53.Since we launched our inquiry in July 2020, debate in and out of Parliament has led to legislative changes through the Pension Schemes Act 2021 which will allow people’s statutory right to transfer from their pension scheme to be restricted where there are signs of a pension scam. Regulations will be developed by DWP and are expected to be in place later this year. The previous statutory right to transfer was clarified in 2016 when the High Court ruled that Royal London was not able to decline a member’s transfer request where there were concerns about the possibility of a pensions scam, overturning a decision by the Pensions Ombudsman.
54.There have been calls since 2016 to introduce legislation which would allow people’s statutory right to transfer to be restricted where there are signs of a pension scam. Before the Pension Schemes Act 2021, the Pensions Management Institute, a pensions professional body, told us that pension providers and schemes are the “first line of defence in preventing scams” but “there is only so much providers and schemes can do, not least given the statutory right to a transfer set out in legislation.”
55.Warning someone that they are about to hand their pension to a scammer is often not enough to prevent them doing so. As part of the Police Foundation’s report, Protecting people’s pensions: Understanding and preventing scams, it undertook a survey of pension companies which found that 70% of pension companies reported that insistent customers wanting to transfer were a major challenge. Some companies described insistent customers being groomed by scammers:
Scammers are often skilled salespeople (with confidence and few scruples) and pension scheme members are often primed with certain messages about what their pension schemes might do or say to attempt to dissuade them from transferring before they even get to us (or we can get to them).
Lorraine Harper, Client Relationship Director and Head of Proposition at Mercer, told us that “We are caught between a rock and a hard place. If somebody has a right and we do not have a very clear reason to refuse a transfer, we have to do it.”
56.Many of the submissions we received called for trustees to be given the power to block transfers, when they have reasonable grounds for suspicion that a transfer is going to a fraudulent scheme. M&G PLC, a savings and investment company, said that giving trustees and providers greater discretion to pause transfers where there are suspicions of a scam may help in some situations.
57.We wrote to the Minister for Pensions and Financial Inclusion in October 2020, during the passage of the Bill, seeking assurances that the powers in clause 125 are sufficiently broad to enable the Government to set out regulations which would limit the statutory right to transfer. The Minister provided us with those assurances and committed during the passage of the Bill to work closely with us and the Treasury Committee on the regulations.
58.Our understanding is that regulations will be in place by autumn 2021 to allow trustees to restrict transfers to suspicious schemes, in line with the Pension Schemes Act 2021. The regulations will identify potential indicators of pension scams which would raise either red or amber flags. A red flag would allow a transfer to be blocked and an amber flag would allow a transfer to be paused until a person has received appropriate guidance. If trustees allowed a transfer to a scheme which showed signs of being a scam without making the necessary checks it may then be possible for a complaint to be considered by the Pensions Ombudsman.
59.The red and amber flags being drawn up by the Department will need to strike a careful balance between protecting savers, being easily used by trustees and not being overly restrictive. Richard Piggin, Head of External Affairs and Campaigns at Which?, told us that “it is important that we avoid box-ticking rules and that regulations remain flexible to respond to the different ways in which fraudsters will operate.” The Association of British Insurers, an insurance industry trade association, also supported proposals to refuse transfers to suspicious schemes, but warned that “it needs to be clear that providers will not face negative consequences for flagging suspicions, and therefore preventing transfers, in good faith; and needs to enable routine transfers to be conducted rapidly.” Brian Thorne, Principal at the professional services consultancy Barnett Waddingham, told us that from the industry’s perspective “any legislation or accompanying regulatory guidance would need to be very clear about under what circumstances transfers could be blocked or paused.”
