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Dashboards forum​
1 May 2024
2
1 Welcome and introductions Julie Anderson-Hill,PDP
2 PDP programme update Chris Curry, Principal, PDP
3 FCA consultationon dashboards Caroline Donelan, FCA
4
Pension dashboard operators’ coalition
update
Richard Smith, PDOC
5 Any other business (AOB) Julie Anderson-Hill,PDP
Agenda for today
Programme update
FCA consultation
on dashboards
5
FCA regulation of
firms operating a
pensions dashboard service
5
Consultation paper CP24/4
The regulatory framework for pensions
dashboard service firms: further consultation
April 2024
6
Regulatory framework for pension dashboard service
firms
6
CP 22/25: proposed framework for operators of pensions
dashboard services.
December 2022
February 2024
Amendment of Regulated Activities Order bringing ‘operating a
pensions dashboard service’ within FCA regulation.
CP24/4 further consultation
Building on CP22/25
Proposed perimeter
guidance:
• scope of new regulated
activity
• when firms will require
FCA permission
Two substantive changes to
proposals in CP22/25:
• new proposal: firms
must present choices to
the consumer
• revised data export
proposals
27 March 2024
7
Proposed perimeter guidance
7
8
The regulated activity
8
The regulated activity
Operating a pensions dashboard service which connects to the Money and
Pensions Service dashboards digital architecture is a specified kind of
activity.
This means:
Firms wanting to operate a pensions dashboard service must:
• be or become FCA authorised
• obtain the regulatory permission to undertake the new regulated activity
• meet our requirements for firms undertaking this activity
Industry told us:
Firms are interested in employing services from other parties to develop or
operate part of the pensions dashboard service. For example outsourcing to:
• a technical services provider to connect to MaPS’ digital architecture
• a software provider to build digital elements of a dashboard service
Proposed perimeter guidance: to support firms understand
• Scope of new regulated activity
• Which party needs authorisation and permission to operate a
pensions dashboard service
9
Proposed perimeter guidance
9
A party will be carrying out the regulated activity of operating a PDS if they
have control over the dashboard service
A party will have control and requires FCA permission if one or both:
Authority Accepts responsibility
• To direct/ decide how dashboard is run or
managed
• To direct/ instruct other parties to provide
services on their behalf
➢ sufficient oversight to manage risks
(compliance with SYSC)
• For compliance of PDS and connection: FCA
rules, Regulations 2022, PDP Standards
• Registered with MaPS
• For users of the dashboard service, eg
complaints, user experience
Unlikely firm has control if it is clear:
x No authority over dashboard and cannot alter, edit or adapt the service, other
than under instruction
x No responsibility for compliance with any legal/ regulatory requirements
x No capability to carry out activities or services to support the dashboard
service, unless instructed by dashboard firm
10
Examples: unlikely to be operating a
pensions dashboard service
Display public link
➢ Display on website a
publicly available link or
URL to another party’s
dashboard
➢ For example, a link to the
MoneyHelper dashboard
➢ It’s clear this is another
party’s dashboard service.
Consultancy service
➢ Provide advice, guidance or
consultancy services to a firm
to support development of
their dashboard service.
➢ For example, guidance to
develop business case or
undertaking consumer
research.
11
Proposed changes to
regulatory framework
11
12
FCA Official
12
1) Proposed choices architecture
requirements
13
FCA Official
13
Greater clarity on:
• when the user’s dashboard journey ends
• when a dashboard operator can engage with a consumer outside the
dashboard without breaching dashboard rules
Consultation feedback
Choices architecture proposal
Dashboard operators must present core set of choices to users:
• After viewing dashboard data: view data, post-view services, self-export
• Exit communications: user aware leaving dashboard and take appropriate care
Proposed choices architecture and context
Aim - clarity to firms on end of regulated dashboard journey and enable
consumers to:
• understand the difference between environments they are navigating
• be clear when a choice takes them outside the FCA-regulated PDS
• exercise appropriate care when viewing material outside a PDS
14
Proposed core choices
14
Choice The menu option will direct the user
to….
Redirect outsi
de
dashboard?
