## Thursday, January 19, 2023

### Examining grievances and redress for pension products

by Vimal Balasubramaniam, Aishwarya Gawali, Nancy Gupta, Renuka Sane and Srishti Sharma.

In a previous article, Examining grievances and redress for banking products, we studied the nature and extent of grievances for banking and payment products in India. We also evaluated whether grievance redress mechanisms worked, and what impact grievances had on the usage of products. In this article we study similar questions for contributory pension products. The analysis is based on a survey of 21,355 respondents that we conducted in five states including Maharashtra, Bihar, Haryana, Madhya Pradesh and Andhra Pradesh.

### Measuring grievances

In the survey, we first ask if the respondent is using or has ever used contributory pension products. These would typically include the General Provident Fund (GPF), the Public Provident Fund (PPF), Employee Provident Fund (EPF) and the New Pension System (NPS). The study explicitly excluded various defined benefit pension plans, such as old age pensions, widow pensions, and disability pensions. We then ask the following questions:

1. If the respondent had faced an issue with any of the contributory pension products in the last 12 months?
2. If yes, what was the latest/most recent issue with the pension product?
3. Did the respondent complain after encountering the grievance?
4. Was the issue resolved after the first complaint?
5. If no, was the complaint escalated further?
6. If the complaint was escalated, was the issue resolved upon escalation?
7. If the respondent did not complain, what was the reason for not complaining?
8. Finally, what was the impact of the grievance on their usage of pension products?

We only consider complaints registered with the financial service provider or pension regulators. We do not include complaints filed in the police station or consumer courts as this is not in the ambit of the regulatory grievance redress system. Our questions do not pertain to any specific pension product. The results, therefore, are a reflection of the overall system of grievance redress, and not of any particular scheme.

Before we describe our results, it is useful to present the existing grievance redress mechanisms in the pension ecosystem. It is also important to note that while certain pension regulatory bodies report the incidence and resolution of grievance, there is no official consolidated statistic on the number of grievances for contributory pension schemes in India. Table 1 provides a snapshot of the governing regulatory bodies and grievance redress mechanisms (GRMs) of some of the major pension products that are relevant to our study.

Table 1: Pension products, regulatory body and GRMs
Pension Product Regulatory Body Grievance Redress Mechanisms (GRMs)
General Provident Fund (GPF) Department of Pension and Pensioner's Welfare under the Ministry of Personnel, Public Grievances and Pensions Online Grievance Lodging and Monitoring System at the Office of the Comptroller and Auditor General of India
Public Provident Fund (PPF) Department of Post of India Centralised Public Grievance Redress and Monitoring System (CPGRAMS) along with a dedicated Grievance Handling Cell accessible via call and email
Employee Provident Fund (EPF) Employees' Provident Fund Organisation (EPFO) EPF i-Grievance Management System (EPFiGMS)
New Pension System (NPS) and annuity schemes Pension Fund Regulatory and Development Authority (PFRDA) A multi-leveled Grievance Redressal System

Our analysis thus pertains to the use of contributory plans, which include, but are not limited to the schemes mentioned above.

### Results

Our sample comprises of 21,355 respondents. 622 (2.92%)individuals reported having used a pension product. This is not surprising given that coverage through mandatory occupational pensions is low. However, there appears to be growing demand for micropension among poor families. This is reflected in our sample as well. Respondents with annual family income of less than one lakh rupees formed the largest share of pension users. 50% (314 out of 622) of pension users had an annual family income of less than one lakh rupees. 30% (187 out of 622) of the pension users had an annual family income between 1 to 3 lakh rupees. The remainder 20% had an annual family income of more than 3 lakh rupees.

### Extent and nature of grievances

Of the pension users, about 11.4% (71 out of 622) reported having faced grievances related to pensions in the last 12 months. 61% (43 out of 71) of the grievances pertained to irregular or delayed pension payments, while 34% (24) of individuals claimed having not received their monthly pension during the last 12 months. About 6% (4) respondents faced grievance related to paper work issues.

### From grievance to complaining and resolution

Table 2 presents the life cycle of pension related grievances - this helps us understand the working of the redress mechanisms, both at the level of financial service providers (FSPs) as well as the regulators. As described earlier, 622 respondents owned a pension product, while 71 had a grievance. Out of the 71, 59 (83%) complained to the FSP. The FSP was able to resolve 33 (56%)complaints. This implies that 26 complaints were not resolved. Of these only 8 (31%) were escalated to a higher authority, leading to a resolution of 5 (63%). Overall, this suggests that 33 grievances (46%) were not resolved - either because the respondent didn't complain at all, or because the problem was not resolved either at the FSP or regulatory level.

Table 2: Grievances, complaints and resolution
Pension Product N
Own the product 622
Complained to FSP 59
Resolved by FSP 33
Escalated to higher authority 8
Resolved upon escalation 5

We also explore the reasons why people do not complain when faced with a grievance with pension products. We focus on those respondents who didn't complain to the financial service provider/regulator. This doesn't include those who did not escalate their complaint after it was not resolved by the FSP. As seen in Table 2, 12 out of the 71 respondents who had a grievance chose not to complain. Of these 12 respondents, four felt that their problem would not get resolved sometimes because they didn't know if their problem was valid in the first place, while four were reluctant to access the process - either because they didn't have enough knowledge of the same, or because they felt the process was too costly and complex. These are very small sample sizes, and hence the results may not be generalisable.

### Impact of grievance on usage

In Table 3, we present the impact on usage for those who had faced any grievance while using the pension products.

Table 3: Impact on usage of pension schemes
Impact on usage of pensions N %
Changed the provider 36 51
Stopped using the product 11 15
No change 11 15
Reduced the use of product 5 7
Do not know/wish to answer 5 7
Increased the use 3 5

Regardless of the respondent's course of action, the experience of having faced a grievance is bound to have an impact on the usage. As a result of encountering grievance, a majority of the respondents chose to change their service provider. 51% of those who had a grievance (36 out of 71) changed their service provider. 7% (5 out of 71) users having faced grievance reduced the usage of the pension products, while 15% (11 out of 71)stopped using the product.

### Conclusion

GRMs in the pensions sector seem to be performing better than the banking and payments sectors. The incidence of grievances is lower, and the complaint rate is higher. However, banking and payments have a substantially larger number of users, and the products also get used more frequently than a pensions product. So it is not surprising that frictions in the banking space are higher. While the incidence of complaints may be lower in pensions, the impact of poor service may be higher on users, especially as the nature of grievances suggests that these occur later in life, when people may have limited means to solve the problem. This makes the numbers reported in the survey large enough to matter.

Vimal Balasubramaniam is a researcher at Queen Mary University, London. Aishwarya Gawali and Nancy Gupta are researchers at NIPFP. Renuka Sane is a researcher at Trustbridge. Srishti Sharma is a PhD student at Texas A&M University.

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