Five changes to CPF rules

[eAtNeAt]

I think the analogy to fd is not quite right. cpf life does not mature at all, even if you are 85 or 90. it only matures if you die.

to me, whether to top up to ers does not depend on when i can finish withdrawing the sum.

i believe when i die, i will have something left for my kids. so i will look for some place with good returns and low risk to park money. cpf life is definitely one of the options.

and if i cannot die, ers will give me a higher payout throughout my life.

I was referring to AMP. It is somewhat like rss. All principal will be distributed by 85. Interests earned will be distributed by 90. So it has a fixed tenure, earns 4%. And even better, the principal gets distributed bit by bit every month. If the member doesn't need the money he can put it back via AMP.
It seems that now they can't, but this is not clear in the narratives so far.

 

[fr33d0m]

Hi BBCWatcher & all posters,

If the aim were to build up the homemaker spouse's retirement income while getting tax relief at the same time, which is better, VC to MA $8k or cash top up to SA $8k?

From what I've read, most employed ones prefer topping up MA to the BHS so that excess contribution overflows to SA. But in the case of the homemaker spouse, this might not be so relevant?

Also VC to MA can it be done $8k to MA only, at one shot, or must be to 3 accounts?

Thanks!

MA can't be used for retirement. For retirement, go straight to SA. And the decision should have been made long ago. Your homemaker spouse should have similar CPF balance as you.

CPF LIFE can't be depended as part of an estate as the interest on CPF LIFE premium goes to the pool. So when the one with CPF balance dies, there could be little left for the one without CPF balance.

 

[BBCWatcher]

Hope it's not retroactive. There are some who deposits via amp effectively treating RA as a safe 4% fixed deposit that matures when they are 85/90.

First of all, AMPs only apply to current recipients of CPF LIFE monthly payouts. If you haven't started CPF LIFE payouts yet then there are no AMPs. (I'm excluding classic Retirement Sum Scheme participants for purposes of this discussion.)

OK, with that background, the announcement says that RA top ups and inflows from November, 2021 (this month onward) will feed into higher CPF LIFE payouts, not AMPs. Members currently receiving AMPs can still get those particular AMPs that are already in progress. But any dollars added from November 1 (two days ago as I write this, which is all I meant by "retroactive") cannot be paid out as AMPs.

That's my best understanding at this point in time based on what has been published.

Don't understand your last point to deposit into ers when one is so old.

That's OK. It's "advanced CPF hackery" that's probably quite silly and really not worth spending time worrying about.

This one i dont understand garmen. why must wait till 65 for the sweep. why does it not sweep immediately when there is money? like that can earn even more interest

This "sweep" only really matters if your 55th birthday sweep didn't result in a Retirement Account funded to the FRS. Most people reading this forum hopefully will have RAs funded to the FRS on their 55th birthdays.

For those that don't, there's a second sweep that occurs. It used to occur at age 65, and now it'll occur just before CPF LIFE payouts start which could be as late as age 70. I think the government's logic is that plenty of people in this category are still working after their 65th birthdays and still have compulsory contributions streaming into their OA/SA/MA. So a later sweep will sweep more principal dollars into their RAs. All bonus interest is still paid into their RAs. On average this'll result in better funded RAs and thus higher CPF LIFE payouts.

But you're quite right that RA pays 4.0% interest (plus receives all bonus interest), and OA pays 2.5% interest. So the compulsory dollars landing in OA are going to trail behind RA. If you start CPF LIFE payouts at age 65 this won't matter -- the sweep still occurs at the same time. It also doesn't matter among those CPF members who perform "manual" sweeps (transfers from SA/OA, in that order, to their RAs). You can still do that, and hopefully you do it if/when it makes sense. And I think the government is probably correct that the people with "underfunded" RAs (i.e. subject to a second sweep) are probably still working if they aren't starting CPF LIFE payouts at age 65, so deferring the second sweep to payout start will sweep up more dollars, even if those dollars aren't all working as hard as early as they could be. The higher principal outruns the lower interest paid on OA, basically.

It makes logical sense to me. On balance it seems like an improvement, but further improvements are probably possible.

If the aim were to build up the homemaker spouse's retirement income while getting tax relief at the same time, which is better, VC to MA $8k or cash top up to SA $8k?

Wow, great question!

From what I've read, most employed ones prefer topping up MA to the BHS so that excess contribution overflows to SA. But in the case of the homemaker spouse, this might not be so relevant?

