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Integrity • Clarity • Simplicity
February 2020 to April 2020
Supporting you to improve governance and stay on top of the ever-changing technical issues in the pensions industry.
Regulatory update
Integrity • Clarity • Simplicity 1
FEBRUARY 2020 TO APRIL 2020
For action/discussion with your advisers and/or administrator
New Issues – New TPR Coronavirus guidance on scheme administration
New Issues – TPR guidance on communicating to members during COVID-19
New Issues – TPR 2020 Annual Funding Statement
New Issues – Updated TPR guidance on DC scheme management and investment
New Issues – FCA expectations for wet-ink signatures in light of Coronavirus
New Issues – FCA updated guidance on Coronavirus
New TPR guidance on Coronavirus
TPR updated guidance on Coronavirus and suspension of initiatives
TPR statement for trustees on Coronavirus
PPF Coronavirus guidance and contingent asset requirement changes
PLSA publishes COVID-19 resources
FCA guidance on Coronavirus
FRC guidance on Coronavirus
ICO guidance on Coronavirus
GMP equalisation guidance – “when to rectify”
Budget day 2020
Companies House grants extension on company accounts
Government statement that electronic signatures are valid
Order made clarifying VAT exemption for management of pension funds
PMI launches professional trustee accreditation programme
FCA Policy Statement on disclosing costs and charges to workplace pension scheme members
Integrity • Clarity • Simplicity 2
FEBRUARY 2020 TO APRIL 2020
For monitoring
New Issues – PPF statement on COVID-19 impact on levy payers
New Issues – Progress on professional trustee accreditation
New Issues – ICO regulatory approach during the Coronavirus pandemic
New Issues – ESMA report on central clearing solutions for pension scheme arrangements
PASA launches COVID-19 guidance for administrators
BEIS committee launches inquiry on audit reform
Consultation on climate-related risk
HMRC releases GMP equalisation tax guidance
TPR publishes first part of consultation on revised code for scheme funding
Pension Schemes Bill – proposed climate change amendments
TPR responds to DWP letter on climate change
TPR response to future of trusteeship and governance consultation
TPR guidance on preparation for future EU relationship
Integrity • Clarity • Simplicity 3
FEBRUARY 2020 TO APRIL 2020
For information
New Issues – PPI briefing note: the pensions implications of COVID-19
New Issues – TPR blog on protecting savers
New Issues – Scams guidance from TPR and the PPF
New Issues – Guidance on good practice for virtual board and committee meetings and new legislation on AGMs
PASA announces new cybercrime and fraud working group
EIOPA publishes model pension benefit statements
PLSA publishes updated Stewardship Guide and Voting Guidelines
General levy increase revoked
PPF guidance on trustee contingency planning
PLSA guidance on diversity and inclusion
FCA updates guidance on how to avoid pension scams
TPR blogs on “positive change” in 2020 and diversity
TPR blog on pension scams
TPR spot checks on large employers
Integrity • Clarity • Simplicity 4
FEBRUARY 2020 TO APRIL 2020
New Issues – New TPR Coronavirus guidance on scheme administration
On 2 April 2020, TPR published guidance for trustees and public service pension schemes on scheme administration in light of the Coronavirus pandemic. It states that trustees should work with administrators to make sure they deliver “critical processes”, which include:
• paying members’ benefits;
• retirement processing;
• bereavement services, as well as any administrative functions required to support these;
• any processes needed to ensure benefits are accurate (eg investing contributions for defined contribution schemes).