No further action Redirect to firm's existing digital estate Yes
Raise a question or complaint about the
service or view data
Redirect to MaPS central complaints process Yes
Further information, support and impartial
guidance
Redirect to MoneyHelper
50+ user could redirect to Pension Wise
Yes
Find an FCA regulated adviser Redirect to MoneyHelper: choosing a financial adviser Yes
Grant permission for adviser to access view
data
Redirect to PDP Consent and Authorisation service Yes
Review, revoke or amend consents Redirect to PDP Consent and Authorisation service Yes
Can be offered if available
Explore/ use post-view services Continue to post-view services No
Copy of view data Continue to export-to-self process No
Flexibility for firms to decide language, format and design for presenting
choices as long as:
o readily accessible from pensions view data onwards
o fair, clear and not misleading, and
o impartial and give equal prominence to each choice
15
Proposed exit communications
15
Where the consumer's choice takes them outside the dashboard,
the firm must clearly communicate to the user:
• they are leaving the FCA regulated dashboard service
• where they are being redirected to
• what they see next is independent of the dashboard service
and not subject to the same legislative / regulatory
requirements, and
• they shouldn’t make financial decisions on view data only
Flexibility for firms to decide language, format and design
for exit communications as long as fair, clear and not
misleading
16
Our proposed choices architecture aims
to strengthen consumer protection
16
✓ Consistent, clear and impartial
presentation of core options on all
dashboards
✓ Consumerin controlof next steps and
navigating on informed basis
✓ Clarity to firms and consumers on end of
dashboard journey
✓ Consumers understand whenleaving
regulated dashboard service and can
exercise care
➢ Consumers being led into actions without
understanding the options available
➢ ‘Halo effect’extending beyond dashboard
➢ Consumers mistakenly assuming
what they see on a firm’s own
website is appropriate or tailored to
pensions view data
➢ Incorrector inconsistent application of rules
by PDS firms
Aims to achieve Aims to avoid
17
FCA Official
17
2) Revisions to data export
proposals
18
FCA Official
Data export proposals in CP22/25
18
User can export view data to only:
❑ PDS firm - to receive advice as a
post-view service
❑ Advice entities in the same
group as PDS firm
NB: only where PDS firm or firm in group
has investment advice permission
User grants consent to delegate
to access view data:
❑ Any investment adviser that
has been given delegated access
Additional: FCA consultation
proposal
Existing: DWP regulations
enabled delegated access
(when built into the architecture by PDP)
19
FCA Official
Proposed revision to data export
19
CP22/25 respondent feedback
➢ unfair competitive advantage to dashboard operator firms/ group over other
FCA regulated advisers
Potential risks
➢ Competitive advantage to few dashboard firms with advice permission and
vertically integrated firms
➢ Discourages active consumer choice in advice market: data export perceived
as simple and convenient option
Proposed revision:
➢ remove additional option for
data export to PDS firm/
group for investment advice
Proposed revised data export
options:
1. Not to offer data export.
2. Offer self-export of data
3. Offer export to self and export to the
PDS firm for post-view services - no
longer include investment advice by
the PDS firm/ group
20
FCA Official
Proposed revised approach…
20
User can export view data to:
❑ PDS firm - to receive advice as a
post-view service
❑ Advice entities in the same
group as PDS firm
User grants consent to access view
data to any investment adviser
given delegated access:
▪ Advisers at dashboard firms
▪ Advisers at non-dashboard
firms
FCA CP22/25 consultation proposal
Delegated access
(when built into the architecture by PDP)
Intendedoutcome:
• One consistent secure mechanism for all investment advisers to access view
data (with consumer consent).
----------------------------------------------------------------------------------------------
✓ promotes consumer choice beyond advisers in the dashboard firm or group
✓ all FCA regulatedinvestmentadvisersaccess view data on the same terms - no
competitive advantage to PDS firms or vertically integrated firms
21
FCA Official
Looking forward
21
Dashboards are likely to drive greater interest in pensions information, guidance and
advice.
Advice Guidance Boundary Review (AGBR)
A joint review by HM Treasury and the FCA to examine the regulatoryboundary between financial advice
and other forms of support:
• outlined proposalsto help close the advice gap
Review of AGBR outcomes and pensions dashboards
Afterthe AGBR concludes, we will consider:
• whetherany AGBR outcomescan be offered as a post-viewservice
• whetherto permit data export to firms deliveringanyof the AGBR outcomes
22
Next steps
22
Steps Date
Publish further consultation CP24/4 27 March 2024
Consultation CP24/4 closes 8 May 2024
Publish Policy Statement and make complete set
of final rules and guidance:
➢ We will consider feedback to both CP22/25 and
CP24/4 before finalising rules and guidance
Q4 2024
(subject to external
dependencies)
23
Pension dashboard
operators’ coalition update
Richard to run slides
Delivered by
(Pensions) Dashboards
Operators Coalition (DOC)
Independent Pensions Dashboards Consultant
Richard Smith
Dashboard
Operators
Coalition
the pensions dashboard?