60.The Financial Conduct Authority (FCA) hosts a warning list on its website. The warning list publishes details of unregulated entities which appear to be carrying out an FCA regulated activity without the requisite authorisation or permission. Throughout our inquiry we have asked whether the fact that an entity involved in a pension transfer appeared on the FCA’s warning list would be sufficient grounds to block the transfer, perhaps by raising one of the proposed red flags. The Minister for Pensions and Financial Inclusion told us that the powers under section 125 of the Pension Schemes Act 2021 do not allow a transfer to be blocked by reference to a warning list operated by a third party organisation, such as the FCA. Instead the Minister told us “Putting it bluntly, we will fix the FCA warning list problem by another means”. Emma Varley, Head of DC and International Private Pensions Policy at the Department for Work and Pensions, expanded on this, saying that the Department believed that, by focussing on the red flags identified by the Pension Scams Industry Group, it would “capture all of those elements that do get somebody on the warning list”.
61.The Pension Schemes Act 2021 will allow people’s statutory right to transfer from their pension scheme to be restricted where there are signs of a pension scam. Regulations will be developed by DWP and are expected to be in place later this year. This will be a significant step in preventing pension transfer scams. Pension scheme trustees will be required to check if a transfer showed signs of a pension scam before allowing it to take place. If a trustee, through a lack of due diligence, allowed a transfer to a scheme which showed signs of being a scam then we believe that the Pensions Ombudsman must be able to require the scheme to compensate the victim. We recommend that a review of the legislation should be published within 18 months of the regulations being operational. If there are any concerns about the operation of the policy this will allow legislative changes to be made during this Parliament.
62.The regulations will identify potential indicators of a pension scam which would raise either red or amber flags. A red flag would allow a transfer to be blocked and an amber flag would allow a transfer to be paused until a person has received appropriate guidance. The red and amber flags being drawn up by the Department will need to strike a careful balance between protecting savers, being easily used by trustees and not being overly restrictive. We recommend that the suitability of the red and amber flags should form part of the 18 month review and then be reviewed at least every 3 years thereafter.
63.The FCA hosts a warning list on its website. The warning list publishes details of unregulated entities which appear to be carrying out an FCA regulated activity without the requisite authorisation or permission. The Minister for Pensions and Financial Inclusion told us that the powers under section 125 of the Pension Schemes Act do not allow a transfer to be blocked by a warning list operated by a third party organisation, such as the FCA. We recommend that inclusion on the FCA warning list should constitute a red flag. If this is not possible, then the red flags developed by DWP should be defined in such a way that any firm or individual appearing on the FCA warning list would trigger a red flag.
64.The move online by pension scammers has been a recurring theme of our inquiry. Scammers can advertise themselves online, they can contact potential victims through social media and they can impersonate legitimate businesses or claim a fictitious relationship to one. Aviva, an insurance and asset management company, told us that since the first covid-19 lockdown in 2020 it had “identified 27 fake web sites purporting to be Aviva, trying to defraud pension age customers of their investments.” The Association of British Insurers, an insurance industry trade association, told us that even once a fake website has been discovered “there are several obstacles to taking down the website leaving the public vulnerable to scams for a prolonged period.”
65.A ban on pensions cold-calling was introduced in January 2019, which made this method of contacting potential victims more difficult for pension scammers. A J Bell, an investment platform, pension provider and investment manager for retail investors, suggested that the cold-calling ban could be “extended to include social media, emails and text.” Quilter, a wealth management business also told us that the cold-calling ban had pushed scammers online and towards social media. Quilter added that:
As it currently stands, there is no legally enforceable system for compelling search engine providers to remove suspected scam adverts, which unnecessarily exposes more people to the scam. We also believe there are few checks undertaken by search engine providers in the first instance to filter out fraudulent adverts in their due diligence process.
The Investing and Savings Alliance (TISA), a financial services industry body, told us that the cold-calling ban would be improved if it was “extended to include social media, emails and texts, which are now an everyday method of communication and not considered unusual to receive out of the blue.”
66.Regulators appear powerless to hold online firms to account for hosting scam advertisements in the same way they would be able to for traditional media. The Minister for Pensions and Financial Inclusion told us that:
I do think there is a dramatic difference between the way we regulate newspapers, TV companies and online providers, and these are the providers of information, in reality, in not that different a way.