Trustees should also “work flexibly” with their administrators “to support them in delivering core functions”, which “may include”:
• agreeing changes in operating procedures;
• holding higher than usual amounts in bank accounts;
• reducing the burden on administrators by limiting any non-critical demands and queries. TPR believes that trustees “should allow electronic signatures and documents and encourage other third-party providers to do the same (e.g. fund managers)”. The legal validity of electronic signatures has been endorsed in a recent statement from Government; however given the complexity of the issue, schemes should seek legal advice before taking this route. The guidance also notes that trustees should be “vigilant and make sure members are not rushed into any financial decisions. They might look to transfer their pension during this uncertain time and could be targeted by scammers.” For more information: https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider/scheme-administration-covid-19-guidance-for-trustees-and-public-service
New Issues – TPR guidance on communicating to members during COVID-19
On 29 April 2020, TPR published guidance on communicating to members during COVID-19. It is designed to help members avoid making hasty decisions during these uncertain times. The key points to note are:
• the guidance is primarily aimed at trustees, but TPR also expects it to be followed by anyone involved in preparing member communications (e.g. pensions managers and scheme administrators);
• “for the foreseeable future”, TPR is asking trustees to send DB members who request a CETV quote a template letter which sets out points they should consider before making a decision, and where they should go for impartial guidance. The template was prepared jointly by TPR, the FCA and TPAS;
• TPR recognises that trustees may tailor their approach for their situation and members. For more information (guidance): https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider/communicating-to-members-during-covid-19
For more information (template letter): https://www.thepensionsregulator.gov.uk/-/media/thepensionsregulator/files/import/pdf/cetv-members-letter.ashx
Integrity • Clarity • Simplicity 5
FEBRUARY 2020 TO APRIL 2020
New Issues – TPR 2020 Annual Funding Statement
On 30 April 2020, TPR published its annual funding statement, primarily aimed at schemes with valuation dates between 22 September 2019 and 21 September 2020 (“Tranche 15”) and schemes undergoing “significant changes that require a review of their funding and risk strategies”. Unsurprisingly, a key focus of the statement is the current pandemic. The statement stresses the need for trustees and employers to work together to manage the impact of COVID-19, balancing deficit recovery and equitable treatment of the scheme with the sustainable growth of the employer. However, TPR does not expect this to be at the expense of pension scheme security; schemes should also still be pursuing a long-term funding target, with suitable short-term modifications to reflect the current economic situation. The approach to risk management largely follows that of previous years, with schemes asked to identify which of 10 broad categories they fall into (taking into account both COVID-19 and Brexit) to identify their key risks and actions. TPR also provides an update on the timing of its revised DB funding code, with the deadline for responding to the first stage of a two-part consultation having been extended until 2 September 2020. This date will be kept under review. TPR confirms that the second stage of the consultation will now be published next year, and that it does not expect the new code to come into force “until late 2021 at the earliest”. For more information: https://www.thepensionsregulator.gov.uk/en/document-library/statements/annual-funding-statement-2020
New Issues – Updated TPR guidance on DC scheme management and investment
On 17 April 2020, TPR updated its Coronavirus guidance for trustees on DC scheme management and investment. The updates include a new section on employers wanting to reduce contributions to a DC scheme, which references the updated guidance for employers on this point and TPR’s recent easement for employers unable to consult fully in line with the usual requirements. It also adds a section on trustee involvement where an employer requests scheme rule changes to reduce contributions. This states that, if trustees have the sole or shared power to make the change, they will need to make sure that the decision “is in the best interests of the members”. This can include factoring in “the likelihood of the employer being able to continue as a going concern if they continue to pay the current rate of contributions”, but trustees should make sure they “are satisfied that this is a genuine risk and give thought to whether any change should be temporary”. For more information: https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider/dc-investment-and-transfer-values-covid-19-guidance-for-trustees
Integrity • Clarity • Simplicity 6
FEBRUARY 2020 TO APRIL 2020
New Issues – FCA expectations for wet-ink signatures in light of Coronavirus
On 20 April 2020, the FCA set out its expectations of firms when dealing with the need for ‘wet-ink’ signatures (i.e. signing a document by hand using a pen) in light of practical difficulties caused by Coronavirus. In relation to agreements, the guidance clarifies that FCA rules “do not explicitly require wet-ink signatures in agreements, nor do they prevent firms from using electronic signatures in agreements”. It notes that the validity of electronic signatures is a matter of law and recommends that firms take legal advice. It also reminds firms that they must consider any related requirements set out in the FCA’s principles for businesses and general rules. The guidance goes on to confirm that electronic signatures will be accepted for all interactions with the FCA, eg in completing FCA forms. For more information: https://www.fca.org.uk/news/statements/expectations-wet-ink-signatures-coronavirus-restrictions
New Issues – FCA updated guidance on Coronavirus
