Opinion: The pensions crisis

The Department for Work and Pensions warns that many final salary schemes have already closed down and those that survive will be closed to new entrants within six years.

The average defined contribution pot – the pension now replacing the more generous final salary scheme – is £26,000. At current rates, this fund would buy a Joint life 50%, 3% escalation annuity of less than £1000 per year.

One in six people retiring this year have not saved into a private pension or accumulated other assets, so will see their salaries replaced with the state pension only.

To provide for a pension in retirement, reasonably proportionate with prior earnings, it is recommended that somewhere in the region of 16% of lifetime earnings should be invested over the course of a working life. Supermarket chain Morrisons, is introducing what is called a cash balance scheme into which employees and the employer contribute 16% of pay.

A cash balance scheme shares risk between the company and its employees. The company will guarantee the pension pot payable at retirement when members typically purchase an annuity.

The company will manage and underwrite the investment to produce a guaranteed fund upon retirement, delivering a predictable pension pot for its employees irrespective of fund performance. This is a significant improvement on the existing defined contribution plan that requires members to actively manage their investment funds.

Such a risk-sharing scheme could be mirrored across the board (in the public and private sector) and adopted as auto-enrolment is introduced. For SME’s and the public sector, the government is best placed to underwrite the investment fund through the National Employment Savings Trust (NEST) and to direct the investment of the pension fund assets.

There is no shortage of cash generating and socially beneficial investments to which NEST could apply its fund. The pension fund could source investments on a commercial basis in areas that are of strategic long-term significance to the British economy – whether that be long-term fixed rate mortgages; economic infrastructure development; nuclear power; green energy development or a National industrial investment bank.

Current institutional arrangements for the pension fund industry are not delivering for the great majority of retirees. Pension funds have seen precipitous declines in value, low or negative returns on investment, relatively high charges and derisory annuities.

A national cash balance pension scheme (with employee contributions supplemented by a combined tax and NI rate of 32%), generating guaranteed returns equivalent to a benchmark ten year gilt yield, would allow for a greater level of certainty in pension planning with the corollary of socially useful investments. Providing for a decent retirement income requires a reasonable basic state pension combined with private savings and longer working lives.

To engender the public trust needed to encourage pension savings, our institutional arrangements for pension provision in retirement need to be improved. Providing individuals a simple and safe option of a guaranteed pension pot at retirement, without the need to actively manage portfolio investments, could be a major step in the right direction.

* Joe Bourke is an accountant and university lecturer, Chair of ALTER, and Chair of Hounslow Liberal Democrats.

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32 Comments

  • Here’s the problem with pension provision in the UK: I’ve read your article twice and I still don’t understand a single word of it. It’s just a page of gobbledygook. And I’m speaking of someone who has a pension. In fact, I have three, because like most people I’ve changed jobs a couple of times in my career (and will probably do so many more times before I retire) and don’t really know what I’m supposed to do with each of them when that happens.

    So I just don’t do anything, and hope it all works out (or that I die before it matters), just like most people do.

  • @Ivan
    A Defined Benefit/Final Salary Scheme guarantees to pay a pension equivalent to some fraction of your final salary, with all investment risk falling on the employer.
    A Defined Contribution Scheme just defines the contributions that are made into the pension pot, with all investment risk associated with creating the pot and in purchasing an annuity falling on the individual employee.
    A Cash Balance Scheme, is effectively a Defined Contribution Scheme with a guaranteed pension pot. Here the employer takes on the investment risk associated with creating the defined pension pot, however, once matured the risks associated with purchasing annuities lie with the employee/pension holder.

    I can see benefits in this approach, although learning from the current defined benefits schemes, we need to ensure that growth guarantees are realistic and reasonable and determine what should be done with the surplus that is likely to arise in a well run scheme.

    A reason for such guarantees is that from history we know that many defined benefit schemes were in surplus in the 1980’s and so companies took pension holidays, which as we now know made the funds more exposed to changing investment returns. a second reason is given the evidence to-date, the (Coalition) government would link the NEST rate to their preferred long term gilt rate of 1%, rather than the market rate of around 4%, and adjust it further to suit Treasury policy…

    Yes a Cash Balanced Scheme has attractions, however, it won’t effect the structural change in the financial services sector that we need, to enable UK pension contributors to achieve the levels of returns our Dutch neighbours are achieving for the same level of contribution.

  • Richard Dean 23rd Apr '12 - 5:26pm

    I do sympathize with Ivan, and I thank Roland for clarifications.

    The Opinion reads like an ad for Ponzi scheme! The match between pensions savings and portfolios of long-term strategically important investments seems at first sight to be appropriate, but I wonder whether there are some hidden issues here? There’s certainly a skill involved in portfolio management, but existing pension funds are supposed to be specialists in those skills. Why would other companies, or governments, do better?

    If a private company guarantees a pot, someone somewhere is taking on the risk that returns on company investments won’t be enough to pay pots as they become due. Who? I suspect it’s the future shareholders, workers or customers, because if things do go wrong they will need to forego dividends, work harder or pay more to make up the shortfall. Some of these people will feel that the company has become riskier by making the guarantee, so they may require higher returns (dividends, wages, discounts) to compensate. Perhaps the advantage comes from the people who don’t realise they are taking on more risk, and so don’t charge for that service in this way.

    Guarentees cost money, so guaranteed pots will be smaller. The way to get a guarenteed return equivalent to 10-year gilts is to buy 10-year gilts. Almost eveything else is riskier, including stretegic and socially useful investments. If people want the chance of a higher return, they necessarily accept the risk that, sometimes, things will go wrong and they’ll get a lower return. And things _do_ sometimes go wrong – the present pension fund situation proves the point. In effect then, the proposal for the government to underwrite the scheme means that future taxpayers take on the risks – and will have to pay more tax if things go wrong.

    So maybe it’s the right way to go, but let’s understand our choices and let’s walk down the chosen roads with all our senses operating!

  • toryboysnevergrowup 23rd Apr '12 - 5:43pm

    What isn’t appreciated is that the corporate sector are in many cases being allowed to walk away from what used to be seen as a moral obligation to provide their employees with decent pensions – there are a lot of corporates out there (often backed by private equity) who have achieved a large reduction in their employee pension costs by switching out of final salary into defined contribution schemes, which will provide their employees with lower pensions and place the investment risk with the employees rather than the employers. This has been done behind a smoke screen of arguments about longer life expectancies, generous public sector pensions, pension costs not being sustainable, but the actaul result is that many corporates have managed to reduce their pension costs to lower levels than was previously the case and have in effect being able to shrug off their moral obligation to provide decent pensions to their employees.

    I’d like to see some legislation that would require companies not to reduce pension costs beneath the previous high water mark of their pension costs(and I mean ongoing costs ignoring pension holidays) – but what do we see in practice is a reduction in the tax rates on corporates, a large planned switch in the burden of taxation towards PAYE and VAT (just look at the projected figures for taxes) all at time when the corporate sector is enjoying a substantial surplus and the public sector has a matching deficit. It is pretty clear whose interests are paramount unde rthe current regime.

  • toryboysnevergrowup 23rd Apr '12 - 5:56pm

    @Richard Dean

    Of course guarantees involve someone taking on risk and having to bear the potential cost – but the argument is about who should bear that risk. Personally, I don’t think it should be employees who as a whole have little opprotunity to manage the risk especially when they become pensioners or get near to pensionable age. Given that the company concerned and the subsequent employers are the ones who benefit from the efforts of their predecessors I would argue that they are in a better position to do so, with the State then providing the safety net in the vent of failure – on the other hand we could have the little atomised world of the Tories where everyone has to fend for themselves with no rights or obligations. I’m somewhat surprised how the latter thinking is becoming more prevalent in what used to be the party of Beveridge.

  • Richard Dean 23rd Apr '12 - 6:05pm

    @toryboysnevergrowup … “with the State then providing the safety net in the event of failure ”

    So you want the future taxpayers to take on the risk – and pay higher taxes if and when things go wrong? Ok, that would be one choice, so what obligations are implied for the present government and the actions it needs to take to protect the future taxpayer?

  • Ivan,

    I am assuming that your three pensions are personal pension funds. You will receive 3 statements each year showing the current unit value of your funds and the projected(but not guaranteed) benefit payments that may be due at retirement.

    Your obligations are to select the investments for your pension fund based on your personal risk preference for growth in your portfolio versus security of your capital. There will be annual charges withdrawn from your pension fund, but it is highly unlikely that you will be able to figure out how much they are or what they are for.