Dashboards are a whole new technology ecosystem, a bit like an hourglass
Compulsion Law (Layer 7)
Connection (ISPs) (Layer 5)
Consumers (Layer 1)
• Data providers (Layer 6)
i.e. (virtually) all UK pension schemes and providers
• Dashboards (Layer 2)
powered by
• Digital architecture (Layer 4)
Compliance (QPDSs) (Layer 3)
All detailed research
findings published on
DashboardIdeas.co.uk
What happens in Norway?
• (Virtually) All Norwegian pension schemes
& providers are API connected to
• Front-end pensions dashboards, namely:
1. NorskPensjon.no direct, or
2. the NAV website (GOV.UK DWP equivalent), or
3. commercial financial apps (e.g. banking apps)
• A central pensions data retrieval service,
which, in turn, is API connected to
2023 usage statistics in Norway?
Total population: 5.5 million
Core working age
population (16-65): 3.5 million
• In 2023, how many times did Norwegian citizens
request to retrieve and view all their pensions
data, from the three different types of dashboard?
• But first, for context: how big is the Norwegian
population?
0.7 million
requests
0.9 million
requests
32 million
requests
How are industry bodiessupporting the PensionsDashboards Programme (PDP)?
• In Layer 2, the (P)DOC will similarly work
collaboratively to help get dashboards done
• In Layers 5 & 6, PASA is doing great
collaborative work with industry and PDP
DOC Policy Paper
8 Step Pathway to a Flourishing Dashboards Universe
Example of Detailed Steps
What’s next?
1. DOC to work collaboratively with DWP, FCA and PDP to ratify the 8 Step Pathway
2. Possibility of the DOC becoming part of an existing industry body?
3. Is your firm going to offer a QPDS? If so, are you interested in joining the Coalition?
Contact: info@pdoc.org.uk
Q&A
Money and PensionsService,
120 Holborn, London EC1N 2TD
Email : supportpdp@maps.org.uk
Web : pensionsdashboardsprogramme.org.uk
Stay in touch
@pensions-dashboards-programme
@PensionsDboards
Sign up to our newsletter via our website

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Pension dashboards forum 1 May 2024 (1).pdf

  • 2. 2 1 Welcome and introductions Julie Anderson-Hill,PDP 2 PDP programme update Chris Curry, Principal, PDP 3 FCA consultationon dashboards Caroline Donelan, FCA 4 Pension dashboard operators’ coalition update Richard Smith, PDOC 5 Any other business (AOB) Julie Anderson-Hill,PDP Agenda for today
  • 5. 5 FCA regulation of firms operating a pensions dashboard service 5 Consultation paper CP24/4 The regulatory framework for pensions dashboard service firms: further consultation April 2024
  • 6. 6 Regulatory framework for pension dashboard service firms 6 CP 22/25: proposed framework for operators of pensions dashboard services. December 2022 February 2024 Amendment of Regulated Activities Order bringing ‘operating a pensions dashboard service’ within FCA regulation. CP24/4 further consultation Building on CP22/25 Proposed perimeter guidance: • scope of new regulated activity • when firms will require FCA permission Two substantive changes to proposals in CP22/25: • new proposal: firms must present choices to the consumer • revised data export proposals 27 March 2024
  • 8. 8 The regulated activity 8 The regulated activity Operating a pensions dashboard service which connects to the Money and Pensions Service dashboards digital architecture is a specified kind of activity. This means: Firms wanting to operate a pensions dashboard service must: • be or become FCA authorised • obtain the regulatory permission to undertake the new regulated activity • meet our requirements for firms undertaking this activity Industry told us: Firms are interested in employing services from other parties to develop or operate part of the pensions dashboard service. For example outsourcing to: • a technical services provider to connect to MaPS’ digital architecture • a software provider to build digital elements of a dashboard service Proposed perimeter guidance: to support firms understand • Scope of new regulated activity • Which party needs authorisation and permission to operate a pensions dashboard service
  • 9. 9 Proposed perimeter guidance 9 A party will be carrying out the regulated activity of operating a PDS if they have control over the dashboard service A party will have control and requires FCA permission if one or both: Authority Accepts responsibility • To direct/ decide how dashboard is run or managed • To direct/ instruct other parties to provide services on their behalf ➢ sufficient oversight to manage risks (compliance with SYSC) • For compliance of PDS and connection: FCA rules, Regulations 2022, PDP Standards • Registered with MaPS • For users of the dashboard service, eg complaints, user experience Unlikely firm has control if it is clear: x No authority over dashboard and cannot alter, edit or adapt the service, other than under instruction x No responsibility for compliance with any legal/ regulatory requirements x No capability to carry out activities or services to support the dashboard service, unless instructed by dashboard firm
  • 10. 10 Examples: unlikely to be operating a pensions dashboard service Display public link ➢ Display on website a publicly available link or URL to another party’s dashboard ➢ For example, a link to the MoneyHelper dashboard ➢ It’s clear this is another party’s dashboard service. Consultancy service ➢ Provide advice, guidance or consultancy services to a firm to support development of their dashboard service. ➢ For example, guidance to develop business case or undertaking consumer research.