Yes, SA flows directly into retirement (RA, CPF LIFE) -- you're quite right about that. So if the sole goal is more/better retirement income security, then SA wins. If your spouse is never going to have compulsory contributions (or highly unlikely to have), then MA overflow considerations and mechanics really never enter into the picture. So I think you would prioritize SA. And you don't necessarily have to limit SA top ups to the $8,000 tax relief limit. If you can afford more then I would probably try hard to get her SA up at least to $60,000 as quickly as possible, and assuming her OA and MA are zero. The reason is that the first $60,000 earns 5.0% interest (4.0% plus bonus interest), and that's really attractive these days.

Bear in mind there are many homemakers spouses that do NOT make you (the other spouse who's making the top up) qualify for tax relief. IRAS's $4,000 income limit is quite strictly defined and includes much more than Singapore taxable income. Check IRAS's Web site for details.

Also VC to MA can it be done $8k to MA only, at one shot, or must be to 3 accounts?

Starting January 1, 2022, you can deposit as much as you want into anybody's MA subject only to the Basic Healthcare Sum (BHS) limit. Before 2022 the CPF Annual Limit also applies, and it applies to the recipient. Let's suppose for example your spouse's MA is currently zero and she will end up with zero contributions to CPF in 2021 that count against the CPF Annual Limit. If you wish you could deposit $37,740 (the whole CPF Annual Limit) directly into her MA today.

This year (2021) only the recipient qualifies for tax relief when there are Voluntary Contributions to MA. There is no separate limit to this tax relief, so in this example your wife would qualify for $37,740 of tax relief. (But since presumably she's in the zero percent tax bracket in Singapore, it's moot. Zero of zero is still zero.) Starting next year (2022) the giver qualifies for MA-related tax relief, if anybody does. And the tax relief will be limited to $8,000 (self) and another $8,000 (eligible family member recipients) with each $8,000 applied to MA+SA+RA (the total).

It's still a little confusing perhaps, so if you're still confused ask a follow up question.

I was referring to AMP. It is somewhat like rss. All principal will be distributed by 85. Interests earned will be distributed by 90. So it has a fixed tenure, earns 4%. And even better, the principal gets distributed bit by bit every month. If the member doesn't need the money he can put it back via AMP.
It seems that now they can't, but this is not clear in the narratives so far.

That's right. AMPs are being phased out, except for two groups: (1) classic RSS participants (who can still top up their RAs and get their classic RSS payout bumps), and (2) people already receiving CPF LIFE payouts and AMPs. Group 2 cannot increase/add to their existing AMPs, but they keep receiving existing AMP streams. Group 1 only includes members born before 1958 who have not opted for CPF LIFE.

The younger portion of Group 1 can still opt for CPF LIFE as late as about age 79.9 if they wish -- and they might want to now! There's a little more incentive to opt for CPF LIFE given another, separate rule change: the CPF Board will start automatically paying out their residual SA and OA balances once they exhaust their RAs. Some people in Group 1 might not like that (for bequest reasons perhaps), but if they switch to CPF LIFE then SA/OA automatic payouts don't happen. Even if the CPF LIFE payout is $1/month, oddly enough that's enough to stop SA/OA automatic payouts. Go figure. But the deadline to enroll in CPF LIFE is about age 79.9 or maybe 79.8.

 

[BBCWatcher]

CPF LIFE can't be depended as part of an estate as the interest on CPF LIFE premium goes to the pool. So when the one with CPF balance dies, there could be little left for the one without CPF balance.

Neither the classic Retirement Sum Scheme nor CPF LIFE guarantees any bequest. Simply live long enough and there is no bequest from CPF RA either way. And once payouts start even if there is a residual the residual decreases every month. "Nothing new here."

However, the one thing CPF LIFE can do exceedingly well, particularly with the Escalating Plan, is guarantee a bequest (or better yet lifetime gifts) from other assets. That's because CPF LIFE payouts are guaranteed for life, however long that lasts. You cannot outlive CPF LIFE.(*) (You can definitely outlive/exhaust your CPF RA under the classic Retirement Sum Scheme. Many people do.) And with the Escalating Plan the monthly payments are guaranteed to escalate, i.e. to fight inflation and preserve a real lifestyle rather well.

