The Pacte law celebrated its 3rd anniversary. Among the key measures was the reform of retirement savings and the creation of the PER. A plan that is supposed to be more flexible, simpler and, above all, transportable from one financial institution to another over the life of the saver. Is the promise of full portability kept? Here are the obstacles which prevent the fluidity of the steps even which block certain transfers.
It has been almost 3 years since savers have been able to transfer and combine their retirement savings into a single product. A large part of the more than 4 million new PERs thus come from a transformation of old retirement savings plans, the Perp and other Madelin. But what about real transfers, from one bank to another, or from an insurer to a broker, which only represent a small part (less than one PER out of 10) of the number of retirement savings plans (PER ) open?
How to explain that these transfers supposed to be facilitated by the Pacte law are not more numerous? The explanations and obstacles are legion. Funds blocking or slowing down the transfer, fragmented information in the documents exchanged between competing managers, need to follow up several times to complete them, etc. Could the promise of complete portability of the PER ever really be fulfilled?
Transfer times that exceed the limit
If your broker announces a delay of between 3 and 5 months for the transfer of your retirement savings, this may seem like a lot to you. And yet, it’s not the worst! MoneyVox questioned about forty players on the transfers of retirement savings products to the new PERs. On condition of anonymity, some brokers, whether historical players or newcomers to retirement savings, announce transfer periods of up to 16 months.
The 4 months run from the receipt of a complete file. However, not everyone is connected to the documents necessary for a complete file.
Yet there are legal deadlines: 2 months maximum to transfer a PER from one actor to another, and up to 4 months (counting the customer waiver period) to migrate a old retirement savings product to a new PER. Solicited by MoneyVox, Bercy and the federation France Assureurs rightly emphasize the fact that there is already a legal deadline.
Another professional federation, the AFG, which represents asset managers in particular piloting retirement-oriented employee savings, is less police: Sometimes a period longer than this legal limit is justified because the 4 months run from receipt of a complete file, explains Alexis De Rozires, Vice-President of the AFG’s Employee Savings and Retirement Savings Commission. However, not everyone is connected to the documents necessary for a complete file. And the AFG adds: It seems necessary to supervise and strictly enforce deadlines.
PER: up to 1 year to transfer all your retirement savings!
Sometimes discouraging transfer fees
The Pacte law provides for the absence of transfer costs if the PER to be migrated is more than 5 years old. Otherwise the costs are limits 1% of accumulated savings. A framework that seems to satisfy everyone…
Except that this limitation of transfer costs is only valid for migrating a new PER to a competing insurer or manager. Do you want to transfer an individual product (Perp and Madelin) or a company retirement savings product (Perco, Corem, Prfon, etc.) to a PER? In this case you are only exempt from fees after 10 years of ownership. Before this chance, the transfer fees levied can be up to 5% of accumulated savings. A much more penalizing tariff, sufficient to cool the ardor of those who want to migrate their retirement savings… while waiting to pass this 10-year milestone.
Progress on other costs
Who charges the least management fees? What about remittance fees? It is not easy for savers to compare the fees of the various PERs available on the market. Bercy has signed a place agreement with all the producers of PER. As of June 1, a single table of costs will be published on the websites of insurers and other retirement savings (and life insurance) managers, standardized, simple, clear and readable by all, promised the Minister of Economy Bruno Le Maire.
Retirement savings plan: the costs that must be successfully compared
Funds that do not facilitate the transfer
Transferring your retirement savings amounts above all to transferring the tax envelope and therefore your tax benefits. The Pacte law theoretically allows assets to be transferred as they are… but, in practice, the media invested are they systematically sold before transferring the money. And the sale of certain funds slows down the process.
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This is the case of real estate funds (SCPI, SCI and OPCI), and more particularly SCPIs, according to the testimonies that the editorial staff has collected. They raise two concerns: on the one hand subscription fees (included in the starting price) that will have to be paid again; on the other hand they are often longer resell.
