Defined Ambition pensions – consultation response – Ros Altmann

    Ros is a leading authority on both private and state pensions,annuities and
    retirement policy. Numerous major awards have recognised her work to
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  • Ros Altmann

    Ros Altmann

    Defined Ambition pensions – consultation response

    Defined Ambition pensions – consultation response

    to DWP Consultation ‘Reshaping workplace pensions for future
    generations’ – Defined Ambition pensions.

    by Dr. Ros Altmann

    Pensions Policy Expert

    (All material on this page is subject to copyright and must not be reproduced without the author’s permission.)

    DWPs consultation on Defined Ambition (DA) pensions aims to try to
    find a way to encourage employers to take on more of the risks of
    pension provision. DA is a chance to start again and design employer
    pensions that are more flexible and allow more leeway for change over
    time, as required to accommodate changes in demographic and financial

    the policy of auto-enrolment is spreading pension coverage across
    millions more workers in the UK, but the overwhelming majority of new
    pension provision is in Defined Contribution (DC) schemes. These
    schemes place almost all the risks of pension provision on the
    individual worker. This is in stark contrast to the ‘traditional’
    British company final salary pension scheme, which used to offer
    Defined Benefit (DB) pensions. In DB schemes, the value of the
    future pension income is underwritten by employers, so the worker is
    only responsible for making the requested contributions, while the
    employer has to make up any shortfall in the funding of the promised
    future pension income in retirement.

    mistakes and well-meaning legislation have resulted in the
    traditional DB schemes becoming unaffordable for most private sector
    employers. The increasingly draconian regulations and requirements
    placed on employers, without the flexibility to adjust to changing
    market, economic and demographic realities, has resulted in employers
    rushing to remove pension risk from their balance sheets. In the
    past, the law gradually tightened employer promises into immutable
    guarantees and added extra costs on top of the original pension
    promises, including inflation linking, spouse/partner pensions and
    revaluation of leavers’ benefits. These have added huge extra
    costs (around 50%) to the pensions promise and rising life expectancy
    without the ability to change pension start dates for past accruals
    has added further costs and risks. Every year that life expectancy
    rises while pension ages stay fixed, employer costs will increase.
    Even if the same level of pension is paid, the value of that pensions
    rises all the time, but workers do not understand that ‘no change’
    actually means a change for the worse for the employer. There is so
    much misunderstanding of pensions and workers do not appreciate the
    additional costs that traditional DB schemes are imposing on
    employers as both demographics and market returns have been so
    different from previous forecasts. This has led employers desperate
    to get rid of the risks they face and to move to DC pensions, which
    leave the risks on employees instead. Firms merely promise to pay
    the specified contribution levels each month, but this merely builds
    up a pension fund for the worker, it does not provide a particular
    level of income.

    DB schemes, the employer must cover all the following risks:

    • Salary inflation
    • Price inflation
    • Interest rate risk
    • Longevity
    • Partners’
      pension risk
    • Revaluation
      of deferred benefits
    • Financial
      market risks
    • Annuity
    • Regulatory
      change risk

    DC schemes, however, the employee carries those risks and the
    employers’ liability is finite.

    consultation tries to find a third way, with DA trying to push some
    of the risks back onto employers. Indeed, it is arguable that DA, as
    described in this consultation document, is really what the original
    DB schemes were intended to be. They were set up by paternalistic
    employers who wanted to help their loyal lifelong workforce enjoy a
    few years of retirement after they finished working for the company.
    The pension age of 65, set many decades ago, would have meant around
    10 years of retirement on average, with many surviving far less long.
    Over the years, employers were encouraged to reduce normal pension
    ages (even as life expectancy increased) and then the Government
    continually tightened up the legal requirements so that pension
    promises from the past could never be reduced – only future
    accruals could be changed.

    thought that these schemes were in surplus and could rely on future
    stock market returns to meet their liabilities, employers were
    saddled with additional obligations that turned out to be
    unaffordable, when it became clear that market movements could not be
    relied upon (even in the long-run) and that the surpluses were not
    really surpluses at all. They were buffers against bad markets and
    future demographic change, that would have ensured extra funds were
    available if required. Nevertheless, the DB system relies on
    employers always being able to make up any shortfalls and being
    willing to underwrite open-ended liabilities for many decades into
    the future. The way UK DB schemes have been prevented from making
    changes to reflect new circumstances has led to unrealistic
    expectations on the part of workers who do not realise how expensive
    pensions have become. Workers have almost been given the impression
    that pensions grow on ‘magic money trees’ and that the future
    pension income can be guaranteed with a fixed past contribution, even
    if the income has to be paid for far more years than originally
    budgeted for. Pensions cannot keep lasting ever longer at the same
    level but many workers do not realise this.