  • 12. 12 FCA Official 12 1) Proposed choices architecture requirements
  • 13. 13 FCA Official 13 Greater clarity on: • when the user’s dashboard journey ends • when a dashboard operator can engage with a consumer outside the dashboard without breaching dashboard rules Consultation feedback Choices architecture proposal Dashboard operators must present core set of choices to users: • After viewing dashboard data: view data, post-view services, self-export • Exit communications: user aware leaving dashboard and take appropriate care Proposed choices architecture and context Aim - clarity to firms on end of regulated dashboard journey and enable consumers to: • understand the difference between environments they are navigating • be clear when a choice takes them outside the FCA-regulated PDS • exercise appropriate care when viewing material outside a PDS
  • 14. 14 Proposed core choices 14 Choice The menu option will direct the user to…. Redirect outsi de dashboard? No further action Redirect to firm's existing digital estate Yes Raise a question or complaint about the service or view data Redirect to MaPS central complaints process Yes Further information, support and impartial guidance Redirect to MoneyHelper 50+ user could redirect to Pension Wise Yes Find an FCA regulated adviser Redirect to MoneyHelper: choosing a financial adviser Yes Grant permission for adviser to access view data Redirect to PDP Consent and Authorisation service Yes Review, revoke or amend consents Redirect to PDP Consent and Authorisation service Yes Can be offered if available Explore/ use post-view services Continue to post-view services No Copy of view data Continue to export-to-self process No Flexibility for firms to decide language, format and design for presenting choices as long as: o readily accessible from pensions view data onwards o fair, clear and not misleading, and o impartial and give equal prominence to each choice
  • 15. 15 Proposed exit communications 15 Where the consumer's choice takes them outside the dashboard, the firm must clearly communicate to the user: • they are leaving the FCA regulated dashboard service • where they are being redirected to • what they see next is independent of the dashboard service and not subject to the same legislative / regulatory requirements, and • they shouldn’t make financial decisions on view data only Flexibility for firms to decide language, format and design for exit communications as long as fair, clear and not misleading
  • 16. 16 Our proposed choices architecture aims to strengthen consumer protection 16 ✓ Consistent, clear and impartial presentation of core options on all dashboards ✓ Consumerin controlof next steps and navigating on informed basis ✓ Clarity to firms and consumers on end of dashboard journey ✓ Consumers understand whenleaving regulated dashboard service and can exercise care ➢ Consumers being led into actions without understanding the options available ➢ ‘Halo effect’extending beyond dashboard ➢ Consumers mistakenly assuming what they see on a firm’s own website is appropriate or tailored to pensions view data ➢ Incorrector inconsistent application of rules by PDS firms Aims to achieve Aims to avoid
  • 17. 17 FCA Official 17 2) Revisions to data export proposals
  • 18. 18 FCA Official Data export proposals in CP22/25 18 User can export view data to only: ❑ PDS firm - to receive advice as a post-view service ❑ Advice entities in the same group as PDS firm NB: only where PDS firm or firm in group has investment advice permission User grants consent to delegate to access view data: ❑ Any investment adviser that has been given delegated access Additional: FCA consultation proposal Existing: DWP regulations enabled delegated access (when built into the architecture by PDP)
  • 19. 19 FCA Official Proposed revision to data export 19 CP22/25 respondent feedback ➢ unfair competitive advantage to dashboard operator firms/ group over other FCA regulated advisers Potential risks ➢ Competitive advantage to few dashboard firms with advice permission and vertically integrated firms ➢ Discourages active consumer choice in advice market: data export perceived as simple and convenient option Proposed revision: ➢ remove additional option for data export to PDS firm/ group for investment advice Proposed revised data export options: 1. Not to offer data export. 2. Offer self-export of data 3. Offer export to self and export to the PDS firm for post-view services - no longer include investment advice by the PDS firm/ group