They are not the only ones. According to some off brokers, the presence of structured funds leads to a waiting position: you will have to wait for the scheduled maturity of the formulated fund to be able to transfer.
1 PER = 3 compartments: a slowing factor
If you collect all your retirement savings in a PER, it can then be made up of three compartments for payments according to their category: voluntary savings (payments in euros made by the holder), employee savings (incentive, participation and time savings account) and compulsory savings (based on employer or employee contributions in companies that have set up a mandatory retirement plan).
However, some insurers and managers do not yet offer all the compartments in their PER. And this mix of three compartments can lengthen the transfer time, the time to reinvest the sums from employee and compulsory savings into voluntary savings.
Retirement savings plan: these funds that block your transfer
Banks or insurers who compete with bad will
According to many concordant testimonies, some losing institutions show bad will when transferring retirement savings. The simplest of these techniques: using only paper mail when an email would accelerate the exchanges. Second technique, of the same ilk: Account holders not accepting requests for outgoing transfers by electronic signature without notifying their investors, laments Charlotte Thameur, consulting director at Yomoni. Some players are on the defensive and prefer to discourage the customer by complicating the process, confirms Alexis De Rozires, of the AFG. There are many obstacles: the non-acceptance of the electronic signature, the fact of favoring mail over email for exchanges, the fact of request confirmation of the transfer requestetc.
There are many obstacles: non-acceptance of the electronic signature, favoring mail, asking for confirmation…
Another testimony of bad will: the subject of newscast. According to Charlotte Thameur, consulting director at Yomoni, there is a real recurring subject around the newsletter (BI) that we also find during the transfer of PEA. What is this technical document for? It’s a bit like the identity card of the placement and it traces its history since its very first opening, explains Charlotte Thameur. If we invest the funds without this document we put ourselves outside the regulations. Between account keepers who turn a deaf ear, those mimicking misunderstanding or even erroneous BIs, it is a considerable time wasted for investors. These identity cards concern the banking PER, insurance, PERP or even Madelin.
In off, an ultimate sign of bad will appears: the disparities between the slips of transfer. However, as Bercy asserts, in order to facilitate transfers, the federations of professionals (France Assureurs, FBF, AFTI and AFG) have drawn up a transfer slip which is intended to be used for PER transfers. This attempt at harmonization has apparently not yet borne fruit: as several brokers testify, the formats are still different from one insurer to another. Some insurers manage their own technical and IT constraints and thus require additional information. Harmonization takes time…
Possible solutions?
To allow a better fluidity of transfer requests, the same solution comes up with insistence in the testimonies collected by MoneyVox: a market agreement between market players… or even a law or a regulatory text if the agreement is not sufficient. Even if they wished to remain anonymous, some wonder. If Bercy was able to establish a clear and defined process for banking mobility, why not do the same for retirement mobility? The procedures for investing are clear, the exit procedures should be just as much, complete Charlotte Thameur.
The Pacte law allowed the transfer but does not provide any details, except for the costs. It is a recent product and there is a need for an agreement between the actors, explains Lotfi Lahiba, head of salary savings and retirement at Gay Lussac Gestion. Off-the-record, some retirement savings specialists even mention the possibility of create APIs (as for the banking sector) for share the information of the famous bordereau for standardized exchanges.
It would be necessary as for the supervision of the costs of the PER that Bercy takes up the subject, with France Assureurs, the AFG and associations of savers, supports Alexis De Rozires, vice-president of the retirement savings commission of the AFG. Above all, the legislator should force the actors of retirement savings to commit to a common procedure. And demand a revaluation of late payment interest in the event of a deadline being exceeded.
Negotiations promise to be tough. This is evidenced by the response of the France Assureurs federation, which is not very optimistic about the outcome of the negotiations: A market agreement would presuppose a consensus between all the players, whether they are insurers but also distributors or asset managers, in order to standardize the all PER transfer procedures.
To understand the PER market and their transfershere you will find all our articles on the subject: