copy the linklink copied!Chapter 8. Trust and confidence in the pension system

This chapter addresses the pervading lack of trust and confidence in the pension system. It concludes that low levels of understanding of the system and a mistrust of the institutions managing the system are at fault. Policy options discussed to improve understanding and trust include measures to increase financial education, to better align the accountability of both the private and public institutions with their responsibilities and to have an integrated regulation and supervision of the entire system.

    

In order for the Peruvian pension system to be able to meet its objectives of providing income in retirement for the Peruvian people, the population needs to have confidence that the system will deliver for them and trust that they will be treated fairly by the institutions running the system. The pervading lack of trust in the pension system seems to have two main drivers. First, that the population does not fully understand how the pension system works and how contributing to the system will benefit them financially in old age. Second, there is a perception that the institutions involved do not have their best interests at heart. This lack of trust is directed at both public and private institutions alike.

More needs to be done to improve the population’s understanding of the pension system and demonstrate that there are appropriate controls in place, for both the public and the private institutions, to ensure that people will benefit from contributing to the system.

Furthermore, there needs to be assurance that the reforms implemented will maintain the long-term objective of achieving an improved pension system and not be swayed by short-term political pressures.

copy the linklink copied!8.1. Measures to improve the understanding of the pension system

The regulators and financial institutions have made numerous efforts to increase the public’s awareness and understanding of how the pension system works and the benefits that they will receive. Financial education is taught in schools, and the private sector and regulator have collaborated to develop educational programmes specific to pensions. Communication to members about their account and pension benefits has been simplified to facilitate understanding, and members have access to tools to show what benefits they can expect from the system. Access to services has also been facilitated for more remote regions to promote and improve access to the pension system.

Nevertheless, despite these efforts, the public’s understanding of the pension system remains low and members are eager to exit the system as soon as possible rather than maximise the benefits they can receive.

8.1.1. Financial education efforts

Financial education has been incorporated into the national educational curriculum since 2009. The SBS along with the Ministry of Education have developed support for teachers and training programmes to rely on in their educational efforts (OECD, 2017[1]).

Specific to pensions, the government has created an Education Fund for the Private Pension System (FESIP) in order to promote higher levels of pension knowledge through the financing of educational projects about pensions. The resources of the FESIP are provided by donations from the AFPs and the insurance companies, as well as from the fines charged in relation to sanctions.

The FESIP oversees the Council for Citizen Participation in Social Security (COPAC), whose objective is to promote the participation of affiliates to the SPP in the educational efforts of the FESIP. The COPAC will provide a forum to centralise proposals by citizens on how to improve the SPP, in particular how to improve education and knowledge of pensions.

8.1.2. Communication on the pension system, pension accounts, and benefits

Ensuring that communication about the pension system and the options that individuals have are simple and easily understandable is crucial for the success of the system. Financial education is important, but it cannot be relied upon alone to achieve the best outcomes for individuals in the pension system.

Regulation imposes requirements on AFPs to try to ensure that communication with affiliates is both comprehensive and effective. In general, communication with members should be done with the objectives of improving the information and guidance provided, ensuring that staff has the adequate knowledge to communicate accurately and effectively and to prevent conflicts between members and AFPs or insurance companies.

AFPs must have information sheets available in their branches and on their website that provide members information on the investment funds offered. These must contain information on the administrator, the responsibility of the AFP, the administrative structure, the main shareholders, a description of the investment process, the commission structure for the funds, the AFP’s financial information, enquiry and complaints handling processes, and supervision and internal control policies. Specific information for each type of fund must also be provided, including the investment objective, the target demographic, the investment policy and profitability, financial information, historical performance, and the rights of the affiliate.

In order to facilitate meeting regulatory requirements, the SBS provides templates for specific communications such as for the contract of affiliation and communication on contributions. In most cases the AFP is not required to use this exact template, but they are required to provide the minimum level of information it contains, namely the type of fund in which contributions are invested, the total contributions accumulated, the total withdrawals from the account, the accumulated net returns, the commissions charged, and the balance of the individual’s account.

All AFPs offer a pension simulation tool on their website for affiliates to estimate the amount of pension they can expect given a certain amount and number of contributions. The methodology used by these tools is subject to the approval of the SBS, and all providers must provide the same default scenario.

When affiliates reach retirement, the AFP is required to provide a consultation meeting to inform them of their benefit options and provide the insurance companies’ quotations from MELER. The SBS establishes minimum standards with respect to the information that the AFP is required to provide to the affiliate. As proof that this meeting successfully occurred, the AFP must issue a certificate stating that the affiliate has obtained all of the necessary information regarding the options available to them and the implications of their benefit decision.

In September 2017, the SBS established new requirements for the pension benefit statements that intend to simplify the information provided, improve its transparency, and increase members’ engagement with their accounts. The AFPs can develop their own templates for communication that the SBS approves if they follow seven principles:

  • Simplicity - promote simplicity and clarity in pension and benefit communication

  • Opportunity - provide information at the correct time for the individuals to use it to make decisions regarding their pension benefits

  • Objectivity - provide accurate and objective information regarding the conditions under which pension benefits can be accessed

  • Security - provide information on the correct process to follow to obtain pension benefits

  • Traceability – implement a set of measures, actions, and procedures to register, identify and validate each stage in the process to obtain pension benefits

  • Accessibility – make the process to obtain benefits easy for the affiliate to follow

  • Service orientation – Provide pension benefits in framework that focuses on customer service

In order to reach geographic areas that do not have physical agencies, the AFPs can set up public information offices called Pension Advice Offices (OAPs). The OAPs are allowed to provide information and guidance to affiliates regarding their account and expected benefits, open new accounts, initiate benefit claiming procedures, issue official documents relating to accounts, update personal data and notification preferences, and carry out transactions.

For more remote regions, AFPs can send Mobile Offices (PM) that are able to provide the same services as OAPs, apart from the submission of requests for the affiliate’s Private Security Code and initiating the process to claim pension benefits.

copy the linklink copied!8.2. Trust and confidence in the institutions of the pension system

Individuals demonstrate low levels of trust in both the public and private institutions of the pension system that leads to a reluctance to participate in the pension system. Complaints about private institutions are particularly high with regard to the AFPs, and centre around efforts to get their money out of the system.

Peruvians do not have confidence in the public institutions involved in the pension system either. The regulator does not always enforce corrective measures for valid complaints, individuals can contribute regularly to the public system yet not receive any benefit if they have not contributed for 20 years, and examples of neighbouring countries show how the ownership of money within the pension system can be quickly changed through policy reversals.

This lack of trust leads members to take their money out of the system as soon as they can, and a preference to keep their money outside of the system even when saving for retirement.

8.2.1. Reasons for dissatisfaction with the financial institutions of the SPP

Complaints provide insight into what aspects of the pension system are causing consumers the most problems. SBS is responsible for resolving consumer disputes relating to AFPs, insurance companies, or products or services relating to the SPP. The SBS may impose precautionary measures to protect consumers as well as apply complementary corrective measures detailed in the Consumer Protection Code of the Law No. 29571. For the pay-out phase, the SBS is only responsible for complaints related to the interpretation of regulation, procedures or payments within the SPP.

Table 8.1 shows that the number of complaints has fallen from 2015 as a result of clearer requirements to make communications with individuals more simple and transparent and the enforcement of those requirements. The number of days to resolve disputes also reduced in 2017 due to procedural simplifications and improved claims handling process.

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Table 8.1. Complaints received relating to the SPP

 

2015

2016

2017

Number of complaints received

562

347

404

Days to resolve

91

106

52

Source: SBS.

The main reasons for complaints in 2015 and 2016 related to the process of transferring pension assets outside of the country for citizens not residing in Peru. Since 2017, complaints have also centred around the withdrawals of the lump-sum and reimbursement of contributions due to terminal illness or cancer. Since 2016, only 11% of claims were determined to be justified, and the SBS ordered corrective measures to be taken for 41% of these cases.

The complaints received in 2017 are broken down by financial institution in Table 8.2. 96.4% of these complaints related to AFPs, and only 3.6% related to insurance companies. This is reflective of the fact that only a minority of affiliates transfer their assets to an insurance company, and for those that do so the AFP remains the intermediary between the pensioner and the insurance company.

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Table 8.2. Complaints by financial institution, 2017

 

Number of claims

Proportion of total

Integra

138

37.5%

Profuturo

124

33.7%

Prima

87

23.6%

Habitat

6

1.6%

Interseguro

3

0.8%

Mapfre Peru

3

0.8%

Pacifico

2

0.5%

Rimac Seguro

2

0.5%

Seguoros Sura

2

0.5%

La Positiva

1

0.3%

Source: SBS.

The complaints data clearly show that consumers are caring most about the process to get their money out of the system, and that they blame the AFPs for the faults of the system. This observation indicates a low level of trust in the pension system, and in particular, though perhaps disproportionally, the AFPs.

8.2.2. Low levels of trust in public institutions

Anecdotal evidence of the reasons for the mass exodus of funds from the SPP through lump-sum withdrawals and early retirement points to a lack of trust that the pension system will deliver on its stated objectives. Procedural problems, such as disappearing contributions and waiting times to receive Recognition Bond payments, add to the disillusionment with the system and the belief that the system will not preserve members’ savings and pay the benefits to which they are entitled. On top of this, examples in other Latin American countries such as Argentina, who renationalised private pension savings, demonstrate that their savings in the system are not necessarily theirs and can be taken by the government at will. At the same time, many individuals contributing to the SNP will not achieve 20 years of contributions, and so will never receive any pension at all, adding to the sentiment that their contributions to the pension system will not result in a pension.

This low level of trust likely drives the observation that 44% of Peruvians who are saving for their old age choose to do so outside of the formal pension system, and 67% of those who do contribute to the system do so only because it is mandatory (SBS, 2018[2]).

copy the linklink copied!8.3. Governance and supervision

The legally imposed framework for corporate governance in Peru aims to promote transparency, independence, and competence. It stipulates the requirements and responsibilities of the board of directors and CEOs, addresses conflicts of interest, and requires the financial institutions of the pension system to act in the best interests of members.

The SBS is independent and has regulatory, supervisory and sanctioning powers with respect to pensions, but these powers could be strengthened. Furthermore, given the split of the system between the public and private pension systems, the scope of its responsibility remains limited.

8.3.1. Corporate Governance

The legally imposed framework for corporate governance establishes a list of requirements for financial institutions that intend to guarantee the moral and economic solvency of the responsible organizers, shareholders, directors, managers and senior managers and the conditions to assure transparency of corporate actions and to eliminate potential conflicts of interest.1

The board of directors and the CEO are responsible for ensuring that banks, insurance companies and AFPs implement best practices around corporate governance.2 At least two members of the board of the AFP must be independent. The governance principles that the board should enforce include the establishment of internal policies to support good governance, the review of the external audit process, and transparency around conflicts of interest, in particular the relationship that directors have with the AFP.

The independent directors will be required to issue an annual report to the Council for Citizen Participation in Social Security (COPAC) that details the work that they have done in the AFP in which they serve as directors, that contains, at a minimum:

  • An opinion on the level of compliance with the policy and rules of transparency of the information provided by the AFP;

  • Mechanisms implemented to ensure the transparency of the engagement and communication with affiliates;

  • Evaluation of the proposals by the COPAC, as well as the level of implementation of the suggestions and/or citizen proposals generated in the COPAC;

  • Opinion on the level of compliance with good corporate governance in the AFP, in accordance with the law;

  • Acknowledgement of the sanctions imposed on the AFP for infractions relating to the transparency of information, as well as the proposed or implemented measures to address the problem;

  • Other issues that are considered relevant for compliance with the requirements around transparency.

AFPs have full fiduciary responsibility to the affiliates in their objective as institutional investors to provide adequate resources to finance retirement, disability and survivor pensions.

The SBS has the power to sanction infringements, according to the severity, without prejudice to applying civil and penal sanctions in accordance with the General Companies Law (Ley General de Sociedades).3

Depending on the severity of noncompliance, fines, temporary or permanent suspensions, removal and even disqualification of directors and managers will be imposed.4 The Directors or managers that have been disqualified or removed cannot be organizers, responsible organizers, shareholders, directors or managers of any supervised institution during the period indicated in the Sanctioning Regulation. In the case of recurrence, disqualification becomes permanent.

8.3.2. Supervision of the SPP

The SBS exercises control over banking and insurance companies, private pension fund managers and other companies that receive deposits from the public or perform related operations. It was created by law as a decentralized public institution of the Economy and Finance sector, following internal public law and with functional, administrative and financial autonomy. The Superintendent is appointed by the President for a term of five years. SBS is financed through contributions from the AFP that are based on the amount of assets under management as well as other voluntary donations from non-supervised entities.

The law establishes the organisational and functional autonomy of the SBS and contains its objectives and powers. In particular, the SBS has the power to approve or amend the necessary regulation for the financial and insurance operations and complementary services of these companies’ activities and to supervise these entities and enforce compliance with the regulation. As such, the SBS has regulatory, inspection, control, and sanctioning powers.

The SBS is in the process of transitioning towards risk-based supervision (RBS) of AFPs following international guidelines (e.g. the IOPS Toolkit for Risk-based Pensions Supervisors). They expect to finish developing their methodology by the end of 2020. The RBS framework seeks to address the following issues relating to the investment supervision process: 1) supervision of the investment regime; 2) on and off-site review process; and 3) aligning supervision and sanctions with the RBS matrix.

The RBS framework aims to control investment risk while allowing for some flexibility of the investment regime. In order to achieve this, the SBS has expanded the allowable investment in alternative assets. It has transferred the registration process for traditional investments to investment managers and established a general authorization process for non-traditional investments such as derivatives and alternatives, replacing the evaluation process for each individual investment. At the same time, it has strengthened the requirements for the management of investment risk, and investment managers have been allowed to implement a wider range of tools to manage the volatility of the funds through the investment in derivatives for the purpose of hedging portfolios and efficient portfolio management.

In order to classify the on-site or off-site review of processes as relevant or critical, the SBS has established criteria relating to the evaluation of the investment decision, the risk control system, the performance measurement methodology and the process of recording the information in the Daily Investment Report. The SBS makes the decision to conduct on-site and off-site reviews according to the priorities based on the results obtained in the quantitative and qualitative indicators of management monitoring of investments and risks of the AFPs. In order to detect weaknesses in the investment process in a timely and accurate way, the supervisors rely on both daily and periodic information.

The RBS matrix, when completed, will allow the supervisor to concentrate only on the relevant activities and better align the supervision processes and sanctions imposed by the SBS within the RBS framework.

For the pay-out phase, the supervisor evaluates all risks taken by the AFP and how they are managed in order to assess the inherent risk. If needed, the supervisor asks the AFP to implement risk mitigating actions in order to assess the residual risk. Depending on the level of residual risk, the supervisor may require the process owner, the COO, internal audit, or the CEO to initiate a period of self-control.

An additional body that plays an important role in ensuring employer participation in the pension system is the Superintendencia Nacional de Fiscalizacion Laboral (SUNAFIL). SUNAFIL is responsible for ensuring employers’ compliance with labour laws and regulations, including pensions.

copy the linklink copied!8.4. Policy options

Unless actions are taken to improve the Peruvians’ understanding of the pension system and their trust in the institutions managing it, the pension system will fail to meet its objectives to provide pensions for the majority of the people. To improve understanding, financial education about the pension system needs to be broadened. To improve trust in the private institutions, a centralised public-private platform that manages administrative processes should take the place of the AFPs as the face and contact point of the system. The corporate governance framework should adequately address any conflicts of interest, and consumer interests should be more represented in decisions on how the AFPs are being managed. To improve confidence in the public institutions, members who have had contributions misdirected need to be made whole and regulation and supervision should be integrated across all components of the pension system.

8.4.1. Promote financial literacy and education about the pension system

Efforts to educate the public about the pension system and help them to understand how to benefit from it are moving in the right direction. The creation of the FESIP will contribute to furthering educational efforts, and the simplification of communication will help to make the aspects of the system easier to understand.

However, despite efforts to promote knowledge of the pension system, more than one in four people expect that they will be able to rely on Pensión 65 as their primary source of income in retirement. This compares to only 15% of the population that expects that the main source of income will be from either the SNP or the SPP (SBS, 2018[2]). Therefore, the role of Pensión 65 to provide a very low benefit to alleviate poverty for the most disadvantaged of the population is clearly not understood by a large proportion of the population.

Education on the pension system needs to be incorporated into the financial education programmes in schools in order to promote saving for retirement from a young age, and to help students understand how the pension system can help individuals achieve their financial goals for retirement. Programmes should teach students how the different components of the pension system work together to provide a retirement income. Currently, 48% of 15 year olds in Peru perform at the lowest level in financial literacy, which is below the baseline level of proficiency that is required to participate in society. This compares to the OECD average of 22% of students functioning at this level. Students in low socioeconomic groups are more than twice as likely as advantaged students to perform at Level 1 when controlling for other variables (OECD, 2017[1]).

The dissemination of information relating to the pension system could also be done through public awareness campaigns to educate the general public about the system. The OECD Recommendation on Good Practices for Financial Education Relating to Private Pensions recommends that campaigns should “explain public policy clearly (particularly where mandatory savings are involved), including pension reform, the pension environment, increase individual responsibility, and demographic changes that require individuals to save more.” (OECD, 2008[3]). These campaigns should be designed with the collaboration of the SBS and key stakeholders such as the Asociación de AFP (AAFP) and the Consumer Association (ASPEC), and delivered in a way that will reach a large portion of the population, such as through radio programmes. Specific campaigns could also target more vulnerable populations, such as informal workers or women in order to tailor the messages more effectively to these different population segments (OECD, 2014[4]). Public sentiment indicates that such information could be effective in getting people to save for retirement by reminding them of the importance of saving and how the pension system can help them to do so. Indeed, 71% of Peruvians think that it is very important to save for old age but 62% of people do nothing about it. Of those who do nothing, 22% have no particular reason for not saving, implying that there is an opportunity to get these people to save more (SBS, 2018[2]).

In order to be most effective, programmes should also target specific populations, for example informal workers. Informal workers are much less likely to take any steps to financially prepare for old age (Arellano marketing, 2017[5]).

8.4.2. Improve confidence in the private financial institutions of the SPP

AFPs seem to be the most dis-trusted institution of the SPP, and indeed were the target of the highest level of complaints compared to insurance companies. This is partly driven by the fact that AFPs have the responsibility of acting as the intermediary for the affiliate for every interaction they have with the pension system, even where they are not the main actors in the process. In addition to fulfilling their role as investment managers for the contributions paid into the system, AFPs are responsible for ensuring that the employer is paying the employee’s contributions, for the application process to receive Recognition Bonds from the ONP, and for the benefit payments paid by the insurance companies.

Public perceptions of the AFPs are that they will lose the public’s money and that there are no protections in place for consumers. Nevertheless, only 0.3% of people report having had a problem with an AFP in the last year, and when they do it is often related to returns on contributions or to the receipt of recognition bonds (Arellano marketing, 2017[5]). These complaints therefore seem misplaced, as returns have objectively been good on average (see Section 6.1.2), and the long waiting period to receive the payment of the Recognition Bond from the ONP is not within the AFPs’ control.

Provide a centralised and neutral contact point for the affiliate to file requests, initiate procedures and manage payments

The AFP should not be obliged to bear the responsibility for procedural failures that they are not in control of, as this will unjustifiably undermine consumer confidence in their competence. Ensuring that the responsibilities of the AFP are appropriate (see also Section 6.3.5) and improving the transparency of the processes of the pension system for consumers could help to mitigate the perception that the AFPs are responsible for all of the ills of the system. In order to have confidence in the pension system, consumers need to have confidence in the institutions that are managing their money and believe that the AFPs are acting in their best interest.

Making the centralised platform PensionsNet (see Sections 4.5.2 and 6.3.5) the point of contact for affiliates of the pension system, would help to mitigate the public’s perception that the AFPs are responsible for all of the procedural failures of the system. This should be achieved without impeding on the AFPs’ relationship with affiliates for the services they provide. In addition, the centralised platform, PensionsNet, should have the mandate to enforce the payment of contributions that have not been paid. To the extent that this platform will be better placed to manage and enforce cash flows between institutions, the risk of procedural errors should also be reduced. In order to ensure that it is being managed with the appropriate objectives and in an efficient manner, the board of directors of the platform should have representatives from both the public and private institutions.

Improve accountability and governance of AFPs

To improve public perceptions that the AFPs are acting in their best interests for the responsibilities that are within their control, the AFPs should be held accountable to the public. Measures have already been taken to do this, as currently the Board is required to issue an annual report to the Council for Citizen Participation in Social Security (COPAC). This objective could be advanced further by ensuring regular reporting to consumer interest groups regarding decisions made by, and the performance of, the AFPs.

In addition, the SBS should ensure that the legal framework for corporate governance is in line with the G20/OECD Principles of Corporate Governance and the OECD Core Principles of Private Pension Regulation to effectively address the potential conflicts of interest that AFPs that are subsidiaries of larger banking or financial institutions could face (OECD, 2015[6]) (OECD, 2016[7]). Advisors from the AFPs need to manage and minimise the conflicts of interest that they face, for example if they would be incentivised to encourage the affiliate to take a lump-sum to invest in a banking product. In addition, any fees paid for intermediary services provided by the bank need to be made transparent.

8.4.3. Improve confidence in the public institutions of the SNP

The Peruvians’ perception of public institutions may also be harming their trust in the rules of the pension system. In many cases, individuals who have contributed to the system will not receive benefits from those contributions, either because they were directed to the wrong institution or because they did not achieve 20 years of contributions in the public system. Having an integrated supervision of the entire pension system would help to ensure that it is functioning properly and in the interests of the people, thereby promoting trust in the system. In addition, the reforms needed to ensure the long-term sustainability of the pension systems and the adequacy of the retirement income that it provides should be implemented by an independent committee free from the political process.

Improve transparency and governance of the management of contributions

The disappearance of contributions that individuals have paid to the system seriously undermines the trust and confidence that the public can have in the system. Improved information sharing and collaboration across institutions would help to eliminate the procedural errors of misdirected contributions (see Section 4.5.2), but additional cooperation will need to be put in place to correct past mistakes and ensure that members do not lose the pension rights that they are entitled to. The Fiscal Responsibility and Transparency Framework of Regional Governments and Local Governments allowing the ONP to return mistaken contributions made since 2012 is only a first step to rectifying the problem. Additional solutions will need to be found to address the contributions that are not returned as a result of this Legislative Decree and restore trust that the pension system will make good on its obligations and commitments.

One potential solution would be to allow these individuals to recoup lost benefits would be to pro-rate a pension entitlement from the SNP. This solution would limit the immediate fiscal impact to the ONP of returning the contributions, while allowing the member to receive some benefit from the contributions to the SNP even if they did not achieve the minimum contribution period of 20 years. Otherwise a solution should be found to return lost contributions to affiliates with interest.

Strengthen regulatory and supervisory powers of the SBS

The law empowers the SBS with regulatory, inspection and control, as well as sanctioning powers. The SBS uses preventive supervision to establish corrective measures for which the severity is based on the potential impact of the identified weaknesses on the overall risk profile of the supervised entity. The SBS also imposes sanctions in the cases that are allowed within the regulatory framework. Nevertheless, the SBS does not have supervisory and regulatory powers for the entire pension system, nor do they have sufficient regulatory powers to address the problems that they identify in the system. For example, the SBS has the responsibility to handle requests from affiliates who want to disaffiliate from the SPP to go back to the SNP, but they do not have decision-making power regarding disaffiliation. They also are not able to obtain all of the information needed to ensure that the system is working properly (see Section 4.5.2), such as the employment information of affiliates to ensure that owed contributions have been paid. In order to ensure that the entire system is well integrated and functioning properly, a single body needs to have supervisory and regulatory powers for the entire system. This will allow the supervisor to ensure that the different components of the system are operating in harmony, improve their effectiveness in addressing any problems, and facilitate the enforcement of sanctions where needed.

Establish broad based and comprehensive reforms and implement them gradually without losing sight of their long term horizon

Providing a regular stream of income in retirement is a long-term challenge. Therefore, any reform of the pension system needs to take a long-term vision that goes beyond short-term considerations. Pension reforms intending to improve the sustainability of the system and the level of pensions that it can provide can only garner the favour of the public and thus succeed when they are broad based and comprehensive. Broad based and comprehensive reforms provide a balanced approach to avoid winners and losers. Piecemeal reforms based on short-term considerations will jeopardise the overall pension system. Changes to pension systems have sometimes catered to these pressures and as a result have undermined their main objective of providing a regular stream of retirement income to people in old age.

In order to ensure that the pension reform maintains this long-term view, an independent committee of experts could be established. This committee of experts will be responsible for the implementation of the reform. This committee should be charged with reaching the agreed upon objective of a reformed pension system in a gradual manner, taking into account fiscal capacity, institutional capability, regulatory powers and labour market developments. This long-term and independent process will also help to promote trust in the system and avoid frequent changes that create additional risk and uncertainty for the population.

References

[5] Arellano marketing (2017), Presentación: Estrategias de ahorro a largo plazo de población joven y adulto mayor.

[1] OECD (2017), PISA 2015 Assessment and Analytical Framework: Science, Reading, Mathematic, Financial Literacy and Collaborative Problem Solving, PISA, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264281820-en.

[7] OECD (2016), OECD Core Principles of Private Pension Regulation, https://www.oecd.org/daf/fin/private-pensions/Core-Principles-Private-Pension-Regulation.pdf.

[6] OECD (2015), G20/OECD Principles of Corporate Governance, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264236882-en.

[4] OECD (2014), OECD Pensions Outlook 2014, OECD Publishing, https://doi.org/10.1787/9789264222687-en.

[3] OECD (2008), OECD Recommendation on Good Practices for Financial Education Relating to Private Pensions.

[2] SBS (2018), Cómo ahorran los peruanos para su futuro.

Notes

← 1. The articles 20, 51 to 59 and 79 to 94 of the amended Text of General Law of the Financial and Insurance Systems and Organic Law of the Superintendence of Banking and Insurance (General Law), approved by Law N° 26702, lay out these requirements.

← 2. Resolution SBS N° 272-2017.

← 3. Article 87 of the Ley General del Sistema Financiero y del Sistema de Seguros y Orgánica de la Superintendencia de Banca y Seguros.

← 4. The General Law and the Sanctioning Regulation (Reglamento de Sanciones) approved by Resolution SBS N° 816-2005 and its amending regulations.

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Chapter 8. Trust and confidence in the pension system