    does not fit with 21st
    century capitalism. Corporate life has changed and employment
    patterns have changed, so that a DC model fits far better with new
    realities. Most companies will only exist in present form for 10-20
    years nowadays and most workers change jobs on average 11 times in
    their working life. Therefore, the concept of a pension being paid
    to loyal lifelong workers in 30, 40 or 50 years’ time does not make
    sense any longer. The employer cannot be relied on to be around in
    the longer term and the worker is unlikely to stay employed until
    they retire.

    moving to pure DC, workers are in a much worse position than before.
    This is a problem for the Government, however, as the state pension
    is being cut and, whereas past state pension reductions could be
    somewhat offset (at least in theory) by relying on increased private
    or employer pension income, as Government shifted more burdens onto
    final salary schemes, the new-style pensions do not offer such
    generous benefits and cannot be relied on to provide good extra
    pension income.

    schemes were a form of social welfare, underwritten by employers.
    This is not the natural role of an employer, it is usually a state
    role. The closure of most private sector DB schemes therefore poses
    a problem for pensions policy. The state pension cuts leave many
    people at risk of inadequate later life income and, if more and more
    pensioners are poor, the long-term economic outlook is damaged as
    they will not have money to spend and may increasingly require
    taxpayer support. Thus, the DA agenda is to try to persuade
    employers to take back responsibility for more of the pension risk
    that pure DC, albeit recognising that DB – as currently configured
    in the UK – is too draconian for employers to voluntarily accept.

    consultation suggests that the aim of DA is to find ways to offer
    more guarantees than are available in DC. There are two models –
    ‘DB minus’ (where the employer offers some extra guarantee or
    even discretionary increases) or ‘DC plus’ where either an
    employer or a pension fund offers a guarantee or discretionary
    additional benefit on some aspect of future pension.

    would question the wisdom of trying to offer too much in the way of
    guarantees on future pensions. As workers draw nearer to retirement,
    a guarantee could be provided but if the guarantee is meaningful it
    may be expensive and if the guarantee is low cost it may not be
    meaningful. A government underpin would be more attractive than a
    guarantee from a private firm or employer.

    proposes various models of ‘risk-sharing’ between employer and
    employee. This is worth a try, although it is not going to be easy
    to persuade employers to take back significant amounts of risk. That
    is why it is sensible to propose ‘safety valves’ which will allow
    for discretionary increases in benefits year by year, if funding
    allows, and changes along the way as other factors change. This
    should always have been part of the DB landscape. Indeed, I would
    argue that DA should not aim for hard guarantees at all. It should
    help workers understand that pensions simply cannot be guaranteed by
    private sector firms many decades hence. The concept of guarantees
    should be replaced by a ‘best efforts’ promise, which cannot be
    relied on absolutely and which needs to be monitored and checked over

    model which proposes mandatory transfers of members out of DA schemes
    into DC schemes on leaving seems to me to be the wrong way round.
    Valuing DA benefits correctly will be a nightmare and I
    consider there will be significant difficulties with such a scheme
    design. I would suggest that this would work much better the other
    way round. After a certain number of years in a pension scheme, the
    benefits could be converted from DC to DA (or DB), so that employers
    will be rewarding loyal service, and adding guarantees (albeit less
    draconian than currently) to their long-serving workers’ pensions.
    Past accruals could be converted into an equivalent number of years
    worth of DA pension accrual. For example, after ten years’ service
    a worker could be offered a chance to convert their DC pension fund
    into a participation in a DA or DB scheme with ten years’ service
    at the salary they earned each year.

    with trying to move to DA

    1. Will
      employers be willing to once again shoulder pensions risks that they
      can pass onto workers in DC? If shareholders do not wish to be
      saddled with future risks, DA will not be adopted by many firms.

    2. Many
      employers may be fearful that the ‘ambition’ will not stay as
      just an ambition, and will be sceptical that DA will be converted
      into a legal guarantee in future, as happened with traditional final
      salary schemes.

