Short Introduction to the pension system in the Netherlands

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1 The right to retirement pension information (Madrid, July 2013) The Netherlands 1 Joyce van der Smitte Ministry of Social Affairs and Employment Short Introduction to the pension system in the Netherlands The Netherlands has an elaborate old age pension system strongly based on collectivity, solidarity. Supplementary pensions are fully funded. Total amount of assets of pension funds: more than 1 billion. In terms of adequacy the Dutch pension system provides good protection against poverty and with a high replacement rate helps older people to maintain their living standards after retirement. Main characteristics: collective risk sharing and the system of transfer of pension value. Supported by mandatory participation in industry-wide pension funds. Challenges: the effects of the financial crisis on the financial position of pension funds and of the participants; the sustainability of the supplementary pension system in relation to demographic change. Some features of the Dutch old age pension system The Netherlands has a three-pillar pension system. The two main pillars are the General Old Age Pensions (AOW, first pillar pension) and the supplementary pensions (second pillar pension): AOW: the government ensures that a lifelong basic income (not means tested) is provided to persons aged 65 and over. In addition to the state pension benefit a person may receive an occupational benefit from his or her employer(s). The general objective is promoting and protecting occupational pensions; besides it is aimed at stimulating employers and employees to make arrangements for a supplementary pension and to create a guarantee that a pension commitment by the employer to his employees will be honoured. From this general objective the following operational objectives are derived: increasing the sustainability and scope of the system of supplementary pensions. As many employees as possible should be given the opportunity to obtain a supplement to their AOW pension in a collective and co-operative 1 Prepared for the Peer Review in Social Protection and Social Inclusion programme coordinated by ÖSB Consulting, the Institute for Employment Studies (IES) and Applica, and funded by the European Commission. ÖSB Consulting,

2 manner, so that after retirement they are able to maintain their standard of living as good as possible. improving the involvement of participants in their pension provision. Participants must be encouraged to take note of their pension schemes and to be aware of how it functions in difficult times. Third pillar pensions are private pension provisions in addition to AOW and supplementary pension benefits and are benefits provided by an insurance company or bank. Guaranteed minimum income as regards (pension) income: minimum wage and first pillar pension (AOW) The first pillar pension entails a statutory guaranteed minimum pension income (AOW). The development of the amount of both the minimum wage and the AOW can be linked pursuant to the development of the wages in the collective labour agreements. The AOW accrual is related to (the duration of) being a resident: as long as one is a resident in the Netherlands or at any rate pays contributions for AOW in the Netherlands, rights to AOW are being accrued. People who go to live outside the Netherlands may buy in any missing AOW years or take out voluntary additional insurance after having left the Netherlands. Everyone who pays Dutch wage tax and/or income tax, who is not yet 65 or older pays the AOW contribution. This contribution income is used immediately to pay out AOW benefits. The contribution is withheld from the wages of employed people or from the benefits of those on welfare. A self-employed person pays the contribution through an assessment imposed on his or her income by the tax authorities. From 2013, the age of retirement will gradually be raised to 66 in 2018 en 67 in 2021, and will subsequently be linked to rises in life expectancy. Second pillar pension More than 91% of the employees accrue a supplementary pension in the second pillar on top of the AOW. Although the government is not primarily responsible for the supplementary pensions, its aim is for everybody to be able to accrue a supplementary pension. Together with the AOW the supplementary pension should be sufficient to keep the standard of living at a reasonable level on retirement. With this in mind, pensions should be financed on the basis of capital funding and the invested pension capital must be placed outside the company. There is also a prohibition on surrendering (subject to exceptions) and there should be a periodic payment (and not a lump sum). Apart from this, protective measures are applicable such as a prohibition on medical tests as well as a legal right to a value transfer, pension settlement after divorce, and equal treatment of men and women, full-time and part-time workers and retirees and deferred beneficiaries. The delayed taxation system applies to supplementary pensions, entailing that entitlements are tax-free and that the pension in payment is taxable. Nowadays, employees may save tax-free up until the actuarial value of an accrual of 2,25 per cent of their pensionable salary for their pensions. The basic principle is that one can accrue a pension of 70 per cent of the average-career income. In order to accomplish this pension outcome, one has to be employed for forty years by the same employer. 2

