be an investment
account as too many parents assume that it is simply a basic savings
account. Equally parents need to be made more aware of the potential
longer-term benefits of a Stakeholder account, particularly as
it has built in "lifestyling".
Helping Children get the most out of their CTF at age 18
3.8 Research commissioned by engage highlights that parents
have some concerns over how their children could use their CTF
amount at age 18 yearswhich may discourage contributions
by some.
3.9 Nonetheless, we are pleased to note that overall
parents were very encouraged by CTFs. We found that 70% of parents
strongly or slightly agreed that having a lump sum paid at 18
would have a positive impact on their child's life, and that 65%
also strongly or slightly agreed that Child Trust Funds will encourage
parents to save for their children's future.
3.10 Our research[21]
highlighted that most children would use such a lump sum for activities
supported by parents, such as further education, savings and purchasing
a car. In fact, the most popular option, voted for by 25% of the
youngsters surveyed, was saving for a rainy day. Asked what they
would do with a potential fund of £13,000 almost two thirds
(64%) of 17-19 year olds surveyed said they would save 75%+ of
their trust fund for the future; 90% said they would save over
50% of the amount.
3.11 It could be made easier for children to continue
saving all, or part, of their CTF final amount at age 18 years
by encouraging them to put their financial education into action;
developing a lifetime "savings habit".
3.12 For example, this could take the form of the provider
being able to "auto-enrol" CTFs into a savings vehicle
if the child does not actively ask to withdraw the final amount,
perhaps linking up with other Government or wider savings solutions
such as Individual Savings Accounts (or even a pension), or providing
an additional incentive for those 18 year olds who choose to continue
saving.
Default account providers
3.13 Currently if the parent fails to open an account
with a chosen provider the Government does so on their behalf.
The Government chooses providers on a rotation basis of registered
providers, allowing an even distribution of default accounts.
We would like to express our support for the current system of
voucher allocation. We believe it maintains the best range of
choice for consumers, as well as being fair for all organisations
involved. Any change to this arrangement could threaten competition
and lead to a reduction in the innovation provided to the market
by modern mutuals.
Further payments at secondary school age
3.14 In the 2005 Budget the Chancellor began consultation
on making a further Government payment to CTFs during the child's
secondary school age. engage whole heatedly supports this as we
have done for their commitment to make further payments when the
child reaches age seven years.
3.15 In our response to the consultation we supported
this payment being made at age 11 years, for the reason that there
already existed significant CTF landmarks at age 16 years to stimulate
financial education, and that a flat rate payment made universally
at 11 years could benefit from five more years of investment/savings
growth.
3.16 Age 16 is an opportune stage to provide the child
with financial education. At this stage they also gain personal
investment control over the account and will therefore have to
understand issues of investment risk, investment options and "lifestyling".
It will also be the last chance to discuss with them at school
the potential uses they may put their CTF account to following
maturity.
3.17 We also believe that there is another important
educational landmark at the age of 16, which could link up with
the CTF. At the age of 15-16 years children are considering whether
they will be staying on at school for a further two years. To
encourage greater educational attainment, HMT, along with the
Department for Education and Skills, has established the means-tested
Education Maintenance Allowance; providing weekly payments of
between £10-30 to pupils from low-middle income households
who decide to remain in education (additional bonus payments of
£100 are payable, based on achievement).
3.18 Any financial education given in schools at the
age of 16 years (and beyond) could ask children if they would
consider making weekly contributions to their CTF, or at least
depositing some of their bonus payment, if achieved. This could
well help encourage the "savings habit" among children.
Account availability
3.19 CTFs are currently available to children living
in the UK born on or after 1 September 2002. We have therefore
understandably had requests from many parents with a child born
on each side of this date for their older, non-eligible, children
to be provided with an account. We understand that for fiscal
reasons vouchers cannot be provided for all children. However,
we would like the Government to consider allowing CTFs to be provided
for such children without Government vouchersallowing parents,
if they wish and have the necessary funds, to make up the difference
so that both children may equally benefit from a lump-sum at age
18.
Registered parent
3.20 Under current CTF rules only one parent/guardian
may register as the account-controller upon application. This
means that the provider cannot issue the non-registered parent
with any information on the account. While we understand that
for practical reasons only one parent may have control over the
investment choices of the account, we would like to see it made
possible for the other parent to at least be able to receive progress
reports on the accountmaking CTFs more compatible with
modern family arrangements.
Contribution cap
3.21 Currently parents can contribute a maximum of £1,200
into their child's CTF per year. We understand the need for a
cap due to the tax privileges of a CTF. To ensure that this cap
remains as valuable, we would like to see the Government link
its value to a relevant form of price index.
November 2005
13
engage commission research conducted by CAPIBUS in February 2005
(1,000+ samples). Back
14
engage Mutual Assurance MIS. Back
15
BDRC Syndicated Survey Wave 6 January-June 2005. Objectives:
to establish parental awareness of the CTF, patterns of registration
behaviour, savings intentions, account opening intentions and
use of CTF funds. Back
16
Ibid. Back
17
engage MI figures. Back
18
BDRC Syndicated Survey Wave 6 January-June 2005. Back
19
HMRC www.childtrustfund.gov Back
20
BDRC Syndicated Survey Wave 6 January-June 2005. Back
21
engage commission research conducted by CAPIBUS in February 2005
(1,000+ samples). Back
|