  • 20. 20 FCA Official Proposed revised approach… 20 User can export view data to: ❑ PDS firm - to receive advice as a post-view service ❑ Advice entities in the same group as PDS firm User grants consent to access view data to any investment adviser given delegated access: ▪ Advisers at dashboard firms ▪ Advisers at non-dashboard firms FCA CP22/25 consultation proposal Delegated access (when built into the architecture by PDP) Intendedoutcome: • One consistent secure mechanism for all investment advisers to access view data (with consumer consent). ---------------------------------------------------------------------------------------------- ✓ promotes consumer choice beyond advisers in the dashboard firm or group ✓ all FCA regulatedinvestmentadvisersaccess view data on the same terms - no competitive advantage to PDS firms or vertically integrated firms
  • 21. 21 FCA Official Looking forward 21 Dashboards are likely to drive greater interest in pensions information, guidance and advice. Advice Guidance Boundary Review (AGBR) A joint review by HM Treasury and the FCA to examine the regulatoryboundary between financial advice and other forms of support: • outlined proposalsto help close the advice gap Review of AGBR outcomes and pensions dashboards Afterthe AGBR concludes, we will consider: • whetherany AGBR outcomescan be offered as a post-viewservice • whetherto permit data export to firms deliveringanyof the AGBR outcomes
  • 22. 22 Next steps 22 Steps Date Publish further consultation CP24/4 27 March 2024 Consultation CP24/4 closes 8 May 2024 Publish Policy Statement and make complete set of final rules and guidance: ➢ We will consider feedback to both CP22/25 and CP24/4 before finalising rules and guidance Q4 2024 (subject to external dependencies)
  • 23. 23
  • 24. Pension dashboard operators’ coalition update Richard to run slides
  • 25. Delivered by (Pensions) Dashboards Operators Coalition (DOC) Independent Pensions Dashboards Consultant Richard Smith Dashboard Operators Coalition
  • 27. Dashboards are a whole new technology ecosystem, a bit like an hourglass Compulsion Law (Layer 7) Connection (ISPs) (Layer 5) Consumers (Layer 1) • Data providers (Layer 6) i.e. (virtually) all UK pension schemes and providers • Dashboards (Layer 2) powered by • Digital architecture (Layer 4) Compliance (QPDSs) (Layer 3)
  • 28. All detailed research findings published on DashboardIdeas.co.uk
  • 29. What happens in Norway? • (Virtually) All Norwegian pension schemes & providers are API connected to • Front-end pensions dashboards, namely: 1. NorskPensjon.no direct, or 2. the NAV website (GOV.UK DWP equivalent), or 3. commercial financial apps (e.g. banking apps) • A central pensions data retrieval service, which, in turn, is API connected to
  • 30. 2023 usage statistics in Norway? Total population: 5.5 million Core working age population (16-65): 3.5 million • In 2023, how many times did Norwegian citizens request to retrieve and view all their pensions data, from the three different types of dashboard? • But first, for context: how big is the Norwegian population? 0.7 million requests 0.9 million requests 32 million requests
  • 31. How are industry bodiessupporting the PensionsDashboards Programme (PDP)? • In Layer 2, the (P)DOC will similarly work collaboratively to help get dashboards done • In Layers 5 & 6, PASA is doing great collaborative work with industry and PDP
  • 33. 8 Step Pathway to a Flourishing Dashboards Universe
  • 35. What’s next? 1. DOC to work collaboratively with DWP, FCA and PDP to ratify the 8 Step Pathway 2. Possibility of the DOC becoming part of an existing industry body? 3. Is your firm going to offer a QPDS? If so, are you interested in joining the Coalition? Contact: info@pdoc.org.uk
  • 36. Q&A
  • 37. Money and PensionsService, 120 Holborn, London EC1N 2TD Email : supportpdp@maps.org.uk Web : pensionsdashboardsprogramme.org.uk Stay in touch @pensions-dashboards-programme @PensionsDboards Sign up to our newsletter via our website