3 Benefit calculations Pension arrangements are made in many different ways. In the Netherlands, the basic agreement should be either a defined benefit (DB) plan, an agreement for the payment of a capital sum, or a defined contribution (DC) plan. In DB benefit plans, benefits are based on a formula linked to income before retirement (final pay plan) or on average earnings over the accrual period (career average plan) and length of employment. A DC benefit plan is a pension scheme by which benefits are based solely on the amount contributed to the plan by an employer or by the employee and any return on that investment. By reaching the pensionable age the total amount accrued will be converted into benefits or an annuity. The AOW pension benefit is included when calculating the occupational pension benefit. Current developments Because of the aging of the population the cost of pensions rise. Besides, the current system for old age pensions is receptive to fluctuations on financial markets. That is why the age of retirement gradually is raised and why the government will adjust the rules for pension funds and pension accrual. The first pillar retirement age will rise gradually to 66 in 2018 and afterwards to 67 in The age for supplementary second pillar pension accrual under favourable tax conditions will be 67 in 2014 (Witteveenkader). A pension fund must have minimum assets at its disposal. Its size must allow the scheme to meet its liabilities. An average pension fund has to keep such a financial buffer that its coverage ratio (the ratio between its assets and its pension liabilities) is approximately 130%. This is based on the norm that once every 40 years (a risk benchmark of 97.5%) a chance of under-funding is allowed. Because of the financial crisis the value of investments is reduced which caused a reduction in the coverage ratio of many pension funds. When the coverage ratio is less than 105 per cent pension funds have to decrease the pension accrual and benefits. The Financial Assessment Framework determines the financial requirements of pension funds. In order to better addressing the risks, the Financial Assessment Framework will be adjusted. All these plans will be further developed in acts and regulations and must be communicated with participants and retirees. Because any change in regulations with consequences for the pension benefit has to be communicated with participant and retiree. 3

4 1. Extent of the information on pension rights 1.1. Which actor(s) provide(s) pension communication (e.g. the government, insurance companies, pension funds, national pension authority, )? Is this pension information provided on a legal obligatory basis and/or on voluntary basis? The legal framework of occupational pensions consists of the Pensions Act (PW), the 2000 Mandatory Participation in an Industry-Wide Fund Act (Bpf 2000), the Mandatory Pension Act for Professional Groups (WVB) and the Equalisation of Pension Rights in the Event of the Divorce Act (WVPS). In the Pensions Act and the Pensions Act for Professional Groups contains a number of mandatory provisions on communication. The nature of the pension arrangements agreed between the employer and the employee must be established explicitly in the pension agreement. This employer has to fulfil a number of mandatory information duties. Because the employer is responsible for the communication about the pension scheme and important changes of the scheme. Also, the employer must be alert when important life events occur with consequences for the employee s pension situation. For fear of having insufficient knowledge about the pension scheme in order to inform the employee and to be responsible for the consequences, this appointed task is transferred to pension providers (e.g. pension funds and insurance providers). The information-related provisions of the Pensions Act became effective on 1 January These provisions are expected to boost pension awareness. This may be significant if people expect a deficit in their old-age income, wish to leave the labour market before the age of 65 or want to live abroad. They may then consciously buy additional pension products to compensate for insufficient old-age income or plan to retire at a different age. On joining the pension scheme, members must be adequately informed about the contents as well as the implementation of the pension scheme. These documents must clearly and understandably state the objectives of the pension fund and the rights of the scheme s members and beneficiaries. Material changes in these objectives or rights must be reported to them in a timely manner. For instance, within three months after the accrual of pension entitlements has started, the employee is entitled to information about the contents of the pension scheme ( starting letter ) from his or her employer. The employee must be informed by the employer or his/her pension provider about the accrual of the pension entitlements. This information must also show whether the pension scheme qualifies as a DB agreement, a DC agreement or a capital agreement. The implementation agreement to be formed must also include the information provided by the employer to the pension provider. The Dutch pension tracking service mijnpensioenoverzicht.nl, which is an initiative of the pension sector, must also be mentioned. This tracking system came into effect in With the introduction of the pension portal, people are able to view their accrued pension benefits online, including the benefit under the General Old Age Pensions Act (AOW). It is also important for objective and non-commercial information about pensions to be available. That is why the Dutch government has supported projects of the Pensioenkijker.nl foundation, in which the main stakeholders in the pension sector were participating. In 2012 Pensioenkijker.nl is incorporated in the pension portal mijnpensioenoverzicht.nl. 4