    3. Guarantees
      may not be deliverable on a reliable basis – schemes must have
      flexibility to work more on the basis of adjusting to developments
      in people’s lives and financial markets

    4. There
      is bound to be a trade off between guarantees and potential returns.
      This needs to be understood. A ‘money back’ guarantee on
      contributions is not a very ambitious ‘Ambition’ and future
      pensions are bound to be uncertain.

    5. Even
      the state pension has turned out to be unaffordable for the state
      itself, and it has been cut several times, with further cuts coming.
      If taxpayers cannot afford unreformed pensions, then corporate UK
      cannot possibly be relied on to deliver future pensions and workers
      need to know this.

    6. Imposing
      conditional or discretionary benefits on employers or schemes could
      still prove too costly, especially in the face of EU EIPOA
      regulations that may come in and extra solvency or reserving
      requirements for pension funds.

    7. Ultimately,
      pensions risk cannot be eradicated. Passing risk from one party to
      another does not make it disappear and, if markets do not deliver,
      or if contributions are too low, pension provision will remain

    Responses to Consultation Questions

    1. Do
    you agree that a greater focus on providing members with more
    certainty about savings or preferably income in retirement may
    increase confidence in saving in a pension?

    agree that providing more certainty can help increase confidence in
    theory, but in practice not only will people find it difficult to
    trust pensions given past experience, but it may also prove
    impossible to actually offer meaningful guarantees anyway.
    Guaranteeing a future income many decades into the future is too
    risky for private companies to be relied on to deliver. It would be
    better to be honest with people and let them know that saving in a
    pension fund carries risks so that future pension income cannot be
    guaranteed (at least not till close to retirement). However, not
    saving is guaranteed to mean lower living standards than if one has

    2. As
    an employer, do you have experience of, or can you envisage any
    issues with, employees being unable to retire due to DC pension
    income levels or certainty about income levels?

    may have some concerns that workers cannot retire if they have
    inadequate incomes, but I don’t believe slight improvements to
    pension income outcomes are likely to be sufficient to address
    retirement affordability in a meaningful manner. Employers can best
    help older workers prepare for retirement by facilitating part-time
    work in later life, which can help them accrue higher incomes and
    continue some saving, in preparation for stopping work altogether at
    a later age, while cutting working hours for a period of time
    beforehand. Offering financial planning help to workers is likely to
    prove a more cost-effective method of dealing with retirement issues
    than trying to underwrite pension guarantees.

    3. What
    are your views on the feasibility of this scheme design?

    DB schemes are feasible and an improvement on inflexible DB, but
    there will still be concerns that employers may not be able to afford
    the core benefits themselves. Certainly, permitting discretionary
    year by year increases, as funding and economic conditions allow,
    would be necessary to attract employers to take on pension risks
    again. They would probably still be concerned that the flexibility
    in DA schemes could be taken away by future legislation.

    Are employers likely to be interested in providing benefits in
    addition to a simplified flat-rate
    DB pension on a discretionary basis or otherwise?

    sector employers may choose to provide additional benefits, such as
    life insurance which has disappeared from DC schemes, however
    additional pension benefits are likely to be less attractive.

    What role do you see for scheme trustees in relation to discretionary
    payments? For example:

    • Should
      they be involved in deciding whether a discretionary payment is made
      at all?

    Trustees should be involved in assessing
    the affordability of discretionary payments.

    • Should
      they be involved in setting out how these payments are apportioned
      to members or should this be down to the employer?

    Trustees should be involved in
    apportionment decisions.

    Do you agree that our starting point should be to keep regulatory
    requirements around discretionary
    benefits to a minimum?


    How do you see funding for the non-discretionary DB element being
    sufficiently protected while
    allowing for extra discretionary benefits? For example, is there a
    risk that paying discretionary
    benefits could threaten the funding for non-discretionary DB benefits
    for younger
    scheme members?

    all depends on investment returns to a large degree and there is
    always the risk that younger members’ benefits could be threatened
    by the amounts paid out to older members before the young ones reach

    defined benefit – automatic conversion to DC

    9. What
    are your views on the feasibility of this scheme design?

    consider there will be significant difficulties with such a scheme
    design. The formula for calculating transfer of benefits is unlikely
    to be easily agreed upon and is fraught with risks. I would suggest
    that this type of scheme design would work much better the other way
    round. After a certain number of years in a pension scheme, the
    benefits could be converted from DC to DA (or DB), so that employers
    will be rewarding loyal service, and adding guarantees (albeit less
    draconian than currently) to their long-serving workers’ pensions.
    For example, after ten years’ service a worker could be offered a
    chance to convert their DC pension fund into a participation in a DA
    or DB scheme.

