Cash Flow Models – compliant or not?

Cash flow modelling – issues with assumptions

When reviewing advice on DB transfers, it is not uncommon for us to come across cases where different projections result in the client receiving a mixed message. For example:

Factor                                                            Indicating

Critical yield (or TVC) is very high               Transfer is unlikely to be advisable

Drawdown run out age is high                    … but your fund will never run out

Cash flow model is ‘optimistic’                   … and your income will be higher too!

The first two factors appear in the Pension Transfer Report (previously the TVAS), so it is understandable that advisers might assume that these are comparable – but they are not. They measure entirely different things and are based on entirely different assumptions. These differences need to be understood and explained to clients.

Cash flow models are increasingly being used by firms when advising on pension transfers, and the assumptions that firms make are widely variable, in particular, the growth rate. This often results in cash flow models that give an impression of the client’s future financial situation that is not only more optimistic than realistic, but also confusingly different to the indications from the key elements of the Pension Transfer Report, namely the TVC and critical yield figures.

The FCA considered the use of cash flow models when finalising the new transfer advice rules that took effect in 2018 and decided against requiring their use. In fact, the FCA has concerns about the use of cash flow models of which more later.

However, the rules do not preclude the use of cash flow models, or other projections, provided certain conditions are met. Identifying those conditions is not easy as they are contained in several different places within the FCA Handbook. The key requirements are:

  • such analyses must not be given more prominence than an analysis prepared in accordance with COBS 19 Annex 4A;
  • projected outcomes at the 50th percentile must be no less conservative than if the analysis had been prepared in accordance with COBS 19 Annex 4A and COBS 19 Annex 4C;
  • any indication of future performance must comply with COBS 4.6.7R, the key points of which include:
    – it is not based on and does not refer to simulated past performance;
    – it is based on reasonable assumptions supported by objective data;
    – the effect of commissions, fees or other charges is disclosed;
    – it contains a prominent warning that such forecasts are not a     
      reliable indicator of future performance.
  • the projection must use rates of return which reflect the investment potential of the assets in which the retail client’s funds would be invested under the proposed arrangement;
  • use more cautious assumptions where appropriate;
  • when making assumptions about the rate of return under COBS 19 Annex 4A, a firm should consider consistency with other assumptions (such as inflation and exchange rates);
  • assumptions must take account of all charges that may be incurred by the retail client as a result of a pension transfer or pension conversion and subsequent access to funds following such a transaction (except for non-contingent charges or charges paid by a third party e.g. the employer;
  • charges that should be included in the analysis include:
    – product and fund charges;
    – platform charges;
    – adviser charges in relation to the personal recommendation and
      subsequently during the pre-retirement period as well as at benefit
      crystallisation and beyond, where likely to be relevant;
    – and any other charges that may be incurred if amounts are
      subsequently withdrawn;
  • different assumptions that produce different illustrative financial outcomes should be clearly explained to the client.

 

Meeting the requirements
So, the rules do not preclude the use of cash flow models, but they must be used in accordance with a pretty demanding set of rules as summarised above and must also satisfy the clear, fair and not misleading rule. Firms must use growth assumptions that are no less conservative than the mandated assumptions and, where other assumptions are used in addition, these must be realistic and supported by objective data. Charges must be accounted for and all relevant projections should be explained clearly to the client.

The objective of the rules is to ensure that clients are given a fair and accurate indication of how their finances might look in future so that they can make an informed decision as to whether to transfer or not. Facing the client with different outcomes from different projections, especially without adequate explanation, hinders an informed decision and could result in a future complaint. Ideally, firms should ensure that they use consistent assumptions. The FCA has stated:

“It is our preference that the role played by the proposed receiving scheme is communicated to the client in the advice as consistently as possible with the KFI which will be provided to the client if a transfer was to proceed.”

The KFI must use mandated growth assumptions.  For pension products, the MAXIMUM intermediate rate is currently 5% (ignoring inflation reduction) … but, as required by the rules, a lower rate must be used if more appropriate to the funds in question. The higher and lower rates are then simply 3% points above and below the relevant intermediate rate. The provider of the KFI should do all the ‘objective data’ work to assess the appropriate intermediate rate.

So, the simplest way to ensure the cash flow growth assumption meets all the rules is to look at the key features illustration (KFI). The intermediate growth rate used there (before inflation) can be taken as an appropriate gross growth assumption for any cash flow model that is to be prepared.

To meet the requirement to take account of charges, a deduction must be made to reflect the overall charges that will apply. The net result is an appropriate growth assumption to use within the cash flow model. At its simplest, it would look like this:

Intermediate rate from the key features illustration                          X%

Less reduction in yield (RIY) figure from the KFI                                  Y%

Appropriate rate of return to use in the cash flow model                (X-Y)%

However, the RIY figure does not usually reflect the initial adviser charge accurately – it will be amortised over a number of years rather than accounted for up front. This means the RIY on the KFI is understated, although probably not enough to be significantly misleading. How can this be allowed for in the cash flow model?

It could be argued that using the straight RIY figure from the KFI will still result in a growth assumption that is closer to the requirements of the rules than the assumptions currently used in cash flow models by many firms.

However, a more accurate way to incorporate the initial charge would be to deduct it in cash up front from the starting capital and then deduct the annual adviser, platform, plan and fund charges from the KFI intermediate growth rate and use the net result as the cash flow growth assumption. It would be good practice to ensure that the client is aware of the basis of the model, including the assumptions used.

So, now the basis of the cash flow model is sorted out, consideration should be given to how the model is used and the following question.

 

Does the client understand the output from the Cash Flow Model?
Probably not in many cases, any more than the average client will understand all the implications and nuances of the Pension Transfer Report (or previously the TVAS) without clear, balanced and consistent explanation. That explanation should be presented in discussions with the client but should ALSO be documented in the Suitability Report. The output from some Cash Flow Models can be 30 or more pages long!

 

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

Our View

There are two areas of concern around cash flow models:

– are the assumptions realistic and compliant?

– how the output is used and how well does the client understand it?

These concerns are not just our opinion. It is public knowledge that the FCA has concerns about the use of cash flow models, specifically around assumptions and how well the client understands the output.

This view is easy to understand when a client can be faced with 5, 10, 15 or more different charts, based on optimistic and unrealistic assumptions, which are not viewer friendly or easy to understand and when there is no clear explanation from the adviser.

The first concern can be easily resolved by using the growth and charges figures from the KFI as indicated above.

Resolving the second concern is less straightforward. In many cases, it will be best to simply use the cash flow models in the background to the advice as support for the recommendation made but not presented in detail, or at all, with the client. If the output is to be presented to the client, advisers should ensure that the cash flow model output is explained clearly to the client and that the client is not faced with more charts than is really going to help the client to make an informed decision. Less is usually more!

Finally, we would mention that the KFI rate should also be mirrored in the Pension Transfer Report (PTR). The PTR providers will use the 5% maximum intermediate rate unless a lower rate is entered when creating the report. If the KFI indicates a lower rate is appropriate, that is what should be used in the PTR.

Action Required By You

  • Firms that use cash flow models should consider the concerns and recommended actions summarised here;
  • Ensure that any projections are compliant;
  • Consider how cash flow models are used – background support for the recommendation or actually presented to the client;
  • Ensure that the output from the model is clearly explained to the client;
  • For more information or assistance, contact your usual ATEB consultant or contact ATEB.

About the Author

Technical Manager - Often referred to as the Oracle or the Sage, Alistair has a wealth of financial services experience. He is our go-to Technical Manager and enjoys nothing more than a complicated conundrum. Feel free to test his renowned knowledge by getting in touch.

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