Open letter petitions Frank Field for transparency inquiry

An open letter from more than a hundred stakeholders from across the pensions industry has called on Work and Pensions Select Committee chair Frank Field MP to open an inquiry into charges levied on pension fund investors.

Andy AgathangelouCo-ordinated by Transparency Task Force founder Andy Agathangelou, the letter, which is printed in full below, calls on the committee to carry out an independent enquiry into charges, building on and pulling together the work already underway at the FCA, DWP and The Pensions Regulator.

Signatories include academics, members of trade bodies, representatives of pension schemes, union officials, providers and pension consultants. The list of signatories, below, includes 99 UK-based pension professionals as well as figures from abroad including the US, Israel and Australia.

Agathangelou says: “It is perfectly clear from recent debates in the Commons that all sides of the House are keen for greater transparency in pensions, because that will drive better outcomes for the UK’s pensions-savers. The Financial Conduct Authority’s Asset Management Market Study has done a superb job in shining a light on the many problems within the Asset Management, but that’s just one link in the ‘value’ chain. For example, there are costs in areas such as administration, platforms, distribution, invoicing, communication and so on that also need properly accounting for.

“What is needed is an inquiry that takes a holistic view on all costs adversely impacting pension schemes. In fairness to asset managers it’s not just their sector that needs sorting and the inquiry would broaden the debate accordingly. The timing is perfect, because the market study concludes in the summer, by which time the Work and Pensions Committee may have already given the Financial Conduct Authority and The Pensions Regulator a steer on what else they might want to look into. The inquiry would be “a tide to rise all boats” and it seems to me that Parliament, the regulators and all right-minded market participants see the need. My fingers are crossed that Frank Field MP and his committee see it that way too; I hope so, as they are best-placed to carry out this truly vital work.”

The Rt. Hon Frank Field MP
Chair, Work and Pensions Committee
House of Commons
London SW1 OAA

Dear Mr. Field,

We are writing to you as a group of independent individuals and organisations, motivated and united by the desire to help protect the interests of the UK’s saving public, through the better provision of transparent, consistent and straightforward disclosure of all the costs and charges they pay.

The issues raised in this letter affect Defined Benefit and Defined Contribution pension schemes and cannot be dealt with fully under the scope of your existing Defined Benefit pensions inquiry.

It is vital that we have transparent, consistent and straightforward costs disclosure because opacity and obfuscation on pension and investment costs leads to:

#1. Decision-makers, including consumers, being unable to exercise ‘informed choice’ properly: They find the market opaque, complex and confusing: It is difficult to identify value for money

#2. The risk of future litigation: Consumers may argue they are not being treated fairly. Such action would severely damage confidence in the sector and its intermediaries.

#3. Seemingly impotent market forces: In this sector, the ‘invisible hand’ seems unable to work its ‘magic’ to create a healthy, competitive and efficient market.

#4. Poor consumer outcomes: If costs are 2% p.a. and gross market returns 5% p.a., a 20-year-old saving £100 per month until 65 will lose 42.55 % of his/her pension fund to costs.

#5. A marketplace where progressive, innovative and highly cost-effective offerings that do represent good value for money inexplicably struggle to get the market share they should.

#6. The risk that the success of the Government’s pensions policy is jeopardised: Those automatically enrolled might opt out if they are later disappointed by their net of costs returns.

#7. The risk that should the ‘high costs/low returns’ reality continue to prevail, belief in the wisdom of deferred gratification and confidence in long term savings will be undermined.

#8. Investment Governance Committees and Trustee Boards struggle with their duty to manage scheme’s costs properly: ‘You can’t measure, monitor or manage what you cannot see.’

#9. Bad publicity, falling trust and apathy: The public’s confidence in pensions is falling sharply and we want to stop it falling ‘below the point of no return’: This is a serious and systemic risk.

#10. The UK’s savings market, including pensions, not being seen to be well-governed, transparent and trustworthy: That’s a particularly important point in our post-Brexit world.

Furthermore, we believe that savers should not only know what their savings cost; they should also know where and how their money is invested. Greater transparency in investment holdings and the stewardship around those holdings is needed. On the basis that it is hard even for MPs to establish where and how their own Parliamentary Contribution Pension Fund is being invested, it follows that the public as a whole may be similarly challenged.