On 3 April 2020, the FCA updated its guidance on Coronavirus to cover issues relating to requirements to provide certain pensions information. The FCA recognises that some firms are “facing challenges” implementing new rules that change both the information given to consumers entering pension drawdown or taking an income for the first time and the annual information given to these customers. The FCA notes that these rules came into effect on 6 April 2020, and so it expects “firms to have implemented or be in the final phases of implementation”. However, the FCA understands that “firms may experience operational challenges in testing and finalising processes, particularly where they are reliant on third parties to complete this work”. Therefore, it appreciates that “a short delay in some firms’ implementation of the rules may be unavoidable”, though it expects firms to implement “as soon as reasonably practicable”. If this is later than 31 May 2020, firms should notify the FCA. For more information: https://www.fca.org.uk/firms/information-firms-coronavirus-covid-19-response#pensions
Integrity • Clarity • Simplicity 7
FEBRUARY 2020 TO APRIL 2020
New TPR guidance on Coronavirus
On 27 March 2020, TPR released three new sets of guidance for schemes on dealing with the Coronavirus pandemic: DC investment guidance for trustees This guidance on investment for trustees of DC schemes highlights the following key points:
• trustees should consider how individual members might react in the current environment to headline market/fund value falls or reduction/loss in earnings. Members could make inappropriate decisions, crystallise losses or be exploited by scams;
• trustees should review and manage specific risks that may now exist within their portfolios or with their service providers, for example in relation to sector exposures/concentrations in certain funds;
• trustees should review any previously agreed investment and risk management decisions to be implemented in the future. This is to ensure they remain appropriate, efficient and do not introduce risks or crystallise losses;
• trustees should review their investment governance structures and delegations to ensure they can continue to function and make decisions in the event of trustee incapacity or absence;
• trustees should assess, following the recent performance of their scheme, whether any changes to their governance framework or provider arrangements should be made at an opportune time.
DB scheme funding guidance for employers In this guidance, TPR acknowledges that this is an “extremely difficult time for many businesses”; however, it still expects trustees of DB schemes to be provided with regular updates on employer outlook and contingency planning. It also expects employers to “make all reasonable endeavours to provide trustees with the information that they need to assess the impact on the employer covenant and the affordability of deficit repair contributions”. TPR says that it “will be pragmatic in scenarios where trustees are being asked to agree to a previously unforeseen arrangement (such as DRC reductions or suspensions, or additional debt being secured over employer assets)”, provided that certain conditions are met, for example that the need for it can be justified and the scheme is being treated fairly compared with other stakeholders. The guidance also confirms that TPR’s annual funding statement will be published “after Easter 2020”. DB scheme funding and investment guidance for trustees This guidance covers a range of issues being raised by the pandemic for trustees of DB schemes, including:
• considerations for schemes completing their valuations now;
• dealing with employers’ requests for easements, such as requests to suspend or reduce deficit repair contributions, or to release security;
• steps trustees should be taking in relation to investments;
• considering transfer values, in particular the higher risk of pension scams. For more information (DC investment guidance for trustees): https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider/dc-investment-and-transfer-values-covid-19-guidance-for-trustees
For more information (DB scheme funding guidance for employers): https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider/db-scheme-funding-covid-19-guidance-for-employers
For more information (DB scheme funding and investment guidance for trustees): https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider/db-scheme-funding-and-investment-covid-19-guidance-for-trustees
Integrity • Clarity • Simplicity 8
FEBRUARY 2020 TO APRIL 2020
TPR updated guidance on Coronavirus and suspension of initiatives
On 20 March 2020, TPR published updated guidance for trustees, employers and administrators on dealing with the impact of Coronavirus. Key points are that:
• trustees, employers and administrators should focus their activities on the key risks to pension savers e.g. paying benefits, minimising the risk of scams, continuing employer contributions and supporting member decision-making. TPR notes that “some administrative breaches of the law may occur” and that it “will maintain a proportionate and fair approach” to any action taken;
• trustees are expected to: assess whether their business continuity plan is still adequate; contact their administrator/service provider about their contingency plans; make priorities clear in the event of under-resourcing. Trustees of DB schemes should also read the further guidance on corporate distress;
• the situation could lead to increased targeting by scammers, attempting to “lure” savers to a “safe haven”. TPR recommends that, if a saver asks about transferring their pension, trustees should “urge them to exercise extreme caution and visit ScamSmart which has specific guidance relating to COVID-19”. Trustees should also signpost their members to the Money and Pensions Service;
• administrators should “prioritise payments of benefits, retirement processing and bereavement services”. After this, they should focus on the processes needed “to ensure accurate benefits (e.g. investment of contributions)”;
• trustees and administrators should report to TPR immediately if they believe they will be unable to pay members’ benefits. Everything else should be reported as normal and TPR “will take a pragmatic approach” in its responses;
• for employers, TPR says it “will take a proportionate and risk-based approach towards enforcement decisions, in light of these challenging times, with the aim of helping to get employers back on track, and supporting both employers and savers”.
