In his Budget earlier this year, the Chancellor George Osborne announced sweeping changes that will remove the limits on the pension benefits that can be drawn from your pension scheme each year as well as reduce the taxation of benefits payable to your family in the event of your death. These new rules are set to come into force from 6th April 2015.
At DP Pensions Ltd, we have always sought to offer our clients the full range of options open to them and this development will be no different. We anticipate that we will be able to offer the new options to all our clients as soon as they become available on the 6th April.

About this document

This Bulletin is based on our understanding of the legislation and guidance recently published by HMRC with regards to pension flexibility for money purchase schemes from 6th April 2015.
Every care has been taken to ensure that it is correct. It is issued by DP Pensions Ltd for use by our SSAS and SIPP clients and their advisers.
Please note that DP Pensions Ltd and D A Phillips & Co Ltd are not authorised to give financial advice. We do not know all of your circumstances or details of any other pension schemes of which you are a member. You should contact your financial adviser for help on how this draft legislation may affect you personally.
No responsibility to any third party is accepted if this information is used for any other purpose. The legislation and HMRC practice may change in the future.

Summary of current rules

Under current rules, members can usually take their pension benefits from age 55. This age restriction is not changing and so the options outlined in this bulletin will only be available to members once they reach that age.
Members who have taken or “crystallised” their funds could be drawing a pension from their SSAS or SIPP under one of the current options:
Capped drawdown – allows you to draw an income limited to a maximum annual amount.
Flexible drawdown – allows you to draw any level of income without limits provided you meet certain requirements.
Scheme pension – allows you to draw a level of income which is set by the scheme actuary.
The new options will be available to clients who, on the 5th April 2014, are taking their pension under capped drawdown or flexible drawdown as well as to all clients who crystallise their benefits after the new rules come into effect. However, the new options will not be available to clients who are drawing their pension under Scheme Pension. Those clients will continue to draw the level of pension set by the scheme actuary. The new options are outlined in more detail below.

Flexi Access Drawdown

A new income drawdown option, Flexi Access Drawdown (FAD), will be introduced. The key features of this option are outlined below.

If you crystallise benefits after 6th April 2015

A pension commencement lump sum (PCLS) usually up to 25% of your fund will still be available as per the current rules.
There will be no annual restrictions on how much of the remainder of the fund that can be taken as taxable income – no maximum income limits will apply. There will also be no minimum income requirement.
As with all pension options, FAD is taxed as pension income at your marginal rate.
Taking an income under FAD will trigger the new money purchase annual allowance rules, which will restrict how much you can contribute to your pension schemes going forward – see later section for details of this.
All new drawdown pension funds created after 6th April 2015 will automatically become flexi access drawdown funds. Capped drawdown and flexible drawdown will cease to be an option for members taking benefits for the first time.
Payment from a dependant’s flexi access drawdown fund will not trigger the money purchase annual allowance rules.

If you are in capped drawdown at the 6th April 2014

If you have entered capped drawdown prior to 6th April 2015, then you can continue with this as long as you do not exceed your annual pension limit. New funds can be designated into an existing capped drawdown fund without triggering the money purchase annual allowance rules.
You can convert your capped drawdown fund into a FAD fund at any time after the 6th April 2015. At this point, you will no longer be subject to the annual limit on your pension and will be able to draw any amount of pension income, but you will be subject to the money purchase annual allowance rules.

If you are in flexible drawdown at the 6th April 2014

If you have a flexible drawdown fund then this will automatically be converted to a FAD fund on the 6th April 2015 and the money purchase annual allowance rules will come into effect.

Uncrystallised Funds Pension Lump Sum (UFPLS)