If you want to guarantee a bequest (or better yet lifetime gifts), then learn more about CPF LIFE and take full advantage of it. It's wonderful stuff if you have these motivations.

Within CPF there's one "leg" that works rather well as a bequest delivery vehicle if that's what you want: CPF MediSave. For example, park the full BHS in MediSave, don't touch it, and your CPF nominee(s) will get all of it. And it'll earn 4.0% interest along the way which is rather attractive.

(*) Unless you outlive the Government of Singapore as a functioning entity. Not likely at all.

 

[fr33d0m]

If you want to guarantee a bequest (or better yet lifetime gifts), then learn more about CPF LIFE and take full advantage of it. It's wonderful stuff if you have these motivations.

Within CPF there's one "leg" that works rather well as a bequest delivery vehicle if that's what you want: CPF MediSave. For example, park the full BHS in MediSave, don't touch it, and your CPF nominee(s) will get all of it. And it'll earn 4.0% interest along the way which is rather attractive.

(*) Unless you outlive the Government of Singapore as a functioning entity. Not likely at all.

how does these bequest help a homemaker spouse if she is too late or without enough to join her own CPF life?

I would argue that CPF LIFE of one own is a better bequest than whatever CPF bequest left after one dies.

 

[firsttimebuyer]

I see others have answered, but I'll add this point. There's an "easy" answer here: they're not required to add any funds to their Retirement Accounts, at least not if they've already reached the Full Retirement Sum (or Basic Retirement Sum with sufficient property pledge/charge).

Prior to this rule change if you are receiving CPF LIFE payouts and add funds to a Retirement Account, then did nothing, the dollars you add would stream out as "Additional Monthly Payouts" (AMPs). The AMPs are similar to the classic Retirement Sum Scheme payouts, meaning they end at a certain age (typically age 90). Now when you add funds to a RA the CPF Board will automatically recompute your CPF LIFE payout, and you'll receive a higher CPF LIFE payout, for life. That's the only thing changing with this rule change: no more AMPs.

I still think they ought to consider adding funds to their RA, though, if they're in a position to do it. RA -> CPF LIFE is still a great deal, better than they're likely to find anywhere else for discretionary savings.

There's a separate rule change relating to older CPF members who have remained on the classic Retirement Sum Scheme with payouts that typically end at age 90. Whenever those payouts end, evidently the CPF Board will now start making automatic payouts from any residual SA and OA funds until those funds are exhausted. OK, fair enough. That is genuinely slightly more convenient for most members. But if there's no opt-out option then (self evidently) an important reason why the CPF Board is doing this is to reduce interest payments on OA and SA balances. There are a few older members who, if they could, wouldn't even touch any of their dollars parked at CPF. Members who are in this category, and who are still below the age of 80 and in good health, should seriously consider switching to CPF LIFE before the deadline. CPF LIFE participants can keep their OA and SA dollars on account for entire the rest of their lives, plus 6 months beyond.

I will need to check if my parents already hit the FRS. I have trouble making sense of the whole thing,

 

[firsttimebuyer]

Yes, and it looks like that particular rule change is somewhat retroactive. With this rule change it's very simple: when funds are added to the Retirement Account of a CPF member who's receiving CPF LIFE payouts, the CPF Board will recompute and increase the member's CPF LIFE monthly payout (for life) starting from the next July. The CPF Board will not pay a separately computed classic Retirement Sum Scheme-like Additional Monthly Payout. (Except for a few "grandfathered" members who are already getting AMPs.)

There's an interesting little quirk in this rule change from an actuarial point of view. Currently the CPF Board does not allow anyone to join CPF LIFE later than age 80, and most members join CPF LIFE no later than age 70. This is to prevent "moral hazard" sort of scenarios where members in good or excellent health try to "game" the system too much. But you can game the system a little. One way (that I keep pointing out over and over, for I write the truth) is to defer payouts to age 70 (the default) if you're able. That gives you 5 more years of information about your own health status. But another potential option is to make RA top ups after you get more knowledge about your own longevity. That's not how I would play the game -- the core interest rate on RA is too attractive, and it's best to take that great deal up front -- but some people could play the game that way. For example, you could do this:

1. Let your RA be funded to the FRS at age 55, and leave it be.

2. Start CPF LIFE payouts at age 70. (Escalating or Standard Plan probably in this scenario, if you're in good health.)

3. When you hit age 90 (for example), deposit a relatively large amount of cash in your RA up to the current ERS.

This scenario is allowed, and maybe it would be "interesting" from a game playing point of view. Maybe it would even work. I think it's pretty silly, but I can imagine some silly game playing.