    If employers are able to use scheme designs 1 and 3, do you think it
    is still helpful for legislation
    to allow for this scheme design?

    am not in favour of this scheme design, since mandatory transfers
    will be difficult to value. If the design works the other way round,
    so that employee benefits are converted from DC after a set number of
    years, then those benefits would remain with the employer but would
    not be tiny amounts from just short periods of accrual.

    Do you think this scheme design could be extended to permit employers
    to automatically transfer
    members out of the scheme at retirement?

    think it would be far better to leave it to workers to decide if they
    want to transfer out and if their accrual only becomes DA or DB after
    a certain period of time, they are less likely to want or need to
    transfer. Transferring between industry-wide employers could be
    another model to consider.

    What would be the most suitable way for benefits to accrue under this
    model? And how might
    this best be communicated to ensure members understand the value of
    their pension

    that could be automatically converted to DC would be difficult to
    explain and I do not believe it is sensible to try to do so.

    Assuming a CETV would not represent ‘fair value’ for the accrued
    rights when the member leaves or retires, how might it best be
    calculated? Should the basis for calculation be different when the
    transfer is initiated by the employer (for example on redundancy)?

    question illustrates why I believe the proposed model is flawed. The
    value of the CETV would be open to manipulation and the complexity of
    different calculations depending on whether the employer or worker
    initiated the scheme exit would be costly, complex and unreliable.

    For schemes providing a lump sum benefit, what are your views on how
    the cash value should
    be calculated for members who leave before retirement? Should the net
    present value
    of the lump sum be calculated on how many years away from pension age
    they are?

    am not in favour of this model

    Could the accrual rate and pension value be along similar lines to
    existing cash balance arrangements?

    should be allowed to stay in current cash balance arrangements after
    they leave employment, not forced out.

    What forms of regulatory requirements would be needed to:

    avoidance activity?

    the scheme has access to sufficient funds to enable a transfer when a

    transfers could result in unfairness to members not transferring out,
    depending on assumptions used for the valuations. Scheme cash flow
    would need to be carefully managed but it is not clear that will be
    an easy task.

    scheme pension age:

    What are your views on the feasibility of this scheme design?

    scheme pension age is sensible but again will be difficult to manage
    fairly. Certainly, the ability to say to younger workers that they
    cannot be sure of their scheme pension start date until nearer the
    time they may start to take benefits is vital. As life expectancy
    continues to rise, it will be necessary for employers to have the
    leeway to increase pension age in future. If future pensions have to
    start at different ages, depending on the original contribution date,
    the administrative complexity will be too challenging.

    It could lead to more schemes having proportions of accrued pension
    payable at different pension
    ages. Would this further complexity outweigh the benefits?

    Future pensions should start from a date to be determined in future,
    rather than pre-set many decades in advance.

    What role do you see the scheme trustees playing? Should they be
    involved in setting a new
    NPA, or should this be down to the employer and the employer’s

    need to be involved in order to protect members’ interests, but
    there should be negotiation between all the parties, with employer
    and actuary having to justify the increase.

    What are your thoughts on how future pension ages are set?

    GAD to publish a standard index based on longevity assumptions?

    do you prefer schemes linking their NPA with the State Pension age,
    so that when the latter
    changes, the scheme’s pension age automatically changes in line
    with this?

    is not up to Government to determine scheme design. Future pension
    age could be determined by industry, as some industries have lower
    life expectancy than others, or it could be tied to state pension age
    or another measure of longevity. This would all need to be justified
    in negotiation and would be complex in practice.

    How might the decision to change the NPA work in multi-employer

    believe in trying to standardise benefits across employers –
    assuming multi-employer schemes are all in the same industry. If
    different employers have different life expectancy for their members,
    then it could prove difficult to adjust pension age a different
    scheme design may be needed.