5 1.2. What is the content of the communication on pension rights (e.g. name, profession, employer, social security number, acquired rights, deferred rights, etc.)? Every year participants that contribute to a pension scheme receive a Uniform Pension Overview (UPO). This overview provides the necessary income details, such as: when one retires; in the event of disability; or what ones partner or children will receive in the event of death of the participant. All Dutch pension funds and insurers are using the same lay-out to inform their participants. This uniform standard of communication provides the necessary support to simplify ones future financial planning. The content of the Uniform Pension Overview is being reviewed What is the periodicity of the communication (e.g. annual, monthly, permanently available through the internet, )? The periodicity of communication depends on the event or document. The starting letter is communicated when the participant has joined the scheme. The Uniform Pension Overview is communicated every year before 1 October. It is still mandatory to send information on paper to the participant. But most pension providers are communicating with their participants through the internet as well. Finally, participants have the right to request for additional pension information about their pension regulations, the annual report, financial statements, pension agreements, relevant information about investments, about emigration to another EU country. The consequences of life events on the pension outcome and above mentioned general information is permanently available on the internet, often Is information general or specific (related to the recipient)? At the moment, pension communication is under discussion. The current reservoir of mandatory communication has to be bundled into a clear and consistent offer. The information in the starting letter has a general character, the information is supposed to be complete and as a consequence complex and hardly accessible for the recipient with slight knowledge of pension matters. A new starting letter with general information about the scheme is under construction. The focus will be on the information needs of the participant and not any longer on the completeness of information. This approach may contribute to the pension awareness of the participant that there are risks involved in his pension outcome. So, to make the information more attractive and accessible the information will be offered in communication-layers. The Uniform Pension Overview offers specific pension information related to the recipient and is offered by the pension provider of his current employer. Since 2011 the pension portal mijnpensioenoverzicht.nl shows people their accrued pension rights online, including the benefit under the General Old Age Pensions Act (AOW). This 5