I remembered my parents did a top-up but I can't remember how much it was though.

So my parents won't get any more AMP but more CPF Life?

 

[zoneguard]

how does these bequest help a homemaker spouse if she is too late or without enough to join her own CPF life?

1. CPF's Enhanced Nomination Scheme for transfer of CPF monies between accounts up to FRS for SA, up to ERS for RA and up to BHS for MA upon nominator's demise.
2. HDB Lease Buyback scheme to monetize the HDB lease for top-up into RA and CPF LIFE.

 

[luvpraline]

Thank you all for your replies!

If the homemaker spouse's SA eventually reaches FRS later, and say she's 45 years old when she might hopefully reach FRS, then what's next?

Can one still transfer their CPF to the homemaker spouse's CPF if she has reached FRS?

I see the point fr33d0m made about trying to even out both spouses CPF balance in case 1 (with the disproportionately higher balance) dies early. But can this still be done if the homemaker spouse has reach FRS while the working spouse's CPF is projected to be way higher at 55?

 

[fr33d0m]

1. CPF's Enhanced Nomination Scheme for transfer of CPF monies between accounts up to FRS for SA, up to ERS for RA and up to BHS for MA upon nominator's demise.
2. HDB Lease Buyback scheme to monetize the HDB lease for top-up into RA and CPF LIFE.

How do these solve the too-late-to-join own CPF LIFE problem? Is a homemaker spouse who is likely not financial-savvy expected to manage her own retirement?

 

[zoneguard]

I see the point fr33d0m made about trying to even out both spouses CPF balance in case 1 (with the disproportionately higher balance) dies early.

There are 4 accounts in CPF with RA only created at the 55th birthday. The CPF nomination scheme covers the scenario of the member's demise. If the intention is to transfer into the surviving spouse's CPF accounts, the Enhanced Nomination Scheme is exactly for that purpose.

 

[fr33d0m]

Thank you all for your replies!

If the homemaker spouse's SA eventually reaches FRS later, and say she's 45 years old when she might hopefully reach FRS, then what's next?

Can one still transfer their CPF to the homemaker spouse's CPF if she has reached FRS?

Yes. can continue to top up to ERS to CPF RA after 55.

But can this still be done if the homemaker spouse has reach FRS while the working spouse's CPF is projected to be way higher at 55?

CPF LIFE is to guarantee an acceptable lifestyle to regular folks after retirement.

It seems that your household has more than that.

 

[lucky_]

I am relatively new to the CPF world so I have a naive question (not sure if I worded it correctly as the terms are a little confusing).

I am in my early 30s currently, and thinking of topping up my MA to reach BHS, or RSTU to SA for tax relief. My SA has not reached FRS yet.

With regards to RSTU to SA, if I contribute e.g. 5k a year for 20 years on top of my employer/employee contributions, and my SA hits FRS before I turn 55, I assume that the FRS will be taken out of my SA to form the RA, and I can withdraw the rest of my SA and OA if desired. It is stated on the CPF website that the RSTU amounts cannot be withdrawn at 55 and will instead contribute to larger CPF Life payouts.

Hence e.g. if FRS when I turn 55 is 200k and I have 300k in my SA (100k from RSTU and 200k from employer/employee contributions), which of the following scenarios will apply?
1. 200k (100k from RSTU and 100k from employer/employee contributions) will be taken from my SA at 55 to form my RA and I have 100k to withdraw anytime I like. My CPF Life payouts will thus be lower than scenario 2.
2. 300k (100k from RSTU, on top of 200k from employer/employee contributions) will be taken from my SA at 55 to form my RA and I cannot withdraw anything from my SA. My CPF Life payouts however will be higher.

I have been hesitating to commit to RSTU to SA as I presumed scenario 2 was true, and I would prefer to have some liquidity once I hit 55. Have I been wrong all this while?

 

[zoneguard]

Hence e.g. if FRS when I turn 55 is 200k and I have 300k in my SA (100k from RSTU and 200k from employer/employee contributions)

At 55 when RA is formed, the sweep from SA first followed by OA to RA will stop when RA reaches FRS for your age. If you want more (up to prevailing ERS) in RA, you need to request for it and monies are taken from first SA followed by OA.