The Financial Conduct Authority is both the criminal law enforcement agency and the regulator for the financial promotions regime. The Financial Promotions Regime requires that most financial promotions should be checked by an FCA-authorised firm to ensure that the promotion is clear, fair, and not misleading. But communicating or approving financial promotions is not a regulated activity itself. The FCA thinks that online platforms should bear clear legal liability for the financial promotions they pass on, at least to the same extent as traditional publishers of online promotions. This would mean that online publishers would have to ensure that any financial promotion which they communicate has first been approved by an authorised person or is exempted. It told us that:
We also pay Google to flag warnings to consumers searching for investment opportunities through Google’s search engine. We have 3 priorities in our ongoing work with Google: first, to remove and refuse advertisements from advertisers which are likely in our view to be scams and appear on the FCA warning list; second, to refuse financial promotions which are not placed or signed off by an FCA authorised firm; and third, to refuse lead generating advertisements which could tempt consumers to embark on a journey that leads to potentially harmful investment.
In the first eight months of 2020, Mark Taber, a volunteer consumer finance campaigner, reported 380 scam adverts targeting savers using Google to the FCA. Mark Taber told us that it can take weeks or months for the FCA to issue a warning—and that this appears to be the only action.
67.Scammers using paid-for online advertisements appear to be particularly hard to tackle without the co-operation of the hosting firm. Mark Taber told us that:
Google Ads has a 90% share of the online paid keyword search market in the UK. Paid keyword search is a highly efficient means for pensions & savings scammers to target their victims. Not only does it enable them to precisely reach potential victims through targeting keywords and phrases such as ‘top ISA rates’ but also they can instantly have an advert placed at the top of the paid search results and above the natural search results simply by outbidding genuine advertisers. Furthermore, fraudsters and scammers are able to outbid genuine advertisers because they have no intention of providing a return on or repayment of money they obtain from their victims.
The consumer organisation Which? told us that in July 2016 it found:
… a significant number of paid-for adverts on search engines such as Google that were aimed at attracting consumers seeking to find out how to withdraw money from their pension, following the pension freedom reforms. Many adverts appeared to offer pension advice, but were in fact linked to unregulated lead generation websites, while other companies overstated the ease, speed and benefits of pension transfers, or pitched the potential benefits of releasing cash from a pension without mentioning the risks.
Tim Fassam, Director of Government Relations and Policy at the Personal Investment Management and Financial Advice Association, warned that association fraud (in which a scammer purports to have an association with a legitimate firm) is increasing:
This is on social media or on search engines. People are not pretending to be one of our members, they are pretending to have an association with one of our members. This makes it much harder to crack down and to get those removed.
68.Mark Steward, Executive Director of Enforcement and Market Oversight at the FCA, told us:
… it is the FCA that is paying social media for some of these warnings to appear. The irony is very rich, that social media is receiving a fee from both the scammer and the regulator. We do not think there is parity between, for example, traditional media and social media in these matters. It is clear that social media is largely unregulated in this space and that there are few gateway controls on the admission of advertising into either the search engines or Twitter or with Instagram. That is something that concerns us.
69.Currently, responsibility for an advertisement online lies with the firm placing the advertisement, or with the FCA authorised firm which has approved it. If the FCA wants an advert to be removed it needs to demonstrate to the online company that an advert is illegal on a case by case basis. Traditional publishers of financial promotions have to ensure that any financial promotion which they communicate has first been approved by an authorised person or otherwise falls within the scope of an exemption in the Financial Promotions Order. The Economic Secretary to the Treasury told the House, in a response to the Gloster report into London Capital Finance, that:
The Treasury is working with the FCA to consider whether paid for advertising on online platforms should be brought into the scope of the financial promotions regime. The Treasury is also working with the Department for Digital, Culture, Media and Sport to ensure that fraudulent online advertising is addressed as a priority harm through its Online Advertising Programme.we ex[
70.The Minister for Pensions and Financial Inclusion was unequivocal in his assessment of the current situation:
I have absolutely no doubt whatsoever that Google needs to take a very, very, long, hard look at itself and to change its ways. There is no question that effectively taking money from fraudulent organisations on your website in circumstances where there is, it seems, very limited assessment of the merit of the organisation before it is allowed on the website—the consequential damage that is then done to all of our constituents by people then thinking that they are going to the Prudential or to Legal and General or to Aviva, or whoever it is, is massive. I read the evidence of the gentleman from Aviva, who, I think, went to the next degree, where they were paying money to persuade Google to take down sites and advertising that their own site may be subject to fraud as well.