6 tracking system is convenient in case people change from one pension fund to another or to an insurer and have different jars with pension savings. This pension portal shows with which pension fund or insurer the pension has been accrued, the amount of pension entitlements, the accrued AOW entitlements as well as links to more pension information. In the near future an expansion of the functionalities of this pension portal is intended and in the distant future the functionalities of this pension portal should be integrated in a financial planner How is the retirement pension in the communication calculated? Basic value of the pension contribution Occupational pension schemes are considered supplementary to the old-age state pension. This AOW benefit is therefore included when calculating the occupational pension benefit. AOW and occupational pension benefit together should amount to 70 percent of the average-career pay under the condition that the employee continues to be employed by the same employer. The part of the income over which no additional pension entitlements are accrued, because it is expected to be covered by the AOW, is known as the offset (franchise). The gross income less the offset is the basic value of pensionable earnings. Average contribution rate In the Dutch system of occupational pensions the contribution is a fixed percentage of gross income less the offset. Solidarity is being achieved by levying an average contribution: all members pay an equal percentage of their salary or an equal contribution to the pension provider that will invest this contribution until the retirement date. The average contribution rate is divided among all affiliated employers and is based on the average earnings or another criterion. So, there is no direct link between the annual contribution payments and the employee s pension accrual in a certain year. Besides, the determination of the contribution rate does not depend on age, sex, health and income. In DB agreements the benefits are linked to the earnings in the accrual period. If pension benefits are based on income before retirement then the pension scheme is a final pay plan. With every career step the pension entitlements will be raised to the level of the actual basic value of the pension benefit. If pension benefits are related to lifetime average earnings then the pension scheme is a career-average plan. In a career-average plan the pension rights are linked to the income in a specific year and are indexed to the general level of consumer prices in a subsequent year. Periodic indexation is generally not guaranteed and is a discretionary power of the pension fund board. Another possibility is a pension scheme with a combination of final pay and careeraverage elements. The basic principle is a benefit based on final pay, but having reached a certain age increases in income are not included any more in the future benefit. This levelling is called moderated final pay plan What parameters are established for this calculation? Due to the fact that most retirement benefits are Defined Benefits, the parameters that are being used for calculation of the benefits are: the offset and an accrual percentage. The defined benefits are mostly calculated as average pay. Personal information (such as salary and working hours) is then used to calculate the yearly accrual of benefits. 6

7 A little bit more than 10% of 2 nd pillar pensions is on the basis of Defined Contribution. Per DC pension plan the level of contributions is decided within fiscal limitations. Most of the times the contributions rise as age rises Which profitability ratios are used? This does not apply to DB plans. Within DC plans a 4% annual return is taken into account for calculating the benefits towards participants How are the estimations on the contributory bases calculated for future periods? For DB and DC plans at this moment no impact is taken into account for the increase of one s salary. For DC plans as explained in most of the time the contributions rise as the age rises. By doing this the annual accrued benefit stays the same for every year How are the future contributory bases updated? For DC plans the maximum contributory base is updated annually. This is updated by actuarial calculations. These depend on expected rates of return and the development of expected change of longevity How are the future contributory bases updated? The parameters for consumer price index are based on the annual figures that are being made available by the Central Bureau of Statistics (CBS) in the Netherlands. Other parameters like the expected annual rate of return and longevity are evaluated annually. In this evaluation the future expectations are taken into account. For longevity the CBS and the Dutch Actuarial Society make estimations. For the expected rate of return a separate committee is established to decide upon this Which entity/entities determine these parameters (e.g. consumers price index)? The parameters for consumer price index are based on the annual figures that are being made available by the Central Bureau of Statistics (CBS) in the Netherlands. Other parameters like the expected annual rate of return and longevity are evaluated annually. In this evaluation the future expectations are taken into account. For longevity the CBS and the Dutch Actuarial Society make estimations. For the expected rate of return a separate committee is established to decide upon this Are there any other hypotheses to be taken into account for the calculations? As explained in hypotheses of rate of return and longevity are being taken into account. Also important for the quality of the benefits is the probable development of price and wage inflation. This is important for the purchasing power of future retirement benefits in both DC and DB plans. 7

