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We agree on the principle of delivering the Stronger Nudge to those 50 and over is appropriate although the earliest age for accessing pensions in most cases is 55increasing to 57. Might 50 be too early particularly as the proposal is to only nudge once?
We believe there is a need for greater clarity about Expected Retirement Income (ERI)and how the ecosystem is going to comply with Data Protection requirements and be compatible with providers' Application Programming Interface (API) for effective planning around sharing data and verifying members.
We support the work being done by TPR and others in seeking to protect the benefits of pension scheme members, to reduce the risk of calls on the Pension Protection Fund (PPF), and to promote the good administration of work-based pension schemes. We note that the government's policy intent in introducing the two new alternative 'act' tests to the existing CN power is to focus on the effect of an act on an employer, which in turn affects its capacity to support the scheme. We consider that both new tests meet the policy intent.
We believe that additional checks are required when schemes are transferring, including how they can be identified for the purposes of the regulations.