In general terms, we believe that:

  • This is an important and widespread public interest issue; it has parallels with the known shortcomings that are affecting the energy sector’s opaque and complex regime of tariffs.
  • Greater transparency on costs and investment holdings will help create the better-served, better-engaged and better-performing savings market we all want.
  • There is merit in doing all we collectively can to help sustain the success of the Government’s automatic enrolment pensions policy.
  • In a post-Brexit world, we shouldn’t underestimate the value to our economy of the potential for the UK becoming the world-leader in pensions and investing transparency.
  • Your Committee is uniquely placed to lead an open enquiry that we are confident would be run in a constructive, forensic, inclusive, robust and non-partisan way, for the long-term benefit of all.
  • There is excellent regulatory activity underway by DWP, FCA and TPR; your enquiry would support that work by ‘pulling it all together’, creating an even more cohesive approach.

To conclude: For reasons of social justice, market efficiency, good governance, national reputation and to help protect the ongoing success of the Government’s pensions policy, we would like your Committee to open an inquiry into the matters set out in this open ‘letter’.

I believe the Financial Times are publishing an article regarding this request online today and in their newspaper tomorrow.

If requested I would be happy to liaise with yourself and/or your Committee Clerk regarding this matter.

For administrative purposes (as it would not be practical to liaise with all the co-signatories) please reply to

We look forward to hearing from you

Yours sincerely

First Name Last Name Position Organisation Website



Managing Director Able Governance Ltd


David Rich CEO Accurate Data Services Ltd


Phil Ninness Business Development Manager Accurate Data Services Ltd


Tracey Sharman Head of Operations Accurate Data Services Ltd


Aidan Dennis Managing Director Amaces


Ian Neale Director Aries Insight




Turner Co-Chair

Association of Member-Nominated





Weeks Co-Chair

Association of Member-Nominated



John Paradise Committee Member Association of Member-Nominated Trustees


Bob Scott Chairman Association of Consulting Actuaries



JB Beckett UK Representative, Author Association of Professional Fund Investors


Mark Miller Vice President, Employee Benefit Consultant Barclays Corporate & Employer Solutions


Stuart Barker Director Barker Coaching & Consulting   
Pete Eggleston Founder Director BestX



Jo Thresher Director Better With Money


Valborg Lie Director Borg Consulting


Philip Meadowcroft Chairman of Trustees Brandmasters Ltd Executive Pension Scheme  
Steve Lugg Project Manager, Finance & Procurement Consultancy Buckinghamshire County Council


Sunil Chadda Managing Director Cairn Consulting Ltd  
Professor Andrew Clare Chair in Asset Management Cass Business School 
Professor David Blake Director, Pensions Institute Cass Business School


Professor Steve Haberman Professor of Actuarial Science, Faculty of Actuarial Science and Insurance Cass Business School


Maurice Frankel Director Campaign for Freedom of Information



Tony Filbin Chairman Capital Cranfield Holdings Ltd



Edward Bushnell Compliance Director Cavendish Medical


Graham Cook Board Member CFA Society of the UK


Alice Garton Senior Lawyer Client Earth


Jeremy Coller CIO Coller Capital








Consumer Insights Ltd 


Alan Salamon Managing Director Corpias



David Stripp Principal David Stripp Consulting  
Andrew Penketh Partner, Head of Pension Funds Crowe Clark Whitehill LLP


Emma Gleaves Employee Benefits Consultant    
Niall Ferguson Principal Consultant Engaging Reward  
Ben Faulkner Communications Director EQ Investors


Chris Connelly Lead Business Solutions Architect Equiniti


Luis Rivera    Co-Founder & CEO ETFmatic Ltd


Jan Lambert Independent Consultant    
Chris Hewett Head of Advocate Programme Finance Innovation Lab


Robert Young BSc FIA Consulting Actuary Gordon Dadds



Nick Keppel-Palmer Head of Strategy Husky Finance
Fiona McDonagh Senior Scheme Secretary Inside Pensions


SV Rangan Director IFG Worldwide Ltd  







Jane Marshall Consulting LLP
James Meenan Principal JNM Investment Governance


Mike Hopwood Head of Pensions Kier Business Services


Vidya Nathan Aspiring Investment Consultant    
Mike Barrett Consulting Director The Lang Cat