In addition to FAD, you will have access to a second new way to take your benefits from 6th April. It is not a drawdown product, because it is a one off payment rather than an ongoing regular one.
Uncrystallised funds pension lump sum (UFPLS) allows you to crystallise a fund and take all of it as a one off lump sum (subject to tax on part). Under these rules, 25% of the payment will be tax free and 75% of the payment will be taxed as pension income at your marginal rate of income tax.
The whole of the fund that you crystallise will be paid out leaving no drawdown fund remaining. However, it is still a benefit crystallisation and your fund will be tested against your lifetime allowance as with all crystallisations. The key features of this product are:
The option of a UFPLS will not be available to a member if they have rights to a disqualifying pension credit, primary protection, enhanced protection or a right to take a tax free lump sum of greater than £375,000 on 5th April 2006.
You can take a UFPLS from your whole fund or from just part of it. If you take a UFPLS from part of your fund then you can take subsequent UFPLS payments on an ad-hoc or regular basis.
Taking a UFPLS will trigger the money purchase annual allowance rules
For members under age 75 any UFPLS paid in excess of the member’s lifetime allowance will be taxed at 55% and the remainder paid as a lifetime allowance excess lump sum.
For members over 75 the tax free lump sum can not exceed an amount equal to 25% of the members remaining lifetime allowance. The rest of the lump sum is taxable as pension income
An uncrystallised funds pension lump sum can only be paid to the member so is not a death benefit option.

Money Purchase Annual Allowance rules (MPAA)

The Annual Allowance is the total amount that can be contributed to pension schemes for an individual each year that will qualify for tax relief. The standard Annual Allowance is currently £40,000.
However, if you take a UFPLS payment or enter FAD then this will trigger the money purchase annual allowance rules, which will reduce the Annual Allowance from £40,000 to £10,000 for money purchase savings.
The MPAA rules will be effective from the day after the trigger event occurred. The Key points of this are:
In addition to reducing the level of the annual allowance, carry forward will also cease to exist for these members
If a member takes a small pot lump sum their annual allowance is not reduced to £10,000
Special lump sum death benefits charge
The following applies to payments made after 6th April 2015.
The lump sum death benefit tax charge for members over 75 and the serious ill health lump sum charge will reduce from 55% to 45%.
Certain lump sum death benefits paid where the member at the time of their death was under age 75 will be tax free. This includes a drawdown pension fund, a flexi drawdown fund and an uncrystallised funds lump sum death benefit.

Other Changes

Trivial commutation and small pot lump sums payment minimum pension age reduced from 60 to 55, or earlier if ill health conditions are met.
Trivial commutation lump sums (£30,000) can only be paid from defined benefit arrangements.
For Pre A Day (ie before 6th April 2006) crystallisations there is a formula to apply when the first crystallisation post A Day occurs (25xGAD Max) this formula is being amended so that the GAD Max is reduced to 80% of the figure being tested so (25×80% of GAD Max).
Pension Commencement Lump Sum (PCLS) recycling – The amount has changed from 1% of the LTA to £7,500. If the payment is viewed as PCLS recycling an unauthorised payment charge will apply.

Reporting requirements

New reporting requirements for members and scheme administrators are being introduced. This includes the requirement for the member to inform all of their pension schemes that are receiving contributions when they trigger the money purchase annual allowance rules.

Death Benefits

The draft legislation and guidance issued by HMRC did not extend to cover all the proposed changes to death benefits and further information is expected to follow regarding:
Death before age 75
The ability to make payments to any nominated beneficiary
Pension payments to nominated beneficiaries to become tax free (the person receiving the pension will pay no tax on the money received)
Benefits will need to be nominated within two years to be tax free
Death after the age of 75
The ability to make payments to any nominated beneficiary
Pension payments to nominated beneficiaries will be paid subject to the beneficiaries marginal rate of income tax
Proposal for the lump sum payment subject to 45% to be amended to marginal rate by 2016
More information
If you have any queries regarding the information in this Bulletin and about how it affects your circumstances then please contact your financial adviser.

Contact us

This bulletin was issued by DP Pensions Ltd. Our contact details are as follows:
DP Pensions Limited
Bridewell House, Bridewell Lane, Tenterden Kent, TN30 6FA
Tel: 01580 762 555 Fax: 01580 766 444
Email: mail@dapco.co.uk
Web: www.dapco.co.uk
Authorised and regulated by the Financial Conduct Authority
Registered in England No 4622475 Registered Office as above

About this document

This Bulletin is based on our understanding of current and proposed legislation and HMRC practice and every care has been taken to ensure it is correct. It is issued by DP Pensions Ltd for use by our SSAS and SIPP clients and their advisers. By its very nature it is a précis and can only be treated as a simplified indication of detailed legislation.
Please note that DP Pensions Ltd is not authorised to give financial advice. We do not know all of your circumstances or details of any other pension schemes of which you are a member. You should contact your financial adviser for help on how these new rules affect you personally.
No responsibility to any third party is accepted if this information is used for any other purpose. The legislation and HMRC practice may change in the future

The Changes

On the 19th March 2014, Chancellor George Osborne announced big changes to pensions in the Budget 2014. Some of the changes to registered pension schemes tax rules announced were foreseeable, but the headline change – the wiping away of all restrictions on drawdown of pension funds at retirement – came completely out of the blue. Some of the changes will be effective from the 27th March 2014, while some will come in next year (April 2015) following consultation.
The key announcements are outlined below.