    As you say, “I just don’t do anything, and hope it all works out (or that I die before it matters), just like most people do.”

    The alternative proposed in the article is a cash balance fund based on a guaranteed rate of interest each year. The pension fund managers make there money by investing the funds in shares and bonds, but pay you a fixed rate of interest on your pension pot, that accumulates each year. You know where you are and the expected size of your pension pot when you retire – regardless of whether the stock market is up or down or how opaque the charges for managing investments are.

  • Roland,

    “…UK pension contributors to achieve the levels of returns our Dutch neighbours are achieving for the same level of contribution.”

    As I understand it, most of the Dutch schemes are career average defined benefit schemes. They have been able to maintain returns by adjusting benefits as longgevity has grown and costs are equitably shared between sponsors and pension plan members.

    I believe that many of the schemes will need to reduce projected benefits to maintain equity between current pensioners and current contributors.

  • Richard,

    In a recent report, the IMF argues that life expectancy increases over the next few years will cause a £750bn pensions shortfall for the British government.

    By 2028, the pension age will rise to 67 for both men and women, and could even rise to 68 by 2046.

    Figures from the Office for National Statistics (ONS) forecast that females born in 2010 will live to an estimated 82.3 years, with males living until 78.2 years. This also dramatically increases for one in three children born in 2012, who are expected to live until their 100th birthday.

    The additional funding would need to be drawn from both public and private sector pensions, as private sector schemes have faltered recently. The report goes on to suggest that many of us are ill-equipped for a rise in life expectancy.

    “With the private sector ill-prepared for even the expected effects of ageing, it is not unreasonable to suppose that the financial burden of the unexpected increase in longevity will ultimately fall on the public sector,” it noted.

    It is urging the government to take measures to address the problem now, with higher contributions into pensions from companies and workers, as well as small payout sums upon retirement. In addition, it is calling for an increase in the retirement age. The IMF report went on to add that the proposals to link life expectancy and age should be implemented.

    Further figures from the ‘longevity risk’ report argue that the UK taxpayer will have to foot the bill for this deficit. By 2050, the nation could be steeped in £750bn worth of extra debt and this could make up 135% of GDP, a rise from current levels of 76%. The UK would need to increase GDP by 1-2% every year to 2050 if they were to reduce this debt.

    Taxpayers already guarantee these shortfalls in private final salary scheme pension funds. So you see, it is not a question of future taxpayers taking on risk – rather it is a question of managing and mitigating the very large risks that have already accumulated.

  • Richard Dean 23rd Apr '12 - 7:31pm

    Joe,

    Thanks. The IMF report certainly makes it clear that there are problems. But I think you are confusing risks with liabilities.

    The IMF are saying there will be an extra £750bn of liability by 2050, because of pensions that start accumulating now. What that suggests is that people coming in to the workforce now should start to expect to pay the kinds of pension contrbutions you suggest – totalling 16% of earnings. That will perhaps solve the liability problem in principle.

    Then there is the second, different question of how to manage the money in the meantime – this is where the risk comes in. Cash depreciates through inflation and is unproductive. Bonds and shares have different risks – some companies collapse so shares in them lose value.

    If a company such as Morisons guarantees a pot in 2050 in exchange for regular payments between now and then, then they are planning to invest those payments in something, and there is a risk that that something will underperform. If they do, then someone will have to make up the shortfall when the pots start becoming due, – perhaps shareholders, workers, or customers in the way I suggested, or the future taxpayer – so it is these people who hold the risk.

  • Richard,

    The IMF report is urging action now to avoid a pensions time-bomb IMF.

    “The extra costs would come from public sector pensions, the liabilities for which the Treasury recently calculated already stand at £1.13 trillion, and the state pension. Part of the increase would also come from the state having to rescue failed private sector schemes, which are equally unprepared for a small jump in life expectancy, the IMF added.
    Governments globally must address the potential crisis now, the IMF added, by raising retirement ages, demanding higher annual contributions or reducing payouts.”

    Large companies, like Morrisons, are able to carry the investment risk of cash balance pension schemes. Some years the company will make a gain, some years they will make a loss. The employees will not make large gains, but will be protected from losses on their pension funds.

    As regards SME’s, they cannot typically carry this kind of risk. The NEST can invest the funds for them (in the SME sector preferably) and pay a rate of interest that the government would pay on a ten year bond.