    As an alternative to opening a new scheme, do you agree it should be
    possible for an employer
    to modify the rules of an existing scheme so that it can be
    re-designed as a Flexible
    DB scheme in relation to new accruals, for example, it is possible to
    change the NPA and/or introduce automatic conversion to DC when a
    member leaves?


    Do you agree that employers should not have the power to transfer or
    modify accruals built up
    under previous arrangements into a new arrangement, beyond what is
    allowed under current


    Should there be a requirement to provide independent financial advice
    in all cases where an
    employer offers to transfer a member’s accrued rights from a
    traditional DB scheme to a new


    Do you think having more certainty than traditional DC would be
    welcomed by members, and
    help generate consumer confidence and persistency in saving?

    answer to Question 1. Members would probably welcome more certainty
    but need much more education about the value and cost of pensions.

    As an employer, if these products mean there is no funding
    liability, only the requirement to
    contribute as for a traditional DC scheme, would you be interested in
    offering these products
    to employees?

    there is no funding liability, it is hard to see what kind of
    meaningful guarantee could actually be on offer. The costs of
    guarantees will vary, but a guarantee that is worthwhile in terms of
    delivering future certainty is likely to be very expensive and a
    guarantee that costs very little is likely to be worth very little.

    In relation to medium- and long-term guarantees outlined in model 2
    (capital and investment
    return guarantee), and model 3 (retirement income insurance), would
    removal of
    the legislative barriers be sufficient to stimulate the development
    of market-based solutions?

    is already possible to obtain capital and investment return
    guarantees, as well as current and deferred income guarantees. For
    example, MetLife offers such guarantees but they come at a cost.
    They are available on existing DC scheme arrangements or savings
    plans and do not require new DA legislation. The problem is that
    there are not enough providers of sufficient size and strength to
    underwrite mass-market guarantees. This is a niche area, only
    available to wealthier savers. Introducing a ‘fiduciary’ to
    negotiate cheaper guarantees seems a really nebulous concept and it
    is not clear that this is a practical option.

    regards retirement income insurance (option 3) this looks like buying
    deferred annuities, which are even more expensive than ordinary
    annuities, with an equity fund to provide a bonus on top of the
    deferred guaranteed income. This is likely to be a very expensive
    way to provide future pensions. Deferred annuities are exceptionally
    poor value due to the risk and profit margins built in. They may
    offer a guaranteed income, but it will be very low. It is far better
    to try to buy a guarantee much closer to retirement and leave members
    to keep on accruing additional savings during their working life.

    As insufficient scale has been identified as a barrier to providing
    affordable guarantees, is there a role for the Government in
    facilitating different types of pension vehicles that would create
    greater scale for this purpose?

    do not believe the Government itself should design new pension
    vehicles, that should be up to the pensions industry. However, I
    think there could be a role for Government in providing longevity
    gilts, which could help offset some of the longevity risks of
    pensions and the Government itself could consider underwriting
    annuities, which would allow much better rates. The profit and risk
    margins on current annuities are clearly very high and there is room
    to pass significant cost savings onto consumers if the provision of
    annuities were taken over by the Government. By threatening to
    compete in the annuity market, the Government would probably then
    force annuity companies to improve the value they offer.

    Do existing protection arrangements for DC products provide
    sufficient protection for members
    in the event of provider insolvency?

    is not clear that savers with more than the statutory minimum
    compensation limits in personal or group pensions with financial
    services firms are sufficiently covered by insurance protection in
    event of provider insolvency. It is not clear whether the PPF itself
    would be involved in this DA area and how it would value the promised

    Are these models likely to be an attractive option for employers and

    options could be made to sound attractive, however the long-term
    risks of these provisions and the probability of disappointment for
    current or future retirees makes them less attractive in the medium

    On model 4 – pensions income builder – what are your views on
    this model in which members
    are in effect deploying their own capital to guarantee their own

    is likely to prove difficult to explain this concept to members in a
    manner that they can understand and the likelihood of
    misrepresentation or misunderstanding is high. This model will not
    provide guaranteed pensions and, although employer contributions will
    be capped, this means workers’ pensions may not pay as much as they
    expect and they may have a false sense of security.

    Do you agree that CDC schemes have the potential to provide more
    stable outcomes on average
    than traditional DC schemes?

    agree that CDC schemes have the ‘potential’ to provide more
    stable outcomes on average. That does not, however, mean they will
    definitely do so. CDC does mitigate risks, especially in the nearer
    term, rather than being fully exposed immediately to mark-to-market

    Given there is no tradition of risk sharing between pension scheme
    members in the UK, are
    individuals going to be willing to share the benefits of protection
    from downturns in
    the market and increased certainty of outcome, with the potential
    disadvantages of intergenerational
    risk transfer?

    question of whether members will be willing to share the protection
    benefits pre-supposes that they will understand how the scheme works.
    There is a notable lack of inter-generational solidarity in Britain
    today, with younger generations seeming to believe that older people
    have had too much of the share of national wealth in terms of
    pensions and housing. The CDC design certainly means younger
    generations could lose out relative to older members of the pension
    scheme, because future returns may not materialise as predicted and,
    therefore, funding may fall. This goes back to the point that we
    need to reduce the idea of ‘guarantees’ in pensions and help
    people understand that pensions cannot be relied on to be exactly as
    predicted many decades ago, due to changes in demographics and
    markets. If members are not led to believe that their pension income
    can only rise and if they are clearly told that there may be times
    when their pension income could have to reduce, then they may accept
    the principles, but it is important that they understand. People
    accepted with profits concepts at the time, but that was partly
    because they did not realise how much returns could fall during bad
    times. CDC has the potential to mislead in the same way as
    with-profits did, or indeed Equitable Life. It is important that a
    distinction is made between past mistakes and future best practice.
    CDC is likely to deliver more reliable outcomes for most people than
    pure DC, but this is not guaranteed. Pure DC is probably the most
    risky form of pension saving for individual workers.

    Is a CDC scheme designed to manage funding deficits by cutting
    benefits in payment going to be acceptable in the UK where
    traditionally maintaining the value of benefits in payment has been
    an overriding priority?

    need to get away from the idea that pension benefits can never be cut
    under any circumstances – this is financially unsustainable. Even
    taxpayers have been unable to commit to maintaining state pensions,
    so private companies are even less able to do so.

    What levels of funding do you consider would be appropriate to
    ensure that a CDC scheme has sufficient capital to meet the
    liabilities and minimise the risk of benefits in payment being cut?

    is impossible to answer this, there will always be times when
    assumptions about appropriate funding levels prove incorrect. A
    ‘best efforts’ basis is more reasonable.

    Given the need for scale and an ongoing in-flow of new members to
    ensure the sustainability
    of a CDC scheme, will it be possible to set up a scheme without some
    form of Government

    schemes could provide scale, but it will always be the case that new
    members carry more risk than older members. This is the nature of
    CDC. That does not mean younger members will necessarily get lower
    pensions, but they are more at risk of this.

    As a mutual model, it has been suggested that CDC schemes might
    prove attractive to the trades unions and other social partners –
    might this be an option worth exploring?

    ways in which we can increase the scale of pension saving schemes is
    worth exploring. Economies of scale are very important.

    Do you have any comments on how to characterise the defining
    characteristics of DA pensions?

    pensions should emphasise the word ‘ambition’ so that members
    know this is an aim, not a cast-iron guarantee. Members should be
    told that the benefits will be influenced by factors such as
    investment returns and changes in life expectancy and that the final
    pension received cannot be predicted until later life.

    Do you think that setting up a CDC scheme should be subject to formal
    approval, for example
    licensing by a regulator?


    Do you think that CDC schemes which do not provide a guarantee or
    promise should also be licensed?


    Do you agree that such CDC schemes should also be subject to DA
    requirements on governance
    and member communications?


    Should there also be an option for schemes that currently offer DC to
    convert to CDC?

    should surely be an option, but requirements for clear explanation
    and member choice are needed alongside this.

    In the absence of both a guaranteed pension entitlement and an
    individually defined pool
    of assets, how should assets in a CDC scheme be apportioned such that
    pension accruals
    can be measured for tax purposes against the Annual Allowance and the
    Lifetime Allowance?

    lifetime accruals does not make sense to me and the annual allowance
    should be based on the amount of money per member actually being paid
    into the scheme.

    What specific areas should we address in relation to governance and
    member communications
    for DA schemes?

    needs to ensure best efforts to deliver the pension ‘ambition’
    but communications need to make it clear that these are aspirations,
    rather than guarantees that can be relied on indefinitely.

    Dr. Ros Altmann
    December 2013

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