Changes with effect from the 27th March 2014

Increase to Capped Drawdown

In 2011, the Government reduced the rate that we use to calculate the maximum pension that a member can draw from their pension each year under capped drawdown. We were required to use 100% of the Government Actuary Department (GAD) Rate, rather than the 120% that we could use previously. Then on 26th March 2013, the rate was increased back up to 120%.
The Government has now announced that the rate will be increased again to 150% of GAD. Legislation needed to affect this change is in the Finance Bill 2014 which should receive Royal Assent in the summer.
The change will take effect from the 27th March 2014. Members can take advantage of the new rate from the start of their next pension year following this date. A member’s pension year normally runs from the anniversary of the date that they initially took their benefits.
However, please note that since the primary legislation will not be enacted until the summer of 2014, we will require an indemnity from members wishing to take advantage of the new limits before the Finance Bill receives Royal Assent.

More flexible Flexible Drawdown

Flexible drawdown allows members to draw a pension without any limits provided they meet a Minimum Income Requirement (MIR). The MIR must be provided by a secure pension income made up of social security pensions, lifetime or dependents’ annuities or scheme pension provided by schemes with more than 20 members.
The Minimum Income Requirement was £20,000 pa, but the Government announced that it will reduce to £12,000 pa from the 27th March 2014.

Trivial Commutation

The Government also announced that from the 27th March 2014, they will increase to £30,000 the maximum total fund value to qualify for trivial commutation whereby pensions can be cashed-in.
They will remove revaluation factor for determining how much of the commutation limit is used up by previous crystallisations.
They will increase the “small pots” commutation limit to £10,000 per pot that can be cashed-in and increase the number of such small pots that can be commuted to three.

Changes that will come into effect later (subject to consultation)

In addition to the above changes, the Government also announced further measures that could remove all limits on the amount of pension that a member can draw from their pension fund. The following announcements are in their early stages of development and need to go through consultation before they are finalised. This means that they may change before they become law.

Flexible Drawdown for all

The Government announced that it plans to completely remove the restrictions on the rate at which crystallised funds may be drawn from a defined contribution (DC) scheme from April 2015. At the moment members are taxed at 55% if they draw a pension in excess of the capped drawdown limits above (unless they are on flexible drawdown).
Instead the Government proposes to tax all withdrawals (other than the pension commencement lump sum which is tax free) at the member’s marginal rate of income tax. This will essentially mean flexible drawdown will be extended to all members with no minimum income requirements or other criteria to be met. So members will be able to draw any level of pension they want.
The pension commencement lump sum (tax free cash) rules which allow a payment of usually 25% of the member’s fund to be paid when they take their benefits are unchanged. All remaining funds will simply be taxed at the member’s marginal rate as and when received.
The Government also announced a possible reduction of the current 55% tax charge on lump sums from crystallised funds on death.
There will likely be a ban on transfers from public sector defined benefit (DB) schemes – and possibly from all DB (otherwise known as final salary) schemes – to defined contribution (DC) schemes, or at least restrictions on the use of transferred funds, to prevent a sudden haemorrhaging of funds from people looking to take advantage of this new flexibility.
Finally, the Government announced it plans to increase the minimum pension access age from 55 to 57 from April 6th 2028 (the date on which state pension age becomes 67).
For more information please see https://www.gov.uk/government/consultations/freedom-and-choice-in-pensions
There are no (new) changes proposed to the maximum pension contribution (annual allowance) or to limits on maximum pension fund accumulated (lifetime allowance), or to the availability of higher and additional rate income tax relief on contributions.

“A guidance guarantee”

The Government announced that it intends to introduce a ‘guidance guarantee’ meaning all individuals with a defined contribution pension will be offered free guidance at the point of retirement from April 2015.
The government said the guidance must be “impartial and of consistently good quality”. It also must:

• cover the individual’s range of options to help them make sound decisions and equip them to take action, whether that is seeking further advice or purchasing a product;
• be free to the consumer; and
• be offered face to face.