    Public sector pensions are paid from general taxation. To control the liabilities and ensure that cash flows are available to meet future pension liabilities it might be a good idea to start investing these contributions in cash generating investments – long-term fixed rate mortgages would be my preference.

    Ideally, we would move to a position where a part of NI contributions equivalent to accumulating State Pension liabilities become the primary source of savings for investment in state infrastructure. The cost to the taxpayer is no more than borrowing in the gilt market to fund the ongoing public sector borrowing requirement.

    National infrastructure investment approaching 500 billion is planned over the next decade.

  • The Government has taken on 39 billion pounds worth of pension liabilities from the Post Office in return for 26 billion pounds worth of assets, but the clever accountants in HM Treasury argue that this is good business because the liabilities will only accrue of the next 60 or so years, whereas the £26 billion can be pocketed immediately and thereby reduce the deficit. If this is such a good idea, why doesn’t the state take over the assets of all private sector schemes in return for accepting the liabilities. That way we’ll solve the we can deal with the pension crisis and the deficit at a stroke. We might even land up with pensions as good as the French and Germans.

  • toryboysnevergrowup 23rd Apr '12 - 10:48pm

    @RichardDean
    I think you ignore my main poin that the corporate sector should be made to take on more of the future burden for its own employees – at the present what is happening is that they are getting away with bearing less of the burden and pushing more of the burden onto the State and hence future tax payers. I also think you fail to recognise that in one form or the other that pensions rely on a covenant by current earners/taxpayers to support those drawing pensions who have made their contribution in the past – even those who have saved for their own individual pensions rely on their investments performing.

    I am not saying that there doesn’t have to be a sensible debate about the level of pensions that an economy can sustain (and to do so you would look at annual pension cost in relation to total GDP rather than the size of the pension liabilities) – but that is not really the debat e that is being had – it is more about how the cost is shared out and corporate trying to reduce their share – and put a greater burden on the tax payer.

  • Richard Dean 23rd Apr '12 - 10:50pm

    Joe,

    I recognize that the pension time-bomb needs attention. But that does not mean we have to say goodbye to clear thinking. Large companies have larger workforces and so will face larger pension-associated risks: their largeness does not make it easier for them to carry this larger risk. They will have larger debts in bad years and will have more people grabbing their profits in good ones.

    The way that risk is mitigated is by diversification, so that if some investment fails, it only affects part of a portfolio. In algebraic terms this uses the central limit theorem to reduce the standard deviation about a mean. This kind of mitigation requires largeness in the sene that you have to have enough funds to invest in many different ventures, chosen properly, and this is what pension funds are supposed to be expert in. This does not however protect against system-wide failure, such as a market or currency collapse.

    Maybe the NEST can do this investment too, but the returns you suggest are the lowest of all. Why should people prefer NEST rather than other investment organizations who might strive for higher returns?

    For pensioners and pension funds to get returns from national infrastructre investment, that infrastructure essentially has to be done by companies rather than the government. If I invest in a company building a toll road, I get my returns from the tolls the company eventually charges to road users. Are you suggesting that the government will pay the companies so that the population can use the roads, and the companies will then pay their investors including the pension funds? It certainly souds like a plan, but one with a lot of political ramifications .

  • toryboysnevergrowup 23rd Apr '12 - 10:54pm

    Joe Bourke

    Why do you think SMEs should be spared the cost of providing their employees with a decent pension in return for the contribution they make to the companies they work for – why the special pleading.

    Surely, if it is just because they are more susceptible to longevity risk they could pool and reduce that risk by getting together – rather than passing their responsibility onto the State and futrure tax payers??

  • Richard Dean 23rd Apr '12 - 11:11pm

    @toryboysnevergrowup. Sorry for ignoring your main point. But what does it mean to make the “corporate sector” take on more of the burden? The corporate sector is you and me, through the payments we make for things we buy and through the fact that our wages are less than what we are worth! That’s how the corporate sector gets its money . So making the corporate sector pay is just another way of making us all pay.

    I think you have identified the key point – today’s pensions are paid by today’s payers of tax and NI – not through investments. I think it’s always been that way. But an analogous issue will arise whatever scheme is developed. A pension fund’s income is initially positive because it has no pensions to pay. But as soon as the fund gets going and pensions start getting paid, the outgoings in the form of pots and annuities rises to match the income in the form of contributions of future pensioners.