The Minister added:
We have reached a situation where the No. 1 provider of information is not a newspaper or an encyclopaedia; it is Google, quite clearly, and to a lesser extent the problem is with Facebook. We, as legislators, need to take a very long, hard look at how we are going to regulate online operators on an ongoing basis. Clearly, this is a decision way above my pay grade. It is a decision not even in my Department, but I have very strong and unequivocal views that what is going on, and what Google and Facebook are allowing to happen, is utterly unacceptable.
71.The Online Safety Bill expected from the Government imminently has been promised for some time, including through the April 2019 Online Harms White Paper. On 15 December 2020, the Government announced its decision to bring forward legislation, but also signalled its intent to exclude certain harms from the scope of the legislation. Richard Piggin, Head of External Affairs and Campaigns at the consumer organisation Which?, told us that “unbelievably” scams were not part of any proposed online harms legislation. Peter Hazelwood, Group Financial Crime Risk Director at Aviva, told us that big technology companies are seen as “key enablers of fraud” and that “it would be highly beneficial to extend the Online Harms Bill to include the advertising of fraudulent investments, including pension scams.”
72.Graeme Biggar, Director General of the National Economic Crime Centre, agreed with this assessment. He told us:
We all see this as a big problem, we all think that the online world needs to do more about it, and we all think that some form of regulation is necessary. The online harms Bill at the moment is a missed opportunity in that regard.
Mark Steward, Executive Director of Enforcement and Market Oversight at the FCA said that recognising investment fraud as a harm in the Bill “would go some way to helping”. The Financial Services Compensation Scheme told the Government that the Bill should include extra powers to tackle online scams. It said that clarity is required between regulators and advertising platforms on who is responsible for financial promotions. The FSCS also suggested that this may entail making online providers legally responsible for the losses of consumers who fall victim to scams advertised on their platforms.
73.The move online by pension scammers has been a recurring theme of our inquiry. Regulators appear powerless to hold online firms to account for hosting scam advertisements in the same way they would be able to for traditional media. Scammers using paid-for online advertisements appear to be particularly hard to tackle without the co-operation of the hosting firm. It is immoral that tech firms such as Google are accepting payment to advertise scams, and then further payment from regulators to warn about the scam. It should not require legislative solutions to deter global firms from benefitting from the proceeds of crime, but unfortunately legislation is clearly needed. We recommend that, in order to create parity between traditional media, such as TV and newspapers, and new media, including search engines and social networks, paid-for advertising on online platforms should be covered by the regulatory framework for financial promotions. This would require online publishers to ensure that any financial promotion which they communicate has been approved by an authorised person or is exempted from the financial promotions regime.
74.On 15 December 2020 the Government announced its decision to bring forward legislation for the Online Safety Bill but also signalled its intent to exclude financial harms from the scope of that legislation. It is notable that several public bodies, including the Financial Conduct Authority and National Economic Crime Centre, are openly saying that there is a better approach for the Government to take than the one it has chosen. We recommend that the forthcoming Online Safety Bill should legislate against online investment fraud.
75.In the period between now and any legislation coming into force, we recommend that voluntary codes of conduct should be developed by search engines and social networks which make it clear that a request from a UK-based regulator is sufficient to remove a scam advertisement.
