LISA offers potential to get more under 40 years’ olds saving but it also increases emphasis on getting communications right
24 November 2016
Comment
from Adrian Boulding, Head of Retirement
Strategy at Dunstan Thomas
With just over
four months to go until the launch of the Lifetime ISA,
the FCA has just published draft changes to its rulebook
to cover the selling of the new LISA in its
Consultation
Paper 16-32. In this 48-page hum-dinger, the FCA
identifies 11 potential risks that purchasers of a LISA
may be exposed to.
These risks fall into five key
categories as follows: complexity, contributions,
investments, access and tax. The regulator intends to
amend its handbook so that LISA sellers and providers
must disclose these risk warnings to customers when they
offer the product.
The FCA believes that investors
in LISAs should receive specific risk warnings in
respect of:
1. Incurring the early withdrawal charge
which may mean that they receive less from their LISA
than they paid in, and
2. Potentially losing an
employer contribution to a workplace pension for which
they may be eligible, where they choose to open a LISA
instead of opting into an Auto-Enrolment (AE) workplace
scheme when it is offered to them
But will a sheet of
risk warnings be any more help than the neatly folded
leaflet, that comes with prescription medicines warning
of potential side-effects? After all, most people don’t
read these leaflets until they’ve felt some of those
side-effects when it may be too late. Looking at the
different risks that FCA has identified, we can see that
we may need to deploy different customer engagement
techniques to address different types of risks.
The
early exit penalty can be addressed by using loss
aversion as the driver. A clear statement that says if
you invest £1,000 in a LISA in Year 1 and promptly
change your mind, and seek to withdraw it all, you will
lose £62.50, should frighten off anyone with cashflow
difficulties that might need their money back quickly.
We can use the natural human emotion that flows from
fear of loss to discourage those who cannot commit to
keeping their funds in a LISA – perhaps pushing them
towards a more flexible alternative such as a cash ISA.
The FCA’s next big concern is that customers might
choose LISAs over workplace pensions as their long-term
savings vehicle of choice. Despite all the Treasury
rhetoric that the LISA is not a competitor to pensions,
it is squarely aimed at younger savers where AE take-up
has been particularly strong.
Recent research by the
Institute of Fiscal Studies found that AE has increased
pensions membership of eligible 20-somethings from 27%
to 85%. FCA worries that the lure of the LISA’s early
Government-backed bonus might tempt younger employees to
switch their regular savings from an AE pension to their
LISA and consequently lose the all-important employer
contribution associated with auto-enrolment pensions.
We can use the human emotion of greed to push people
away from switching long-term saving away from AE and
into a shiny new LISA. A simple message to say that
there may be a better long-term savings vehicle for them
than the LISA in the form of a pension where their pot
will grow twice as fast as a LISA as their employer will
be paying in too.
But the FCA’s worries over
investment strategy are much harder to engage customers
on. The regulator has rightly pointed out that the
investments geared to supporting first home purchase in
three or four years’ time, are likely to be very
different from those suitable for saving for retirement
over a 30 or 40-year period (and designed to deliver
retirement income over a further 20 to 30 years). This
means that the provider needs to keep up-to-date with
the customer’s savings goals.
The customer’s
investment strategy will need to change if he/she
retains their LISA long after the window that the
provider would reasonably expect a first-time house
purchaser to have bought (and cashed up his LISA). At
this point, perhaps by age 40, the LISA holder’s
investment strategy will need to be reviewed and
possibly altered with a view to supporting their
retirement plans (which is the next exit point aged 60).
Customers buy savings products for all sorts of reasons:
perhaps they liked the advertisement, their mate down
the pub says he’s got one, they have a general sense
that they should be saving something and they’ve just
read that this new LISA is the latest Government
initiative for savers.
We must help convert that
generic enthusiasm for saving - to investing for the
future with a view to reaching a well-defined goal. That
means helping people to think ahead about what their
real goals are and when they want to achieve them by.
After all, we are not all like Michael Heseltine, who
famously sketched out his life plan on the back of an
envelope at Oxford and then achieved it all, apart from
falling marginally short as deputy prime minister!
But simulating people to do their financial planning,
often without the assistance of an adviser, will require
some highly imaginative and engaging communications
solutions to tempt them into those introspective
thoughts that can help us move from forming notional
aims to defining clear financial goals. The other thing
to consider is that this engagement work cannot just be
done at point of sale but through ongoing monitoring and
regular updating of progress and goals over the 40-year
plus duration of the LISA contract.
As always,
this innovative offering designed to support young
people in their quest to get on the housing ladder, has
turned out to be rather more complex and challenging
than it sounded when George Osborne announced it in his
2016 Budget. But that just makes our task of engaging
and communicating with savers that much more important,
and it’s not one we should shy away from as an industry.
Adrian Boulding is Director of Retirement Strategy at
Dunstan Thomas
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