Submission 52

Green Paper submission

January 2008

I submit that anybody who has a pension fund (whether sourced from an employer’s pension scheme or from a personal pension plan etc) should be allowed to transfer the fund to an approved retirement fund ( ARF) and should not have to fulfil the criteria of being a director (with 5% shareholding) of the company from which the pension fund accrued. I think that this is a throwback to the thinking that only directors and suchlike were capable of managing their fund or understood investments and pension provision.

A person who has decided to take the fund from an employer’s pension plan, and invest it in a retirement bond cannot subsequently invest it in an ARF (and/or an AMRF as appropriate). This is an unequal and unfair situation and should be reformed.

I submit that the criteria for assessing the level of the contributory social welfare pension paid should be based on total RSI contributions rather than average per annum. In the past, there was a rule that no contributions were necessary from an employer or the employee, if the level of income was above a certain amount. This was later discarded as the poor thinking behind the regulation was realised.

What could then occur was that, as no contributions were made for say 4 years, the average number of contributions were impacted on dramatically, despite the fact that full annual contributions were made for a long number of years.