    The essence of the pension time bomb is that the outgoings to pensioners will eventually outstrip the income from contributors still in work and saving. It’s what happens when a Ponzi scheme reaches its limit. This seems to be the reason why retirement ages are to be increased – frankly people who are old like me may not be as productive as young ones, but if we’re working then we’re not drawing money out of the Ponzi, so allowing it to survive.

  • Graham.

    I am not sure how taking responsibility for the post office pension fund deficit can be considered good business other than to provide for the transfer of the post office to private hands.

    It would be more prudent to maintain the post office pension fund private investments (other than gilts) to meet the future liabilities being assumed.

  • Richard,

    large companies have in the past operated final salary schemes. These are being phased out and replaced with defined contribution schemes. This transfers all the investment risk to employees and these schemes have proven very volatile, making retirement planning difficult. The article argues that a cash balance pension scheme is a more appropriate hybrid method of sharing the risk for all – Large companies, SME’s and public sector pensions.

    Large company pension funds will appoint there own pension fund trustees and investment managers.

    The state can perform this function for SME’ through NEST. The option of selecting your own portfolio investment funds remains for those who prefer to actively manage their pension funds. For those that prefer the safety and security of guaranteed returns – the cash balance scheme should be made available.

    National Infrastructure investment is typically financed by issue of government bonds. The Interest payable on the bonds held by the pension fund is income to the fund. It has been recently floated that new road building and toll roads may be financed by hypothecation of part of the Road Fund Tax – this may be possible financing structure for other types of economic infrastructure.

  • toryboysnevergrowup,

    SME’s are eligible to enroll their employees in NEST as pension auto-enrollment begins. Currently NEST offers a selection of investment funds in the same way as private pension fund providers do.

    The cost to the SME of employer pension contributions is unchanged by NEST offering a cash balance scheme. The cost of borrowing from the public/private sector to the state is unchanged. The only change is that employees, if they so choose, are relieved of the need to take investment risks with their pension fund and can select a more secure guaranteed cash balance scheme.

    Larger companies can choose to invest in ten year gilts if they choose to take no investment risk themselves. Alternatively, they can manage the funds more aggressively, accepting the gains and losses that may arise from year to year based on their investment performance.

  • Richard Dean 24th Apr '12 - 12:43am

    Ok, Joe, was I almost right first time – this Opinion is essentially an ad for NEST?

    NEST will presumably compete with other organizations offering pension services? It does have a nice website http://www.nestpensions.org.uk/schemeweb/NestWeb/public/whatIsNEST/contents/what-is-nest.html

  • Richard,

    Nest already exists and is available to all employers. The opinion argues for the wider introduction of cash balance pension schemes in the UK – along the lines of the Morrison scheme.

    In a cash balance type of money purchase scheme, the investment risk before benefits are claimed is borne by the employer. Any shortfall on promised ‘pots’ are made up the employer. The rate of return promised by employers may be based on gilt yields, inflation + real rate of return, earnings growth index or any other measure deemed appropriate. The point is that the employee can know with a good degree of certaintity what the pension pot will be at retirement.

    In some large schemes, the scheme may also promise the terms on which the ‘pot’ is converted into a pension. In this situation, the employer is taking on the investment risk after the pension starts and the risk that pensioners will live longer than the schemes advisers have assumed in setting these terms.

    The fact that the growth of the pot is ‘promised’ means that the pot based upon that return must be made available to provide benefits irrespective of the value of the actual funds held by the scheme.

  • Richard Dean 24th Apr '12 - 2:10am

    Joe, Ok, “borne by the employer” means the investment risk is borne by some combination of future shareholders, workers, and customers, and taxpayers if the government plans to step in if things go wrong. The price the employee pays, for the certainty of knowing what the pot will be, is a smaller pot for a given level of contributions. Some people will prefer that, yes, and some people might prefer and alternative – to go for a bigger promised pot but accept the risk that the actual pot may end up smaller.

  • @Joe Bourke Apr 23 – 6:41 pm
    >Ivan,
    >I am assuming that your three pensions are personal pension funds.