8 1.6. Are prospects, estimates, simulations, being made (e.g. information regarding benefits at an earlier or later age than the statutory retirement age)? Within 2 nd pillar these prospects are not prescribed by the government. The Pensions Act provides a couple of possibilities for the redistribution of retirement benefits. The possibilities are: early or postponed retirement, variation in the level of benefits, exchange of benefits between retirement benefits and survivor benefits If simulation is possible: What are the parameters? These parameters vary by pension plan. Every plan has it s own population and depending on this population the forecasts of longevity are being taken into account. The expected rate of return in these calculations is set on the expected risk free rate of return Who establishes these parameters? The risk free rate of return is decided upon by the financial markets but also due to a political process. As stated above the longevity forecasts are being established by the CBS and the Dutch Actuarial Society Can the receiver change the simulation by adjusting these parameters? The receiver is not able to change the simulation by adjusting the parameter For funded schemes: what assumptions are used with regard to the rate of return, the interest rate and the inflation? See the above answers. 2 nd pillar pensions in the Netherlands are all based on funded schemes. 1 st pillar is based on pay-as-you-go Are these assumptions communicated? The expected rate of return and the interest rate are not communicated towards participants as they are the same for all beneficiaries. The inflation as such is not communicated to the participants as well, but the expectation of the compensation for inflation (indexation based upon price or wage inflation) is indeed communicated to the participant Who determines these assumptions? These assumptions are based on regulations set by the Pensions Act. Following the inflation (indexation) is a choice made by social partners when they set up a pension plan. 8

9 Are these assumptions checked by the government? The Dutch Central Bank is supervising these regulations in the Pensions Act. This can be done by looking into regularly provided information by the pension provider (such as annual statements or other mandatory provided documents) or on special request by the supervisor Is the communication integrated (covers all possible pension schemes, irrespective of pillars or other elements)? If yes, is it also consolidated (information on public and private pension rights are communicated together)? The communication covers the state pension and the occupational pensions. The pension portal mijnpensioenoverzicht.nl covers the accrued AOW entitlements as well as the accrued supplementary pension entitlements. 2. Manner of the communication 2.1. By which means is the information provided to the citizen (e.g. by ordinary mail, internet website, , mobile phones )? At the moment it is mandatory to send the information on paper to the participant. But on account of a first stocktaking of pension communication needs of participants together with a number of recommendations sent to Parliament by the Minister of Social Affairs and Employment, pension providers are anticipating legislative changes by providing information by ordinary mail, internet websites, , mobile phone apps, etc. By means of a pension tracking system participants are able to look online into their accrued pension rights. The aim of this system is to be more transparent about individual pension rights. The Dutch tracking system covers the first and the second pillar only; third pillar pensions are not included, yet If the information is provided by using the internet, how is the user identified? Pension providers use different ways to get into contact with pension scheme participants and retired persons. They are gathering addresses in order to be able to forward customized pension information Is extra information or comment on pension rights provided (e.g. by call centre, invitations for personal communication, chat sessions with the pension institution )? Yes. Industry-wide pension funds, for example, communicate with participants by call centres, chat sessions, pension information meetings in schools, companies, pension markets. Every year there is a Pensioendriedaagse in October, three days on which the focus is on pensions. Pension providers, supervising authorities, advisors, employers organize pension consulting hours or lunches in order to inform people of their pension. 9

10 2.4. Is there any control whether the recipient has received and opened the message? This is not in the scope of the legislator. Pension funds and insurers are responsible for the communication and for its effectiveness Is the information provided on request of the person concerned or automatically by the Social Security System itself? In Holland the information about the AOW is provided automatically by the system as well as on request of the person concerned. Information on request about supplementary pensions is not provided by the Social Security System In which language(s) is the information available? Who establishes the language of the communication? On what grounds? The information about the AOW is available in English, French, German, Spanish, Polish and Turkish. The administration body for the AOW is the Social Insurance Bank (SVB) which is responsible for the communication with the recipients. The choice for the different languages is made on behalf of the number of retirees entitled to an AOW benefit residing abroad Are estimated amounts given in current or future value? Estimated amounts are given in current value Are absolute numbers or percentages used? Absolute numbers are used, because recipients do not like percentages Are numbers rounded (no figures after the comma)? Numbers are rounded Are visual effects used (e.g. charts, colours, drawings, )? In future, text in combination with infographics will be customary What is the assumed level of understanding of the recipient? The level of understanding in the Netherlands is recorded in the Common European Framework of reference for languages. The level is B1. If you have level B1 than you are able to carry on a conversation about daily topics like family or hobbies. 10

