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Simplification is the key - Centre for Policy Studies

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Such principles would have to ensure that an unscrupulous provider could not<br />

irresponsibly harness <strong>the</strong> power of <strong>the</strong> trusted ISA brand 148 <strong>for</strong> example. Tarn<strong>is</strong>h <strong>the</strong> ISA<br />

brand, and <strong>the</strong> interests of <strong>the</strong> whole industry would be damaged – as providers of With<br />

Profits Funds d<strong>is</strong>covered to <strong>the</strong>ir cost.<br />

10.7 Operational considerations<br />

There should not be any technical barriers to implementing <strong>the</strong>se proposals, although<br />

some providers may have to make a step-change in <strong>the</strong>ir IT capabilities. Data tracking<br />

would be required in respect of transactions such as early access to pension savings<br />

and fund movements within couples, not least to minim<strong>is</strong>e <strong>the</strong> scope <strong>for</strong> gaming <strong>the</strong> tax<br />

framework.<br />

A number of leg<strong>is</strong>lative changes would be required to facilitate <strong>the</strong> env<strong>is</strong>aged increase in<br />

flexibility, such as <strong>the</strong> transfer of ISA assets into a pension savings product. It should not<br />

be necessary, <strong>for</strong> example, to have to go through <strong>the</strong> two-step required today (divest <strong>the</strong><br />

ISA, <strong>the</strong>n reinvest in <strong>the</strong> pension, completing <strong>the</strong> necessary ISA d<strong>is</strong>charge and pension<br />

saving application <strong>for</strong>ms to do so).<br />

It <strong>is</strong> not env<strong>is</strong>aged that <strong>the</strong>se proposals ra<strong>is</strong>e any significant regulatory <strong>is</strong>sues, but to <strong>the</strong><br />

extent that <strong>the</strong>re are any, <strong>the</strong>y should not be allowed to d<strong>is</strong>tract attention from <strong>the</strong> v<strong>is</strong>ion:<br />

more people saving more, <strong>for</strong> longer.<br />

148 There are indications that th<strong>is</strong> <strong>is</strong> beginning to happen because of <strong>the</strong> very low rates of interest being<br />

paid on Cash ISAs.<br />

65

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