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Pensions Dashboards – ensure you’re prepared
DB funding – consider your scheme’s approach
LDI – review the Regulator’s recommendations
Investment consultant and fiduciary manager monitoring – reporting under the new regime
Plus – what to expect in the coming weeks.
Get up to speed on dashboards. The Pensions Regulator (TPR) continues to urge schemes to make sure they’re ready as staging dates move closer – and notes that it will take “a dim view of wilful or reckless non-compliance.” TPR’s guidance provides useful checklists.
In the past few weeks there has been a flurry of activity: the Dashboard regulations came into force, alongside DWP guidance on deferring connection; revised PDP ‘Standards’ have been published, and TPR is currently consulting on its compliance and enforcement policy in relation to dashboard-duties breaches.
ACTION: ensure your scheme is fully prepared for its staging date, including having all data in order. Schemes looking to defer dashboard connection (allowed in very specific circumstances only) must take action as soon as possible in 2023.
consultation on its draft DB funding code was published in December, alongside revisions to its proposed ‘Fast Track’ mechanism and regulatory approach. The new regime is expected to come into force with effect from 1 October 2023, for valuations falling from that date.
DB schemes’ funding and investment strategies will be expected to have a long-term objective for providing scheme benefits. Schemes should start to consider how the new requirements will impact their current funding approach.
ACTION: Watch out for publication of the final Code, and finalised DWP regulations, in 2023. Be aware that further changes may yet be made to both, stemming from discussions around Liability Driven Investments (‘LDI’ – see below). New covenant guidance from TPR is also expected in 2023.
Autumn saw pensions making headlines as the Bank of England stepped in with measures to support market functioning, including gilt purchases, following the September mini-budget. While the industry stressed that members’ pensions remained safe, schemes were urged to take steps to review and manage risk going forwards.
TPR has since issued a guidance statement calling on schemes to maintain resilience and governance in leveraged arrangements, and setting out practical steps trustees should take. It plans to issue an update in its April 2023 Annual Funding Statement, with further guidance as necessary.
ACTION: Trustees should familiarise themselves with TPR’s recommendations. And with the Work and Pensions Committee’s Inquiry ongoing, and the Bank of England recommending that further regulatory and supervisory action is required, watch out for further impact stemming from this ‘crisis’.
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.
TPR’s new single code, with the final version expected imminently. Speak to us about the steps you need to take and how we can help
new and updated notifiable events, which will need to be factored into corporate plans – these are still awaited despite having been expected to come into force in April 2022
a continued focus on value. Smaller schemes will by now have carried out value for member assessments. TPR continues to expect schemes to improve – or wind up. The DWP, FCA and TPR are also due to consult on a new value for money framework in 2023, setting metrics and standards in areas such as investment performance, costs and charges and service quality.
05 January 2023