The guidance confirms that TPR is temporarily suspending its regulatory initiatives and will be in direct contact with those schemes affected, regarding expectations and next steps. It is also postponing the publication of its Corporate Plan, long-term strategy, and consultation on bringing together its codes of practice to form one single code. TPR will review timings of its DB funding consultation “in the coming weeks” and has cancelled or moved all scheduled events. For more information (updated guidance for trustee): https://www.thepensionsregulator.gov.uk/en/covid-19-an-update-for-trustees-employers-and-administrators
For more information (guidance on corporate distress): https://www.thepensionsregulator.gov.uk/en/covid-19-an-update-for-trustees-employers-and-administrators/guidance-for-db-scheme-trustees-whose-sponsoring-employers-are-in-corporate-distress
For more information (ScamSmart): https://www.fca.org.uk/scamsmart
For more information (Money and Pensions Service): https://moneyandpensionsservice.org.uk/
For more information (report to TPR – unable to pay benefits): https://www.thepensionsregulator.gov.uk/en/covid-19-an-update-for-trustees-employers-and-administrators#5cd21a3cf51d4b98b3c8e4d9fc1b4b66
For more information (regulatory initiatives): https://www.thepensionsregulator.gov.uk/en/about-us/how-we-regulate-and-enforce
Integrity • Clarity • Simplicity 9
FEBRUARY 2020 TO APRIL 2020
TPR statement for trustees on Coronavirus
On 12 March 2020, TPR published a statement on COVID-19 (Coronavirus) and what the trustees of pension schemes need to consider. TPR expects trustees to “have appropriate monitoring and contingency planning in place” and to “understand their service providers’ business continuity arrangements”. It also expects trustees to “establish which scheme activities would be prioritised in the event of under-resourcing”, and refers to its guidance on Integrated Risk Management to help trustees “to consider how best to respond to emerging issues based on their particular circumstances” , in particular in relation to funding. The statement also says that TPR is currently engaging with “key administrators to understand their current preparedness”. For more information (statement): https://www.thepensionsregulator.gov.uk/en/covid-19-coronavirus-what-you-need-to-consider
For more information (Integrated Risk Management): https://www.thepensionsregulator.gov.uk/en/document-library/regulatory-guidance/integrated-risk-management
PPF Coronavirus guidance and contingent asset requirement changes
On 18 March 2020, the PPF published guidance on its measures for responding to the impact of Coronavirus. This includes changes to its requirements for submitting contingent asset documents:
• documents should not be provided in hard copy, but should be emailed to [email protected] (instructions on e.g. file size are given);
• the PPF can’t formally approve extensions in advance, but it understands “that key individuals might not be able to finalise documents because they are unwell or in self-isolation” and, where documents are submitted after the deadline, it will “consider the circumstances” and “where it’s reasonable”, accept them. Reasons for late submission must be provided when documents are sent;
• on e-signatures, for PPF-specific documents, for example officer’s certificates, the PPF will accept “other forms of confirmation that the form is authorised, such as signatures produced by e-sign software”. For documents that are intended to have legally binding effect beyond the PPF-specific requirements, the PPF recommends that organisations speak to their legal advisors;
• to the extent that there are “known/expected impacts of COVID-19 that can be estimated”, these should be taken into account in assessing contingent assets and asset-backed securities in March 2020. However, “reflecting the material uncertainty over future economic impacts of the virus, and the impact that Government responses to it may have, there is no need to make further allowance for this general uncertainty. Reports should therefore indicate what assumptions have been made, rather than seeking to exclude consideration of COVID-19”.