76.Last year fraud became the biggest single reported crime. Commander Blackburn, National Coordinator for Economic Crime at City of London Police, told us:
You are more likely to be a victim of fraud than any other crime type; I think we need to remember that.
There is a lack of understanding that most people are at risk of becoming pension scam victims; overconfidence among savers is a serious concern. The Pensions Policy Institute, an independent expert research organisation, told us:
Three quarters (76%) of people feel confident at spotting pension scams. However, in 2016 Citizens Advice carried out an experiment in which participants were shown mock pension adverts. Almost nine in ten (88%) participants who took part selected a pension access offer containing pension scam warning signs.
Margaret Snowdon, Chair of the Pension Scams Industry Group, told us,
Even though we have campaigns to alert people to pension scammers, 50% of people still do not think it matters to them because they would never be fooled by a scammer, but the truth is they always can be victims.
77.The Financial Conduct Authority is the Project Bloom lead on raising public awareness of pension scams. With the Pensions Regulator, it has been running multi-year ScamSmart campaigns since 2014 to alert consumers to the risk of scams. The Department for Work and Pensions told us that the campaign began by focussing on investment scams but has grown to incorporate pension scams as well. Mark Steward, Executive Director of Enforcement and Market Oversight at the FCA, told us:
The campaigns that we have run through Project Bloom and the ScamSmart website that the FCA runs, together with the other information that we have, have been very effective but I think it has always been limited by the amount of money we have had to spend on it. It needs much broader, saturating coverage. That is what happened in Australia and it is worth looking at. The success of these campaigns has been good; I think we need to go further but there is a real question of resource and money here.
78.The Investing and Savings Alliance, a financial services industry body, said that the joint TPR/FCA ScamSmart awareness campaign had been successful, but “in order to be an effective force against pension scammers, a single body should operate with ultimate responsibility for setting and co-ordinating the approach”. The trade association PIMFA said that a drawback of the current approach is that “those most vulnerable to scams may not have the wherewithal to seek out the FCA website for example and check to see whether or not a firm appears on their register” and pointed to automatic enrolment and PPI as large scale advertising campaigns which improved “consumer awareness and understanding of issues relevant to them that they ordinarily wouldn’t be aware of.”
79.Since 2014, the FCA and the Pensions Regulator have been running ScamSmart campaigns to alert people to the risks of scams. The campaigns have made effective use of limited resources to target groups vulnerable to scams. We recommend that Pensions Regulator and FCA should continue to run the ScamSmart campaign, while regularly evaluating whether it is reaching the right groups and whether it has the necessary resource to do so effectively.
80.When someone is looking for support to help them make a decision about their pension they can seek either advice or guidance. Advice is a personalised recommendation which can only be provided by firms regulated by the Financial Conduct Authority. Guidance is a broader term which includes general information and signposting about pensions. Guidance does not include a recommendation and can be offered by any organisation. People can receive guidance from public bodies, including the Pensions Advisory Service, Pension Wise and Money Advice Service—all of which are part of the Money and Pensions Service and will be consolidated into a new consumer facing brand—Moneyhelper—in June 2021.
81.This difference is not always understood by consumers and can be exploited by scammers. Neil Copeland, Director at Dalriada Trustees Limited, told us that many people do not know the difference between regulated and unregulated advice, saying:
We speak to members of the scam schemes we have been appointed to and when we first get in touch with them, they will often tell us that their financial adviser recommended transferring into this particular scheme. When we investigate, we find that it is an unregulated introducer and members have not had financial advice even though they think they have.
For this report, which is the first of three planned reports in our broad inquiry, we are focussing solely on the role of advice and guidance in preventing pension scams. Our next report will look in more detail at how savers use advice and guidance when they access their pensions and our final report at the role advice and guidance has in helping people save for retirement.
82.When the pension freedoms were introduced, a guidance guarantee was presented as a key pillar of the reforms, in order to support people making use of the new range of choices available to them. Everyone with a defined contribution pension is entitled to free impartial guidance from Pension Wise when they come to access their pension. The Pensions Regulator told us that it encourages trustees to “actively promote the free, impartial pensions guidance from Pension Wise, including phone appointments and online information. This will help provide savers with greater understanding of their retirement options and question any potential scam activity.”