Jeff Houston Head of Pensions Local Government Association


Francisco Gomes Professor of Finance London Business School


Philip Brown Head of Policy LV=


Terence Prideaux Managing Director Morley Hall Ltd  
Tim Walton Manager, Data and Research Strategy Morningstar






Barry Mack Client Director Muse Advisory
Alan Browne CEO MyFutureNow


Malcolm Booth

Chief Executive Officer


National Federation of Occupational Pensioners



Alex Noble Director Noble & Associates Ltd


JB Beckett Consulting Chie Investment Officer and Author New Fund Order Consulting  
Derek Bradley Founder & CEO Panacea Adviser


Callum Mayor



PEN Partnership LLP



Henry Tapper Founder Pension PlayPen


Philip Miller Founder Pensions Focus


Tim Middleton Technical Consultant Pensions Management Institute


Daniel Godfrey co-Founder The People’s Trust.


Rohan Sivajoti Director, Postcard Planning


Jon A Collins Director Professional Pensions and Investments Ltd.



Andy Scott Principal Punter Southall


Paul Trickett Chair Railpen Investment


Malcolm Small Executive Chairman Retirement Income Alliance Ltd


Rob Lake Responsible Investment Advisor Rob Lake Advisors


Nick Greenwood Pension Fund Manager The Royal Borough of Windsor & Maidenhead



Tony Greenham Director of Economy, Enterprise and Manufacturing Royal Society of Arts, Manufactures and Commerce



David Pitt-Watson Leader The RSA’s Tomorrow’s Investor Project


Dr. Hari Mann Director The RSA’s Tomorrow’s Investor Project


Adam French Co-founder & Managing Director Scalable Capital Ltd

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Shazia Afghan Litigation and Contentious Regulatory Lawyer/Institute Fellow Seven Pillars Institute for Global Finance and Ethics


Catherine Howarth Chief Executive ShareAction





Lead Adviser & Co-Director


Simplified Money




Sarah     Hutchinson         Consultant  S J Hutchinson Ltd    
Andrew Evans Chief Executive Officer Smart Pension


Gerry Wright Partner Smith & Williamson Investment Management


Dr. Daniela Carosio Senior Partner Sustainable Value Investors


Graham Wrightson Partner Stephenson Harwood LLP



John Serocold Principal Studio Serocold  
Dan Norman CEO TCF Investment


Mark Goyder Founder & Chief Executive Tomorrow’s Company


Andy Agathangelou Founding Chair Transparency Task Force


Nic Round Client Strategist & Wealth Adviser Treowe Wealth Partners



Tim Sharp Policy Officer TUC



Alex Letts Chief Unbanking Officer U



Michelle Baddeley Professor in Economics & Finance

UCL Bartlett Faculty of Built Environment

University College London


Markus Krebsz Interim CRO Member of UNECE GRM



Steve Kenzie Executive Director United Nations Global Compact UK


Noel Whiteside Professor of Comparative Public Policy University of Warwick



Paul Hewitt Senior Business Development Manager Vigeo Eiris
Michael Cotter Solicitor Advocate & Partner Waterside Legal LLP


Geik Drever Strategic Director of Pensions West Midlands Pension Fund


Stuart Travers Director Winterbourne Trustee Services Limited.



Steve Conley Managing Director Workplace Pensions Direct


First Name Last Name Position Organisation Website Country
Sam Instone CEO AES International


United Arab Emirates (DIFC)





Managing Partner Fiduciary Wealth Partners



Ronan O’Houlihan Founder Calm Financial Care Ireland
Stephen Davis Associate Director and Senior Fellow,  Programs on Corporate Governance and Institutional Investors Harvard Law School



Richard Field Founder Institute for Financial Transparency


Paul M. Secunda Professor of Law and Director, Labor and Employment Law Program Marquette University Law School USA
Phil Stockton FHKSI MCSI Director Private Capital Ltd


Hong Kong
Dr. Kara Tan Bhala President and Founder Seven Pillars Institute for Global Finance and Ethics




Oren Kaplan Co-Founder Sharing Alpha


Nicholas Morris

Adjunct Professor, Faculty of Law


University of New South Wales, Sydney, Australia


Erik Conley Founder ZenInvestor