For more information: https://ppf.co.uk/news/our-coronavirus-covid-19-preparation
Integrity • Clarity • Simplicity 10
FEBRUARY 2020 TO APRIL 2020
PLSA publishes COVID-19 resources
On 26 March 2020, the PLSA published resources to help schemes “deal with short-term issues and prepare for the longer-term effects” of the Coronavirus pandemic. The resources include “top tips for DB schemes and LGPS funds” and “top tips for DC schemes”, based on “best practice”. For more information: https://www.plsa.co.uk/Policy-and-Research-Covid-19-Resources
FCA guidance on Coronavirus
On 17 March 2020, the FCA published guidance for firms on responding to Coronavirus. The guidance states that the FCA “stands ready to take any steps necessary to ensure customers are protected and markets continue to function well”. The FCA expects firms “to be taking reasonable steps to ensure they are prepared to meet the challenges Coronavirus could pose to customers and staff, particularly through their business continuity plans”. Firms should report to them “immediately” if they believe they will be in difficulty. The guidance covers areas including regulatory change, impact on consumers, insurance products, operational resilience and market trading and reporting. It confirms that the FCA is reviewing its work plans so that it can “delay or postpone activity which is not critical to protecting consumers and market integrity in the short-term”, has extended the deadline for a number of consultation papers and calls for input until 1 October 2020, and will delay various publications which were due before the end of June 2020. The FCA also published guidance for insurance firms on 19 March 2020, setting out its expectations of insurers during the pandemic. For more information (guidance for firms): https://www.fca.org.uk/firms/information-firms-coronavirus-covid-19-response
For more information (guidance for insurance firms): https://www.fca.org.uk/firms/insurance-and-coronavirus-our-expectations
FRC guidance on Coronavirus
The FRC has published a range of guidance on the impact of Coronavirus on audits and corporate reporting. This includes guidance for auditors who may be facing practical difficulties in carrying out audits as a result of the pandemic. This states that audits “should continue to comply fully with required standards”. It acknowledges that in current circumstances additional time may be required to complete audits and “it is important that this is taken, even at the risk of delaying company reporting… In some cases, companies may need to reconsider their reporting deadlines”. For more information: https://www.frc.org.uk/about-the-frc/covid-19
Integrity • Clarity • Simplicity 11
FEBRUARY 2020 TO APRIL 2020
ICO guidance on Coronavirus
The ICO has published guidance on data protection in light of the Coronavirus pandemic. On 16 March 2020, it released general data protection advice for data controllers and a blog post. This guidance contains some reassurance for controllers concerned about data protection practices at this time. The ICO understands that “resources, whether they are finances or people, might be diverted away from usual compliance or information governance work”. The ICO states that it won’t penalise organisations that it knows “need to prioritise other areas or adapt their usual approach during this extraordinary period”. In relation to increased homeworking, the ICO comments that while data protection law doesn’t prevent the use of workers’ own devices or communications equipment, organisations will “need to consider the same kinds of security measures for homeworking” that would be applied in normal circumstances. The ICO also published a blog post aimed at the public on 18 March 2020, with information on some key concerns they may have about their personal data. The ICO has launched a new data protection and Coronavirus information hub. For more information (guidance): https://ico.org.uk/for-organisations/data-protection-and-coronavirus/
For more information (information hub): https://ico.org.uk/global/data-protection-and-coronavirus-information-hub/
GMP equalisation guidance – “when to rectify”
On 17 March 2020, the cross industry GMP Equalisation Working Group, issued its latest guidance: ‘When to Rectify’. This new guidance relates to making corrections as a result of GMP reconciliation, known as GMP rectification. It recommends steps trustees should undertake to ensure they make the right decision for their scheme. These include:
• understanding the data: the number of members requiring rectification and how this population overlaps with those in scope for GMP equalisation;
• understanding the nature and timing of the task: when to rectify benefits, the potential approaches available and how the rectification project dovetails with the work required for GMP equalisation;
• considering the impact on members who are in scope for GMP rectification of any delay whilst finalising the equalisation project;
• documenting and consider the scheme’s position: this focusses on the factors that will influence the decision about when to undertake rectification for those also impacted by equalisation.