83.Pension Wise is widely considered to provide a good service to those who use it. The 2019/20 Pension Wise evaluation report found that 95% of people who have an appointment with Pension Wise feel very or fairly confident in their ability to avoid pension scams, compared with 79% of non-users. Just Group, a specialist financial service group focusing on the retirement income market, told us:
Short of people receiving regulated financial advice–which many consumers are uninterested in or can’t afford–there is no evidence of a better approach to improving people’s ability to make informed decisions about how to use their DC pension savings than the free, impartial guidance offered by Pension Wise.
84.The Financial Guidance and Claims Act 2018 requires the FCA to ensure that consumers have received appropriate pensions guidance or have opted out of guidance before accessing or transferring their pension savings. In July 2020 the Money and Pensions Service published the results of behavioural trials to increase the use of Pension Wise. The trials increased the proportion of people receiving Pension Wise guidance from 3% to 11%—an additional 27% had already received guidance or advice from another provider in the previous 12 months. The Department for Work and Pensions told us that:
We want to present taking guidance as a natural part of the journey when individuals access their pension savings. That is why we intend to introduce regulations in the near future to introduce a stronger nudge to guidance. We are also working with the FCA on rules that would require managers of personal pension schemes to introduce parallel provisions.
85.Guidance is not always sufficient to prevent pension scams, Rachel Vahey, Senior Technical Consultant at A J Bell, told us:
For all of this, it depends when in the process you are pushing or you are nudging or you are compelling the client to go and seek advice. Often, especially when it comes to pension scams, the client may be in dire financial straits and desperately needs this money, which is why they are taking such desperate action. We have found that if you are telling them just at the point of transfer or just at the point where you are encashing the fund, “Go get financial help, go get advice or go get guidance”, they may be reluctant to do so because they are not interested in that. They are only interested in getting their money at that particular point.
Margaret Snowdon, Chair of the Pension Scams Industry Group, also told us that guidance is not enough: in the Pension Scams Industry Group’s experience only 25% of people who take guidance will listen to it and the other 75% will be determined to go ahead with a transfer.
86.Regulated advice comes at a cost to savers which can be a barrier for many. The Association of Member Nominated Trustees told us that the cost of providing independent advice could be a significant proportion of the value of someone’s pension. It suggested that the gap between Pension Wise guidance and full paid-for advice might be bridged by an advisory service and recommended that the practicalities of establishing one should be investigated. Similarly, in November 2020, the Association of British Insurers called for the advice boundary to be shifted, so that consumers could either get simpler and more affordable advice or guidance which offers more help, after it found that 72% of people were unwilling to pay for advice. Money Alive Limited submitted to us a proposal to use a tech-based approach to bridge the gap through interactive video engagement, which could report whether a person has watched and understood content about scams to trustees and pension scheme administrators.
87.Calls for a shift in the advice-guidance boundary are not new. Julian Adams, Director of Public Policy and Regulation at M&G PLC, told us that whether there is a “middle path” between guidance and advice “is a longstanding issue between the industry and the FCA.” Nita Tinn, Chair at Association of Professional Pension Trustees, said that “some limited form of either enhanced guidance or basic advice from someone like Pension Wise or Money Advice Service would be welcome” but added that thought would need to be given to how it should be funded.
88.There is an option for members of defined contribution and hybrid pension schemes to use some of their pension savings to pay for advice. The pension advice allowance was introduced in 2017 and allows £500 to be withdrawn from a pension up to three times in different tax years for advice. PIMFA told us that “there are two obvious issues with the policy as things stand”, namely:
Industry representatives told us that the pensions advice allowance is not being widely used. Julian Adams, Director of Public Policy and Regulation at M&G PLC told us that M&G PLC do not provide it because “it is also complex and expensive to administer.” Rachel Vahey, Senior Technical Consultant at A J Bell, echoed these comments, telling us that A J Bell had “not had the demand from advisers or their customers to bring it in”. Neil Copeland, Director at Dalriada Trustees Limited, said that “There is scope for the pension advice allowance to be effective” but that £500 “is not going to get you very much advice”.
89.The Minister for Pensions and Financial Inclusion wrote to us on 22 February 2021 telling us that HM Treasury intends to consider the effectiveness of the pension advice allowance as part of its wider work to tackle any remaining challenges in the financial advice market but does not intend to formally report back on it.
90.When someone is looking for support to help them make a decision about their pension they can seek either advice or guidance. These are both important tools to prevent scams, with earlier intervention likely to lead to better outcomes. Advice is a personalised recommendation which can only be provided by regulated individuals and firms. Guidance is a broader term which includes general information and signposting about pensions. This difference is not always understood by consumers and can be exploited by scammers.
91.When the pension freedoms were introduced, a guidance guarantee was presented as a key pillar of the reforms supporting people making use of the new range of choices available to them. Everyone with a defined contribution pension is entitled to free impartial guidance from Pension Wise when they come to access their pension. The Minister for Pensions and Financial Inclusion has agreed that having a Pension Wise appointment should be the norm. We recommend that DWP should set out a plan for how this will be achieved and a timetable for getting there. Pension Wise is an important tool to prevent scams and we will look further at its role, within the new MoneyHelper brand, in the next part of our inquiry on accessing pension savings.
92.We recommend that the Department for Work and Pensions should consider the options available for the Money and Pensions Service to offer enhanced guidance or limited advice, including through technological solutions. Regulated advice comes at a cost to savers, which can be a barrier for many, whereas the guidance currently provided may not be enough for some people to avoid them becoming a victim of a scam. We have asked for views on this in the call for evidence for the second part of our inquiry which will look at how people access pension savings.
93.The pension advice allowance allows members of defined contribution and hybrid pension schemes to withdraw £500 from their pension up to three times in different tax years for advice. There appears to have been little take up of the Pension Advice Allowance which has been set at too low a level. We welcome news that HM Treasury is reviewing this policy after the Minister for Pensions and Financial Inclusion told us that it will consider the policy’s effectiveness as part of its wider work on the financial advice market. We recommend that the overall cap of £1,500 should be reviewed and the annual cap of £500 on the amount which can be withdrawn in any one year under the pensions advice allowance should be removed.
80 Hughes v The Royal London Mutual Insurance Society Ltd  EWHC 319 (Ch)
81 Pensions Management Institute ()
82 The Police Foundation, , September 2020
84 Age UK ()
85 , 4 November 2020
86 HC Deb 16 November 2020, Vol 684, Col 111
89 Association of British Insurers ()
93 Aviva ()
94 Association of British Insurers ()
95 A J Bell ()
96 Quilter ()
97 Quilter ()
98 The Investing and Saving Alliance ()
100 Financial Conduct Authority, , September 2020
101 Financial Conduct Authority ()
102 Mark Taber ()
103 Mark Taber ()
104 Which? ()
110 Department for Digital, Culture, Media & Sport and Home Office, , 15 December 2020
115 Financial Services Compensation Scheme, , 20 November 2020
116 Financial Services Compensation Scheme evidence to Treasury Select Committee ()
119 The Pensions Policy Institute ()
121 Department for Work and Pensions ()
123 Personal Investment and Financial Advice Association ()
125 The Pensions Regulator ()
126 Just Group ()
127 Money and Pensions Service, , July 2020
128 Department for Work and Pensions ()
131 Association of Member Nominated Trustees ()
132 Association of British Insurers,
133 Money Alive Limited ()
135 Personal Investment and Financial Advice Association ()
139 Letter from Minister for Pensions and Financial Inclusion to Chair of the work and Pensions Committee about Pension Advice Allowance, 22 February 2021