    My reading of Ivan’s post was that he had swapped jobs several times and as a result has gathered several employer funded pension schemes; which could be a mix of final salary and defined contribution/”money purchase” schemes along with contracted in/out arrangements. So working out his potential pension could be and whether it could be improved will probably be a little involved – something an independent pensions advisor would do for a fee; however for many it will be easier to just leave the paperwork in the draw until retirement …

  • “Larger companies can choose to invest in ten year gilts if they choose to take no investment risk themselves. ”
    Unfortunately, the low yields on gilts is already having an adverse impact on pension fund funding levels and performance; just try costing out a final salary scheme where the investment grows at 1% pa and the salary grows at 3% pa and you will soon see why companies can’t close them quick enough…

  • Richard,

    the pension benefits that employers offer is there own choice (based on their evaluatiin of the compensation required to attract talent) not the governments. What I would like to see is the NEST scheme offering the option of servicing cash balanced schemes for SME’s and a move towards these schemes for public sector pension provision.

    Ultimately, as you say, it will be a matter of personal choice as to whether such schemes are favoured by individual pension savers and that will, in part, depend on how attractive employers choose to make the guaranteed benefits as compared with the more risky defined contribution schemes.

    Yesterday there was a work and pensions question fron Julian Hubbert MP, concerning the possibility of pension funds investing in the Cambridge retro-fit project. The pension minister, Steve Webb advised that NEST will have an ethical investment fund that could be a source for such projects. So as regards investment of pension funds in socially useful projects, It seems that some of our MP’s are ahead of us on this.

  • Roland,

    a cash balance scheme based on current short-term gilt yields would provide a below inflation return on pension fund investments , althoug longer term gilt yields are better and will hopefully improve as the econony recovers.

    It would be good to see employers introducing cash balance schemes along the lines of the state pension triple lock i.e. a guaranteed return to employees of the higher of CPI inflation, earnings growth or 2.5% in any given year.

  • Richard Dean 24th Apr '12 - 1:50pm

    The Cambridge retro-fit project is going to make a profit?

  • @Joe Bourke
    “he pension benefits that employers offer is there own choice (based on their evaluatiin of the compensation required to attract talent) not the governments.”

    Not really true. I run an SME and would love to be able to make a judgment on pensions in this way. The truth is that, in line with most private businesses, we have to cut our cloth according to the reducing margins in the economic climate. Private business have not been able to compete in pension terms for a long time. Anything that requires more investment will require a reduction in expenditure elsewhere, typically meaning a reduction in staffing. Only the largest employers can think about offering final salary, or even cash balance schemes in line with your comment above.

    I value the people who work for me and provide as good a remuneration package as possible. The reality is that we have seen margins tighten every year since 2007 and any further expense (or risk) associated with employment will lead to us cutting staff in an already high unemployment area. This will not be a matter of choice, and certainly will not be greed, it will simply be a necessity to protect the remaining positions.

  • It’s a good question Richard.

    I assume the return to investors will come from a share of the savings on energy costs made by building owners. Looks like an interesting idea.

  • I hear what you are saying Steve.

    I think most SME’s provide access to a stakeholder pension now. When auto-enrolment begins for smaller employers in 2015 (or later) there will be an element of employers contribution.

    Whether there is any additional cost/risk to an SME employer in choosing a cash balance scheme over a defined contribution scheme comes down to whether any investment risk is assumed. If the scheme provides a return based on ten year gilts and the pension fund invests solely in gilts then no investment risk should be incurred. The investment return to the employee is low but secure and it is easy for them to see how the fund is growing each year. It has the benefit of avoiding the volatility associated with funds investing primarily in the stock market. On the downside, employees are foregoing the potential greater growth availble with equity investments.

  • Happy to see we have a Pensions Minister giving this some serious thought:

    From Mark Pack Newsletter:

    Liberal Democrat MP and Minister for Pensions Steve Webb has revealed that the government is looking at a new “defined ambition” style of pensions, which would offer a better balance of risk between employer and employee.

    Currently, money purchase schemes put the risk on the employee (poor investment returns or a market crash means they get a lower pension) and final salary schemes, quickly going out of fashion, put the risk on the employer (poor investment returns or a market crash means they have to put more money in).

    Instead, Webb is talking of a new type of scheme where the size of the cash pot on retirement is guaranteed, but the size of pension that it then purchases is not, so splitting the risks:

    Firms would like to offer their employees some sort of certainty but without all the costs and burden they already face.

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