The government has asked the Financial Conduct Authority to make sure this guidance meets “robust” standards, working closely with consumer groups.
The government will also make a £20m development fund available to get the initiative up and running over the next 2 years although product providers are estimating this will cost much more.

“Battle lines drawn on pension liberation fraud”

HM Revenue & Customs (HMRC) is set to receive new powers to help it fight the battle against pension liberation fraud. Pension liberation also known as ‘pension loans’ and ‘pension scams’, is a transfer of a scheme member’s pension savings to an arrangement that will allow them to access their funds before the age of 55.
In rare cases – such as terminal illness – it is possible to access funds before age 55 from a current pension scheme. For the majority, promises of early cash will be bogus and are likely to result in serious tax consequences.
HMRC was granted new powers to de-authorise schemes which it suspects are being used for pension liberation fraud and to block the registration of schemes which it deems unsuitable.
HMRC will have the power to require scheme administrators to pass a ‘fit and proper person’ test. The powers will allow HMRC to refuse to register a scheme, or de-register an existing scheme if, in HMRC’s opinion, the scheme administrator is not a fit and proper person.
The test will come into effect in September.
HMRC will have new powers to send information notices to the scheme administrator and other persons, in order to help it decide whether or not to register a pension scheme.
HMRC will also have new powers to enter business premises and to inspect documents.
HMRC’s guidance note is here: https://www.gov.uk/government/publications/pensions-liberation-guidance-note

We are very proud to announce that we have received a Defaqto 5 Star Rating for our Premier Trust SIPP for 2014.
Defaqto is an independent financial research company focused on supporting better financial decision making.
The 5 Star Rating means that the Premier Trust provides one of the highest quality offerings on the market.
More information about Defaqto can be found at www.defaqto.com

Following the recent reports that Standard Life will no longer permit SIPPs to undertake a mortgage for a commercial property purchase, we wish to confirm our commitment to allowing SIPPs and SSASs to continue to borrow up to 50% of the net assets of the scheme.
We have no plans to change our view on this. Most borrowing is subject to usual terms and conditions agreed with the lender. Although there have been difficult times for clients we have not experienced any defaults. Please call if you wish to discuss a commercial property purchase.
The relevent news articles can be found at:
http://www.moneymarketing.co.uk/news-and-analysis/pensions/sipps/standard-life-to-scrap-sipp-commercial-property-borrowing/2005088.article
https://www.ftadviser.com/2014/01/10/pensions/sipps/standard-life-ceases-commercial-property-sipp-loans-6h0znlcDEzV6r54DDqjjPJ/article.html
See our Property and Borrowing Sections for more information about borrowing and commercial property

About this document

This Bulletin is based on our understanding of current and proposed legislation and HMRC practice and every care has been taken to ensure it is correct. It is issued by DP Pensions Ltd for use by our SSAS and SIPP clients and their advisers. By its very nature it is a précis and can only be treated as a simplified indication of detailed legislation.
Please note that DP Pensions Ltd is not authorised to give financial advice. We do not know all of your circumstances or details of any other pension schemes of which you are a member. You should contact your financial adviser for help on how these new rules affect you personally.
No responsibility to any third party is accepted if this information is used for any other purpose. The legislation and HMRC practice may change in the future.

The Lifetime Allowance to reduce from £1.5 million to £1.25 million

The Lifetime Allowance is the maximum amount of pension savings, that an individual can accumulate free of tax, across all pension funds. The Lifetime Allowance is currently £1.5 million (for the 2013/14 tax year). However, this will be reduced to £1.25 million from the 6th April 2014.

Fixed Protection 2014

The Government has introduced a new “Fixed Protection 2014” to protect those clients whose funds do (or may) exceed the new limit of £1.25 million up to the current Lifetime Allowance of £1.5 million.
You must apply for the protection online and the deadline for applying is the 5th April 2014.

How do I decide if I need Fixed Protection 2014?