 

[BBCWatcher]

how does these bequest help a homemaker spouse if she is too late or without enough to join her own CPF life?
I would argue that CPF LIFE of one own is a better bequest than whatever CPF bequest left after one dies.

Why not both?

I remembered my parents did a top-up but I can't remember how much it was though.
So my parents won't get any more AMP but more CPF Life?

If your parents have not started CPF LIFE payouts yet, then any/all funds added to RA will boost their future CPF LIFE payouts. That part hasn't changed at all.

If your parents HAVE started CPF LIFE payouts AND they have started AMPs, their existing AMP streams will continue. That doesn't change either.

If they're "in between" it's a little unclear. From the wording of CPF's announcement and the statute revision it seems like dollars flowing into RAs from November 1, 2021, will end up boosting CPF LIFE payouts. That's clear enough. Dollars flowing into RAs prior to November 1, 2021, for members already receiving CPF LIFE payouts evidently can be paid out as AMPs (the default) or (upon request within the next few months) higher CPF LIFE payouts. But it's a little unclear, so it's a good question to ask the CPF Board if you're in that particular situation.

1. CPF's Enhanced Nomination Scheme for transfer of CPF monies between accounts up to FRS for SA, up to ERS for RA and up to BHS for MA upon nominator's demise.

For the record I'm not a huge fan of the CPF Enhanced Nomination Scheme with the possible exception of a nominee who is -- shall we say -- not too financially responsible. You can pretty easily redeposit inherited cash into your CPF account(s), sometimes with tax relief and/or matching funds. The CPF Enhanced Nomination Scheme bypasses tax relief and matching fund opportunities.

I'm certainly not opposed to it, but you ought to think through the ramifications and apply it to your particular circumstances. And you can change your mind. If for example your nominee deteriorates in terms of financial responsibility, you can modify your CPF nomination to switch it to the ENS.

2. HDB Lease Buyback scheme to monetize the HDB lease for top-up into RA and CPF LIFE.

Yes, or open market sale, cash proceeds, and rental housing.

Thank you all for your replies!
If the homemaker spouse's SA eventually reaches FRS later, and say she's 45 years old when she might hopefully reach FRS, then what's next?
Can one still transfer their CPF to the homemaker spouse's CPF if she has reached FRS?

Well, there's MA up to the Basic Healthcare Sum. The BHS increases every year until the member's 65th birthday year.

There are also "all three account" CPF Voluntary Contributions. That's up to the CPF Annual Limit which is currently $37,740 per calendar year.

When this spouse celebrates his/her 55th birthday his/her Retirement Account is created. Then the RA limit is the current Enhanced Retirement Sum (ERS). The ERS typically increases every January 1 and is based on principal only, so every January it should be possible to add more dollars to the RA.

And of course there are private sector savings/investment opportunities.

I see the point fr33d0m made about trying to even out both spouses CPF balance in case 1 (with the disproportionately higher balance) dies early. But can this still be done if the homemaker spouse has reach FRS while the working spouse's CPF is projected to be way higher at 55?

Relative balance is perfectly fine, subject of course to applicable limits. We certainly do that in my household. My spouse balances are very close to mine. I would certainly focus on helping a balance trailing spouse (or partner) at least get up to maximum bonus interest ($60K) as reasonably quickly as possible since that's a "no brainer."

How do these solve the too-late-to-join own CPF LIFE problem? Is a homemaker spouse who is likely not financial-savvy expected to manage her own retirement?

Oh, that's actually quite easy. You can put, say, a mere $1,000 into a spouse's CPF Retirement Account, keep it there, and that spouse can join CPF LIFE at age 79 (for example). The monthly payout will be quite low, but the spouse will be on CPF LIFE. Thereafter somebody can dump $200K (or whatever) into that spouse's Retirement Account and hugely boost the monthly payout amount. All of that is allowed under current rules.

I'm not suggesting you should do this. I think you should help your spouse/partner maintain relative balance in his/her CPF accounts compared to yours, and vice versa. But you and he/she could do this.

 

[BBCWatcher]

I am in my early 30s currently, and thinking of topping up my MA to reach BHS, or RSTU to SA for tax relief. My SA has not reached FRS yet.

