Key issues for pension trustees' agenda

Get up to speed on dashboards. The Pensions Regulator (TPR) is urging schemes to make sure they’re prepared as staging dates move closer – and notes that it will take “a dim view” of those who “fail to prioritise their dashboard responsibilities.”

We have now had the DWP’s response to its consultation on the dashboard regulations, and expect the final version imminently; the Pensions Dashboards Programme’s consultation on draft dashboard “standards”; updated TPR guidance, and industry guidance on data accuracy, amongst other things. 

ACTION: ensure your scheme is aware of its staging date, and continue to take steps so that your data is in order and your scheme ready to connect.

• DC and hybrid schemes with less than £100 million in assets under management must carry out detailed annual value for members assessments, to demonstrate whether they offer good value. If not, TPR expects schemes to improve – or wind up.
• These assessments must be undertaken at every scheme year end from 31 December 2021, and reported to TPR.

ACTION: where relevant to your scheme, table as a standing issue at trustee meetings.

• Trustees have been used to sending a statement to the Competition and Markets Authority (CMA) by early January each year, confirming their compliance with requirements in relation to investment consultants and fiduciary managers.

• From 1 October 2022, TPR took over compliance monitoring from the CMA and published revised guidance for schemes. Reporting to TPR is expected to have to be made via the scheme return – although TPR’s recently-published sample scheme return for 2023 with updated questions (including requiring greater detail from schemes on asset class splits, for example) did not include reference to this.

ACTION: while we await confirmation of the new reporting requirements, schemes should ensure they are aware of the differences between the CMA and TPR regimes in this area.

• With inflation in double figures, and the cost of living set to increase further over coming months, trustees should consider whether and how to address this with members. Schemes may see members making changes to their contribution levels, and find themselves asked to consider offering discretionary increases. (See our forthcoming Pension Ombudsman Update - September 2022 for a determination in relation to a member’s request for a discretionary increase.)
• Inflation assumptions for the calculation of transfer values and early retirement pensions should be reviewed and discussed with advisers, and both trustees and employers should be alive to the economic climate’s potential impact on funding.

ACTION: be prepared to discuss at your trustee meetings – and to respond to increased member concerns and queries.”