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In a letter to Parliament late 2016, the State Secretary for Social Affairs and Employment set out the government's conditions for allowing mergers between mandatory industry-wide pension funds with temporarily ring-fenced funds. We have identified a number of areas that could be problematic. These include that the proposed ring-fencing ban is not essential, that the proposal does not anticipate the introduction of a new pension contract, and that there is no provision for the governance of merged pension funds.

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