HM Revenue & Customs has set up an online tool to help you decide whether you should apply for Fixed Protection 2014 and/or Individual Protection 2014. The tool can be found at www.hmrc.gov.uk/pensionschemes/fp14online.htm.
You should also contact your Financial Adviser who will be able to advise you.
Please note that Fixed Protection 2014 is only available if you don’t have any of the existing Lifetime Allowance protections on 6th April 2014. Those protections are primary, enhanced or fixed protection 2012. If you have one of these protections you should check that the particular protection you have remains valid. If the existing protection is lost before 6 April 2014, then you will be able to apply for fixed protection 2014, giving you a protected Lifetime Allowance of £1.5 million from 2014-2015 onwards.

How do I apply for Fixed Protection?

If you decide that you want to apply for Fixed Protection 2014 you should notify HM Revenue & Customs by completing their online form. The form can be found at www.hmrc.gov.uk/pensionschemes/fp14online.htm. The deadline for submitting the form is the 5th April 2014.
HM Revenue & Customs will provide you with an immediate confirmation of receipt when you submit your online application. Once they have processed and accepted your application, they will also send you a certificate which you should show to your pension scheme administrator every time you take any benefits from your pension scheme(s).

How do I make sure that I do not lose Fixed Protection 2014?

If you have successfully applied for Fixed Protection 2014 then to keep this protection there are restrictions on any tax relieved pension savings that you can make from 6 April 2014. The basic requirement is that no further contributions can be paid into any pension schemes for you from that date. This includes accruing benefits in a final salary pension scheme.
More information about these restrictions and Fixed Protection 2014 can be found at www.hmrc.gov.uk/pensionschemes/pension-savings-la.htm.

Individual Protection 2014

In addition to Fixed Protection 2014, the Government has also announced that it will introduce an Individual Protection 2014. However, the details of this have not yet been decided. The Government launched a consultation on this subject on the 10th June 2013 and this runs until 2nd September 2013. It is proposed that members will be able to apply for the protection from the 6th April 2014 and that they will have three years in which to make their application. More information about Individual Protection 2014 will be provided once they are known.

The Annual Allowance

The Annual Allowance is the total amount that can be contributed to pension schemes for an individual each year that will qualify for tax relief. It is currently £50,000 per annum for the 2013/14 tax year. However, this will be reduced to £40,000 from the 6th April 2014.
For people who do not use all of their annual allowance in a particular year, they can carry forward any unused relief for up to three years, provided they were a member of a registered pension scheme during the period. The Government has confirmed that the amount that will be available to be carried forward will be based on the annual allowance that was applicable in the year that the member is carrying forward from.
Please note that other thresholds also apply to contributions. Individuals will only receive tax relief on personal contributions up to 100% of relevant UK earnings; and Employers will only receive tax relief on company contributions where the contribution is ‘wholly and exclusively for the purposes of the business’.

Update on the Chancellors Autumn Statement announcements

Lifetime Allowance

The Lifetime Allowance is the maximum amount of pension savings, that an individual can accumulate free of tax, across all pension funds. The Lifetime Allowance is currently £1.5 million. However, this will be reduced to £1.25 million from the 6th April 2014.
Members with enhanced, primary or fixed protection will not be affected by the reduction in the lifetime allowance. A member will lose fixed protection or enhanced protection if further contributions are paid by or on their behalf.
The Chancellor announced a new “Fixed Protection 2014” will be available for those who may be affected by this cut. The forms are expected to be ready by the summer of this year, with a deadline for submitting them to HMRC of 5th April 2014.
The Chancellor also announced that they are considering a new “personalised protection” in addition to Fixed Protection. This would allow members whose pension savings are over £1.25 million on 5th April 2014 to continue to make pension contributions with an individual lifetime allowance of the greater of the value of their pension rights on that date and the new lifetime allowance. The Government will discuss this possibility with interested parties.

Annual Allowance

The Annual Allowance is the total amount that can be contributed to pension schemes for an individual each year that will qualify for tax relief. It is currently £50,000 per annum. However, this will be reduced from £50,000 to £40,000 from the 6th April 2014.
For people who do not use all of their annual allowance in a particular year, they can carry forward any unused relief for up to three years, provided they were a member of a registered pension scheme during the period.
The Government has confirmed that the amount that will be available to be carried forward will be based on the annual allowance that was applicable in the year that the member is carrying forward from.
Please note that other thresholds also apply to contributions. Individuals will only receive tax relief on personal contributions up to 100% of relevant UK earnings. Employers will only receive tax relief on company contributions where the contribution is ‘wholly and exclusively for the purposes of the business’.