For more information: https://www.pasa-uk.com/guidance/gmp-equalisation/gmp-rectification-march-2020-final-2/
Integrity • Clarity • Simplicity 12
FEBRUARY 2020 TO APRIL 2020
Budget day 2020
On 11 March 2020, the Chancellor, Rishi Sunak, delivered his first Budget. Key points for the pensions world included changes to the tapered Annual Allowance (AA) and a consultation published alongside the Budget on the possible reform of RPI. The tapered AA The AA restricts the amount of tax relief an individual can receive on their pensions savings in any given tax year, with some higher earners having also been subject to a tapered AA since 2016. In a move designed to “support the delivery of public services” (primarily, the NHS), the Budget announced that the two main tapered AA thresholds will each rise by £90,000 from the tax year 2020/21. This means that:
• threshold income will be set at £200,000, so individuals with income at or below that level will no longer be affected by the tapered AA, and
• the tapered AA will only kick in for individuals whose adjusted income is above £240,000. In addition, the upper boundary of the taper is set to be extended further, so that for those earning £312,000 and above, the tapered AA will be just £4,000 going forwards. HMRC has published a tax information and impact note, explaining the proposed changes and their impact. The RPI consultation The Government’s consultation on the future of RPI follows a recommendation by the UKSA that RPI should eventually stop being published but, in the interim, its “shortcomings…should be addressed by bringing the methods of” CPIH (CPI, including owner occupier’s housing costs) into it. The Government’s consent is required to make such changes before 2030. The Consultation looks at whether to implement the proposal at a date other than 2030 and, if so, when between 2025 and 2030. Other pensions-related announcements The Budget confirmed that:
• the LTA will increase in line with CPI for 2020/21, rising to £1,073,100;
• following a recommendation by the WPC last year, the Government will review an anomaly affecting lower paid workers whose pension schemes use a “net pay” arrangement. A call for evidence will be published “shortly”;
• funding will be provided which ensures individuals can derive or inherit a State Pension from an opposite-sex civil partner; and
• the Government will legislate to ensure that collective DC (“CDC”) schemes can operate as registered pension schemes for tax purposes, once permitted under the Pension Schemes Bill.
The Government also announced a review of the VAT charged on fund management fees and published a consultation on tax treatment of asset holding companies in alternative fund structures. For more information (budget): https://www.gov.uk/government/publications/budget-2020-documents/budget-2020
For more information (tapered AA): https://www.gov.uk/government/publications/pensions-tax-changes-to-income-thresholds-for-calculating-the-tapered-annual-allowance-from-6-april-2020/pensions-tax-changes-to-income-thresholds-for-calculating-the-tapered-annual-allowance-from-6-april-2020
For more information (RPI consultation): https://www.gov.uk/government/consultations/a-consultation-on-the-reform-to-retail-prices-index-rpi-methodology
Integrity • Clarity • Simplicity 13
FEBRUARY 2020 TO APRIL 2020
Companies House grants extension on company accounts
On 25 March 2020, it was announced that businesses will now be able to apply for a three-month extension for filing their accounts. As part of the agreed measures, while companies will still have to apply for the extension to be granted, those citing issues around COVID-19 “will be automatically and immediately granted an extension”. Applications can be made through a fast-tracked online system. For more information: https://www.gov.uk/guidance/apply-for-more-time-to-file-your-companys-accounts
Government statement that electronic signatures are valid
A ministerial statement was made on 3 March 2020 giving the Government’s response to the Law Commission’s report on electronic signatures. This statement agreed with the “report’s conclusion that formal primary legislation is not necessary to reinforce the legal validity of electronic signatures. The existing framework makes clear that businesses and individuals can feel confident in using e-signatures in commercial transactions”. It also agreed with the Law Commission’s recommendation that “an Industry Working Group should be established, which the Government should convene [because] there are issues on the security and technology of electronic signatures that require further consideration”. The Government also confirms that it will ask the Law Commission to undertake “a wider review of the law of deeds” (suggested in the Law Commission’s report) when time permits. For more information: https://www.parliament.uk/business/publications/written-questions-answers-statements/written-statement/Commons/2020-03-03/HCWS143/
Order made clarifying VAT exemption for management of pension funds
On 3 March 2020, the Value Added Tax (Finance) Order 2020 was made, extending the existing VAT exemption for the management of investment funds to the management of pension funds that satisfy certain conditions, and removing the current restriction on the type of assets that a close-ended collective investment undertaking can invest in for its management to qualify for exemption. Directly effective EU law already in place allows businesses to exempt their supplies of fund management services from VAT; this Order is intended to “provide certainty for businesses and be aligned with the majority of current practice in the sector” by bringing UK law into line with that overriding EU law. The Order comes into force on 1 April 2020. For more information: https://www.legislation.gov.uk/uksi/2020/209/contents/made