With regards to RSTU to SA, if I contribute e.g. 5k a year for 20 years on top of my employer/employee contributions, and my SA hits FRS before I turn 55, I assume that the FRS will be taken out of my SA to form the RA, and I can withdraw the rest of my SA and OA if desired. It is stated on the CPF website that the RSTU amounts cannot be withdrawn at 55 and will instead contribute to larger CPF Life payouts.

That's right.

Hence e.g. if FRS when I turn 55 is 200k and I have 300k in my SA (100k from RSTU and 200k from employer/employee contributions), which of the following scenarios will apply?
1. 200k (100k from RSTU and 100k from employer/employee contributions) will be taken from my SA at 55 to form my RA and I have 100k to withdraw anytime I like. My CPF Life payouts will thus be lower than scenario 2.
2. 300k (100k from RSTU, on top of 200k from employer/employee contributions) will be taken from my SA at 55 to form my RA and I cannot withdraw anything from my SA. My CPF Life payouts however will be higher.

Door #1, assuming the rules don't fundamentally change.

I have been hesitating to commit to RSTU to SA as I presumed scenario 2 was true, and I would prefer to have some liquidity once I hit 55. Have I been wrong all this while?

Yup.

I've made a lot of $7K SA top ups with tax relief. But when I celebrate my 55th birthday, and my Retirement Account is funded up to the Full Retirement Sum (it certainly will be, which is nice), I'm definitely going to have many tens of thousands of dollars of liquidity from RA -- plus full liquidity from residual SA and OA -- if I were to be so foolish to withdraw dollars from a 4.0% interest earning account (RA) with property pledge/charge. It's absolutely no problem having a slight reduction in RA liquidity. And most readers of this forum should be in a broadly similar situation, one would think. If you're gasping for financial air in the decade from age 55 to 65 where $20K of liquidity (or whatever) would make a difference, something went horribly wrong. And you're that much more likely to avoid that horribly wrong scenario if you collect, save, and prudently invest all that tax relief you're getting along the way.

 

[zoneguard]

The CPF Enhanced Nomination Scheme bypasses tax relief and matching fund opportunities.

But wins in terms of interest earned since it is account transfers so no interest is lost. Cash to CPF account deposits need to work with all the limits for the accounts and familiarity with CPF rules for the surviving nominee/spouse. Excess over FRS/ERS/BHS is paid out as cash nevertheless.

CPF is complicated and evolving and I'm not sure the surviving spouse would want to optimize for the sake of tax relief/matching fund opportunity and learn all these rules.

 

[BBCWatcher]

But wins in terms of interest earned since it is account transfers so no interest is lost.

Maybe a month of interest. Maybe.

Cash to CPF account deposits need to work with all the limits for the accounts and familiarity with CPF rules for the surviving nominee/spouse.

This part isn't complicated any more, and it wasn't particularly complicated to begin with. The limits are exactly the same (starting from January 1, 2022, with respect to MA): FRS for SA, ERS for RA, BHS for MA. OA isn't part of the Enhanced Nomination Scheme.

I should also point out there are some interesting cases when a surviving spouse/partner might choose to live outside Singapore, and that foreign country might have a tax system that doesn't align well (or at all) with CPF. There are some foreign tax jurisdictions that are fairly hostile to CPF.

CPF is complicated and evolving and I'm not sure the surviving spouse would want to optimize for the sake of tax relief/matching fund opportunity and learn all these rules.

OK, but (starting from January 1) there's literally nothing a surviving spouse cannot do with a cash nomination that the ENS makes possible. The ENS takes away myriad options but adds none. You're still free to leave a "sternly worded letter"...and then trust your spouse (or your spouse's legal guardian, if applicable). You're also still free to help your spouse achieve relative CPF balance. If your spouse is (also) at applicable SA/RA/MA limits, the ENS would be moot even if you chose it.

 

[fr33d0m]

Why not both?

How nice that everyone can just choose whatever they want.

In any case for no or little income homemaker spouse, it is prudent to have balanced CPF balance for both before starting CPF LIFE. Better if before that.

In most case, 1+1 > 2 as CPF is more beneficial near the bottom end.

 

[zoneguard]

OK, but (starting from January 1) there's literally nothing a surviving spouse cannot do with a cash nomination that the ENS makes possible. The ENS takes away myriad options but adds none.

I can think of a very specific scenario where only ENS will work and cash nomination doesn't achieve the same outcome. Anyway everybody's situation is different and I will leave readers to ponder if ENS make sense for their own households.