Capped Drawdown

In 2011, the Government reduced the rate that we use to calculate the maximum pension that a member can draw from their pension each year under capped drawdown. We were required to use 100% of the Government Actuary Department (GAD) Rate, rather than the 120% that we could use previously.
The Government has now announced that the rate will be brought back up to 120% of GAD. Legislation is needed to affect this change, but the draft legislation has been released for consultation.
The change will take effect from the 26th March 2013. This means that members can take advantage of this new rate at their next pension review after this date. Members can also request an interim review at any pension year end falling after the date.
However, please note that since the primary legislation will not be enacted until the summer of 2013, we cannot allow members to draw their full entitlement until that time in case the rules are amended before they become law.

With effect from the 21st December 2012 the rates used to calculate women’s pensions under capped drawdown will be brought in line with the rates used for men. This change was brought about as a result of a recent European Court of Justice ruling which found that insurance companies cannot base the price of pensions on the gender of a person.
Currently there are separate Government Actuary’s Department tables for men and for women and we use the appropriate one when calculating someone’s maximum pension under capped drawdown. However, from the 21st December we will have to use only the men’s tables for both men and women. The rates on the men’s tables are better than the rates on the women’s tables because men on average have a lower life expectancy than women. As a result, women will be better off following this change and men will be unaffected.
Any female clients who are already receiving a pension through capped drawdown or who begin drawdown before the 21st December will continue with their current maximum pension until their next pension review. At that date their review will be conducted using the men’s tables.
All of our SSAS and SIPP clients also have the right to request that their maximum capped drawdown pension is reviewed on any pension year end date. This would mean that our female clients might be better off if they request a review at their first pension anniversary following the change.
Any female clients who are considering taking their benefits and drawing an income through capped drawdown, may be better off if they wait until after the 21st December as we will then be able to use the new rates.
For further information about capped drawdown and how it is calculated, please visit the technical section of our website.

We have been looking for some time to find a bank that can deliver a greater range of bespoke banking services to our SIPP clients as well as competitive interest rates and a high quality service. After much research, we have chosen to work with Metro Bank Plc.
DP Pensions has been providing pension administration services for over 25 years from its offices in Kent. We have been continually upgrading our own administration systems but have been seeking to work closely with a high street bank to provide a fully integrated banking service to our clients.
In selecting Metro Bank, we are seeking to maximise interest rate returns to our clients. The current rates that will apply to the accounts are as follows:

A full range of banking products will be delivered on a one-stop basis, so eliminating the need for clients to seek more competitive banking returns elsewhere, however if any member wishes to hold another deposit account with another bank then we are happy for them to do so, but Metro Bank will be the audit trail account for the SIPP. We will have on-line access to all accounts and a full interface to our own systems and so will be able to permit clients to have immediate access to up-to-date balances and a full history of banking transactions. Each client will sign a mandate for their new account and migration will be controlled and smooth. From 5 December 2011 all new SIPPs will be set up with a Metro Bank account.
Metro Bank is the first new British bank on the high street in over 100 years. They opened their doors to the public on the July 2010. In order to launch this service they have built a dedicated team of professionals with over ten years experience of providing pension banking requirements. Metro Bank is FSA approved and complies with the FSA’s proposed new capital adequacy requirements for banks.
If you wish to discuss this further or have any other questions please do not hesitate to contact your account administrator.

If you are trying to set up a SIPP with ourselves in order to complete a Pension Back loan to a 3^rd party company Solar Solutions and have been told by them or Pension Back Loans (a trading name of FS Resourcing Ltd) that we will accept these loans please note that this is incorrect. We have decided that we are not allowing these loans.

In our newsletter dated 20 December 2010 we stated that the new Pension changes were going to allow a new drawdown called ‘Flexible Drawdown’. These new rules stated that to qualify for Flexible drawdown you had to have a minimum income requirement (MIR) of £20,000 pa. This income could be a mixture of social security pensions, lifetime or dependants’ annuities or scheme pension.
Yesterday, 31 March 2011, there was an amendment that stated for scheme pension to qualify for MIR it had to be from a scheme of 20 or more members. This effectively rules out SSAS or SIPP scheme pension being used to provide the MIR. There are, of course, other reasons where scheme pension will be a useful tool for clients.