11 2.12. (How) is the financial (il)literacy of the recipient taken into account? Pension communication must be in the interest of the recipient. It is important that participants acquire understanding in the amount and the adequacy of their pension income so that they know whether or not it is necessary to take additional measures in order to maintain their way of living having reached their retirement age. Simple language and visual concepts are important in pension communication Is the communication layered (e.g. the older a person gets or the further one looks into a website, the more detailed the information )? In future communication will also be layered Is communication standardized (by various pension actors) relating to terminology, wording of the content, tables and/or graphs? (please specify) The yearly pension statement is standardized (Uniform Pension Overview) in order to sum up the different pension statements in the pension portal mijnpensioenoverzicht.nl, a pension tracking system that provides participants with an online overview of their accrued pension rights. 11

12 2.15. Is pension information centralized (retained in one single administration, body or database) and/or decentralized (e.g. cross-roads bank) The pension information in the pension portal mijnpensionoverzicht.nl is not centralized for safety reasons Is pension information embedded with other information (e.g. in general social security information, bank or insurance communication )? Pension funds and insurers write up the pension data of each individual participant in their schemes. On request of the person concerned they set up his pension statement information to be processed by the pension portal mijnpensioenoverzicht.nl. After consultation and being logged out of the pension portal, the personal pension data of the participant vanish from the tracking system. 3. Target group of the communication 3.1. To whom is the communication targeted? (e.g. active workers, self-employed, salaried workers, civil servants, deferred beneficiaries meaning so-called sleepers with dormant rights..)? Communication is targeted to active workers, salaried workers, civil servants, deferred beneficiaries and retirees From what age onwards do citizens receive the communication and how much time prior to the statutory retirement age is the information provided? In line with the directive portability of supplementary pension rights employees may join a pension scheme when they are 21 years. On joining the pension scheme the employee is entitled to information about the contents of the pension scheme ( starting letter ) from his employer within three months after the accrual of pension entitlements has started. Six months prior to the AOW retirement age the Social Insurance Bank sends the future retiree information about his AOW benefit What requirements must the citizens comply with in order to get the information (if any)? Citizens must be of have been resident in the Netherlands between the age of 15 and 65 years to get the information about the AOW benefit. 12

13 4. The legal value and authenticity of the communication 4.1. Does the current legislation provide a right to pension information (if so, how is it formulated)? On behalf of the Pensions Act the information and communication about pensions must be clear and understandable. Besides, the frequency of communication must rise in order to promote the pension awareness of the pension risks by participants. So, pension providers must inform every new member of the scheme by sending a starting letter. Other mandatory information is when a pension scheme is changed, the accrual of pension rights every year, the termination of the participation in the scheme, the start of the payment of the pension benefit What future legislation on pension communication is envisaged (if any)? Improving the sustainability of the supplementary pension system In the June 2010 Pension Accord, the employers federations and trade union federations, the so-called social partners forming the Labour Foundation [Stichting van de Arbeid], set out the adjustments necessary for occupational pensions in the second pillar, for which they bear particular responsibility. This Agreement also contains proposals regarding the future stability of the related state pension in the first pillar. The social partners believe that significant changes are necessary in order to safeguard the sustainability of the entire Dutch pension system. The two pillars of the Dutch pension system are coordinated and must remain compatible in the future. The proposals for the near future to have both the state pension and occupational pensions reflect the fact that the average Dutch citizen is living longer and to offer more flexible retirement ages in both pillars, and thus also with regard to the state pension will ensure this. The current pension contract is insufficiently shockproof against developments on the financial markets (interest, returns, inflation). As a result of demographic changes, the contributions measure has become increasingly ineffective in terms of absorbing financial setbacks. Pension expectations of current participants must reflect both demographic developments and the reality of the financial markets. In the Pension Accord the basic pinciples for a new, more transparant pension contract are set out. This will require a customized financial assessment framework which means that new schemes must be subject to ensure transparency about risks and communication. Communication The current legislation on communication provisions has been evaluated in The results show that the current communication efforts do not always have the effect hoped for. Mandatory information is not clear and comprehensible enough. Participants expect a higher pension income because they are not aware of the pension risks. Besides, a lot of information is verbalized in general terms, while the participant only wants to know how much pension he can expect. Finally, the evaluation shows that pension providers do not have the capacity to provide their participants with customized information. 13

14 The precarious economic situation and the intended structural adaptations of the Dutch pension system necessitate to communicate properly about pensions. By giving proper, empathic, significant and relevant information about the future of an individual pension and by creating tranquility and confidence for participants with clear communication What is the material and personal scope of the current and/or future legislation? The scope of future legislation is the interest and the need of the participant. The communication must accommodate his most important pension questions. Besides, the right to be informed by the internet will be regulated and the information must be clear (using infographics), relevant, offered in a logical and relevant sequence, at a relevant moment and be provided in communication-layers How are the necessary data provided to the authority/institution responsible for the information on pension rights? Every pension fund and insurer has individual ways to obtain the necessary data from the employer(s). Information about salary and employment is needed for the identification of the pension fund and to indicate the correct pension scheme, but also to be able to effectuate the calculation of pension entitlements and pension contributions, in a decent way. Besides, information about salary and employment is the basis for the provision of mandatory information (uniform pension overview, starting letter, stop letter) to the participant. The pension sector is making inquiries into the development of a uniform standard for the provision of salary and employment data by employers to their pension fund Who owns the pension data and who validates them? The basic principle of the Pensions Act is that social partners are primarily responsible for the occupational pension provisions. They jointly decide on the contents of the pension agreement. The employer is responsible for placing the pension contributions outside the company by joining an industry-wide fund, establishing a single-company fund or outsourcing the accrued pension assets to an insurance company. Finally, pension funds and insurers are responsible for drawing up pension scheme rules in accordance with the pension agreement and which complies with legal requirements. The pension fund and insurer are also responsible for the information provision to participants and beneficiaries. So, pension funds and insurers own the pension data. The Dutch Central Bank validates that pensions are duly paid into the account of the retiree, for instance, and The Authority for Financial Markets exercises market conduct supervision and validates pension information Is there a central database or not? And if so, is it solely responsible for the data? There is no central database on pensions Is the communication authenticated in one or the other way? Yes, by the Authority for Financial Markets. 14

15 4.8. Is the recipient of the information asked to verify the information? No In case of wrong communication, who is held responsible (e.g. the owner of the data and/or the provider of the data and/or the communicator)? The pension fund or insurer concerned Does the communication create a legitimate expectation whereby a possible beneficiary can have a claim against the pension provider (e.g. in case of a wrong prospect of simulation)? There is a lot of discussion about legitimate expectation with pension funds communication. For the characteristic of forecasts is that they are uncertain, questionable. And so the pension forecast will be. Pension providers are anxious to financial claims. But participants have indicated that they want to be informed about their future pension income What are the legal disclaimers used? Recover the loss by going to court How is the privacy of the recipients respected, in particular when the internet is used as communication channel? It is the responsibility of pension funds and insurers to respect the privacy of recipients when the internet is used as communication channel. But this aspect will be part of the new legislation. 5. Further information Is there any other relevant element which you think is necessary to understand the right of retirement pension information in your country that has not been dealt with by this questionnaire? Every day, pension funds have to demonstrate that their participants can rely on them, for pension funds have lost their authority. Over again, they have to learn how to communicate with their participants and retirees: expeditiously, properly, empathic, significant and relevant. Pension funds have to win the attention of participants who are active on social media: the student of 21 as well as the mother of 77. The confidence of people in financial institutions after the crisis is historically low. Pension funds have to look for other means and ways to communicate with their participants. The challenge is how to provoke people to amass knowledge of their pension in a situation that they, actually, are not receptive to information of this kind. 15

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