Integrity • Clarity • Simplicity 14
FEBRUARY 2020 TO APRIL 2020
PMI launches professional trustee accreditation programme
The PMI launched an accreditation programme for professional trustees on 13 February 2020. The “APTitude” programme was formed “following standards published by the Professional Trustee Standards Working Group (PTSWG) in 2019 to raise standards and provide assurance about the quality and skills of professional trustees and discourage poor practices in the industry”. The programme is open to all professional pension scheme trustees, who meet TPR’s description of a professional trustee. Applications may be made from 24 February 2020. For more information: https://www.pensions-pmi.org.uk/news-and-publications/pmi-launches-accreditation-programme-for-professional-trustees/
FCA Policy Statement on disclosing costs and charges to workplace pension scheme members
On 4 February 2020, the FCA published a Policy Statement setting out its final rules and guidance on requiring pension scheme governance bodies to report costs and charges information to members of workplace pension schemes and some amendments to its Conduct of Business Sourcebook (COBS) rules. This follows a consultation in February 2019. Since 3 January 2018, the FCA’s rules have required asset managers to report costs and charges information to the operator, trustee or manager of workplace pension schemes. This policy statement sets out rules requiring scheme governance bodies to disclose this information to scheme members on an ongoing basis. The amendments to the COBS rules address how asset managers must calculate transaction costs when reporting the costs and charges information. The changes are intended to address concerns raised by some industry stakeholders that the current methodology could lead to potentially misleading information. This policy statement will apply to those involved in FCA-regulated relevant schemes in the DC workplace pensions market. Firms will need to comply with the new rules from April 2020. For more information: https://www.fca.org.uk/publication/policy/ps20-02.pdf
Integrity • Clarity • Simplicity 15
FEBRUARY 2020 TO APRIL 2020
New Issues – PPF statement on COVID-19 impact on levy payers
On 28 April 2020, the PPF published a statement on the impact of COVID-19 on PPF levy payers. The statement is intended to “reassure” levy payers that the pandemic will have a “minimal impact” on the amount of levy the PPF expects to charge this autumn. The rules used to calculate the levy were fixed before the pandemic and, in calculating invoices, the PPF will be using information that was “largely collected before the economic impact of COVID-19 became significant”. The PPF confirms that, as in previous years, the highest levy they will ask an individual scheme to pay will be “0.5 per cent of its liabilities”. It also notes that the PPF is considering “all options” to find ways it can help schemes with the crisis, and will communicate any decisions “before invoicing starts”. For more information: https://www.ppf.co.uk/news/impact-covid-19-our-levy-payers
New Issues – Progress on professional trustee accreditation
On 27 April 2020, the Association of Professional Pension Trustees (“APPT”) announced that its accreditation process for professional pension trustees is “moving ahead despite the COVID-19 pandemic”, offering provisional accreditation until full accreditation can be assessed. This follows on from the PMI announcing the first fully accredited professional trustee under its accreditation process. For more information: https://appt.org.uk/appt-moves-ahead-with-provisional-accreditation-for-professional-trustees/
New Issues – ICO regulatory approach during the Coronavirus pandemic
On 15 April 2020, the ICO published a document setting out its regulatory approach during the Coronavirus pandemic. It states that the ICO is “committed to an empathetic and pragmatic approach”. Whilst continuing to recognise the rights and protections granted to people by the law, and taking firm action against those looking to exploit the public health emergency, it will focus its efforts on the most serious challenges and greatest threats to the public, and be flexible in its approach, taking into account the impact of the potential economic or resource burden its actions could place on organisations. The document examines these areas in further detail, noting the ICO’s Regulatory Action Policy and principles it will follow during this period. For more information: https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2020/04/how-we-will-regulate-during-coronavirus/
Integrity • Clarity • Simplicity 16
FEBRUARY 2020 TO APRIL 2020
New Issues – ESMA report on central clearing solutions for pension scheme arrangements
On 2 April 2020, ESMA published a first report for consultation on central clearing solutions for pension scheme arrangements (“PSAs”). Currently, PSAs benefit from a temporary exemption from the clearing obligation. That exemption, under the ‘EMIR refit’ regulation, lasts until 2021, with the possibility of two further one-year extensions. The extension goes “hand in hand” with the objective that “progress is made by the relevant stakeholders” in addressing the challenges to PSAs in clearing their OTC derivative contracts. The report “documents the progress made towards clearing solutions for PSAs” six months on from the entry into force of EMIR refit, including discussion of the different solutions envisaged so far. It also poses questions for public consultation, focused on possible solutions, “in preparation for the second report due in a year’s time and in order to get input from a wide range of stakeholders”. The consultation closes on 15 June 2020. For more information: https://www.esma.europa.eu/sites/default/files/library/esma70-151-2823_esma_report_to_the_european_commission_on_central_clearing_obligations_for_psa_-_no_1.pdf
