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ARTICLE · 08 MAY 2015

Lessons From Across The Pond

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If you want to see where the law on pensions is going in the UK, the US is usually a good place to start.

United KingdomEmployment and HR

If you want to see where the law on pensions is going in the UK, the US is usually a good place to start.

Part of this is down to similarities in economic models, political influence and common language. The UK Government copied the best bits of the Pension Benefit Guaranty Corporation when it set up the PPF.

There are also "structural" similarities created by the existence of a sizeable private pension sector. Both systems have a basic divide between schemes with a third party subject to a fiduciary duty looking after pension savings (in the UK a trustee in the US, a fiduciary) and contract- based schemes. Both systems also have a divide between defined contribution and defined benefit pension schemes.

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