Key issues for pension trustees' agenda

Pensions Dashboards

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.

Value for Members

• 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.

Investment consultant and fiduciary manager monitoring

• Since 2019, trustees have years been required to send a statement to the Competition and Markets Authority (CMA) confirming the extent to which they have complied with requirements in relation to investment consultants and fiduciary managers.
• From 1 October 2022, TPR takes over the compliance monitoring from the CMA, with reporting to be made via the scheme return. TPR has published revised guidance for trustees on the tendering process for fiduciary managers and for setting objectives for investment consultants. 

ACTION: whilst affected schemes should already be largely compliant with the requirements, there are some technical differences between the two regimes to be aware of.

Cost-of-living increases

• 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.”