from your link....
Fifth, the regulation of pension funds is important. Countries with less regulation tend to offer a larger variety of portfolios to pensioners; meanwhile, their pension industry could be
more prone to fraud with large losses for investors. Clearly, countries with less developed capital markets tend to choose a more restrictive environment for their pension funds than countries with more developed capital markets.
REGULATION OF PENSION FUNDS
The five countries discussed in this paper use basically two types of pension fund regulation. The United Kingdom and Australia have left investment choices largely unregulated, relying simply on the prudent-man rule. By contrast, Argentina, Chile, and Mexico have imposed fairly strict regulatory requirements on their pension industry. The strictness of the regulation seems to be related to the maturity of the respective countries' capital markets.
Of the countries studied, the United Kingdom is the country with the least regulatory interference. Workers are free to choose their pension fund from a large variety of investment firms, banks, and other pension providers. The firms' managers must give their customers reliable advice and diversify investments, but no specific limits are placed on certain investment instruments. Because the U.K. system allows workers to opt out, it was originally prone to
overzealous sales practices. Moreover, the lack of a uniform fee structure causes a potentially confusing variety of pension fund fees and commissions. U.K. investments are much more broadly diversified than those held by Latin American pension funds, however, leading to a broader supply of funds with differing risk and return properties.
Australian regulators also interfere little in investment choices, only restricting investment of funds in the company of the sponsoring employer. Because most workers cannot choose their investment fund, however, Australia has not had a problem with high-pressure sales practices as has the United Kingdom. Moreover, with the growing importance of the superannuation sector, the government has
increased its supervisory efforts to prevent unwise investment practices and fraud. Because investment funds cannot compete for individual workers, however, the funds' portfolios may not coincide with a worker's risk preferences. In fact, some consider the Australian investment practices too conservative.
Chile and Argentina
heavily regulate their pension funds. In both countries, funds face minimum return requirements, investment limits, and
strict oversight by a supervisory authority. In addition, each fund may offer only a single portfolio. As a result, investment firms tend to have similar portfolios, basing competition more on services offered than on portfolio choices and investment performance. Moreover, firms may charge commissions and fees only on new contributions--not on assets. On the one hand, such a regulation improves the transparency of the fee structure and reduces costs for low-income workers with less steady employment and inactive accounts; on the other hand, it substantially reduces the net investment returns of new contributions and forces active contributors to subsidize the accounts of noncontributing account holders.
Mexico also heavily restricts pension funds: they must meet stringent requirements and are controlled by a supervisory commission. According to the current plan, however, Mexico's system will eventually allow workers more choices than the Argentine or Chilean system. In Mexico, each pension fund will offer a variety of investment portfolios, allowing workers to allocate their accounts among several mutual funds. Moreover, the Mexican system permits a variety of commissions and fees, including a charge on assets. END OF QUOTED PART OF THE LINK>>>>
I highlighted a few spots...
The USA has a much larger economy, and more crooks per square mile than all the other countries combined.
If we switch, I hope our govt puts SEVERE criminal penalties for fund managers who try to screw over the public...