PASA launches COVID-19 guidance for administrators
On 30 March 2020, PASA published guidance for administrators to “support administrators during the COVID-19 crisis”. This guidance discusses what administrators should prioritise, which PASA believes should be:
• ensuring sufficient funds are held to settle benefits and other scheme expenditure;
• maintaining evidenced accuracy for benefit calculations;
• keeping good records of any work in progress. It sets out some “basic enablers required when remote working to meet pension scheme priorities”, for example daily operations and leadership calls, and planning for the critical tasks of running pensioner payroll and settling benefits to ensure these continue uninterrupted. It also sets out “higher level enablers” to enable best practice. For more information: https://www.pasa-uk.com/covid-19/covid-19-guidance-for-administrators-march-2020-final/
BEIS committee launches inquiry on audit reform
The BEIS Committee has launched an inquiry on Delivering Audit Reform to “help map out a path for implementing meaningful reform of the UK’s audit industry”, following a series of inquiries from the BEIS Committee, the CMA, Sir Donald Brydon, and Sir John Kingman. The provisional target date for the submission of written evidence is currently advertised as 4 May 2020 but this will be kept under review and the Committee will continue to take evidence after this date for the inquiry. For more information: https://www.parliament.uk/business/committees/committees-a-z/commons-select/business-energy-industrial-strategy/news-parliament-2017/committee-launch-new-inquiry-19-21/
Integrity • Clarity • Simplicity 17
FEBRUARY 2020 TO APRIL 2020
Consultation on climate-related risk
On 12 March 2020, the DWP and Pensions Climate Risk Industry Group (“PCRIG”) published a consultation on new, non-statutory guidance for occupational pension schemes on assessing, managing and reporting climate-related risks. A quick start guide for trustees has also been published. The guidance is in line with recommendations by the Taskforce on Climate-Related Financial Disclosures (“TCFD”). Government has set the expectation that all listed companies and large asset owners, including occupational pension schemes, will disclose in line with TCFD by 2022. In addition, amendments made to the Pension Schemes Bill will, if passed, provide a power for the Government to require prescribed pension schemes to publish climate change related risk information and to impose requirements with a view to ensuring effective governance of those schemes with respect to the effects of climate change. The launch by Guy Opperman at the PLSA’s Investment Conference was welcomed by TPR. The consultation closes on 7 May 2020. For more information (consultation): https://getinvolved.dwp.gov.uk/05-policy-group/aligning-your-pension-scheme-with-the-tcfd-rec/
For more information (non-statutory guidance): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/871772/aligning-your-pension-scheme-with-the-TCFD-recommendations-consultation-guidance.pdf
For more information (quick start guide for trustees): https://www.gov.uk/government/consultations/aligning-your-pension-scheme-with-the-tcfd-recommendations/tcfd-for-trustees-of-pension-schemes-quick-start-guide
HMRC releases GMP equalisation tax guidance
On 20 February 2020, HMRC released long-awaited guidance (“the Guidance”) on some of the pensions tax issues arising when equalising benefits for the effect of GMPs. The Guidance focuses specifically on the so-called “dual record keeping methods” for achieving equalisation approved in the Lloyds case, covering the impact of GMP equalisation benefit adjustments on both the AA and LTA. HMRC makes clear that the Guidance “relates to benefit adjustments where the reason for the adjustment is solely for GMP equalisation” and that it “does not cover other benefit adjustments”. Taking a pragmatic approach, HMRC confirms that increased entitlements resulting from GMP equalisation will not generally constitute new accrual of benefits (requiring a test against the AA) in respect of deferred members. Similarly, benefit adjustments solely for GMP equalisation purposes should not prejudice applicable LTA protections. However, an adjustment may trigger a retest against the LTA in certain circumstances (e.g. for pensions in payment). The Guidance stops short of looking at some of the trickier areas, such as lump sum and death benefit payments, which HMRC says it will produce further guidance on “as soon as possible”. It also does not cover the pensions tax implications of reshaping benefits as part of a GMP conversion exercise, which HMRC says it will “continue to explore”. For more information: https://www.gov.uk/government/publications/guaranteed-minimum-pension-gmp-equalisation-newsletter-february-2020/guaranteed-minimum-pension-gmp-equalisation-newsletter-february-2020
Integrity • Clarity • Simplicity 18
FEBRUARY 2020 TO APRIL 2020
TPR publishes first part of consultation on revised code for scheme funding
On 3 March 2020, TPR published the first stage of a “major” consultation on its revised code of practice for DB funding. This first consultation sets out TPR’s initial proposals for a “clearer, more readily enforceable funding framework, which implements the new requirements set out in the Pension Schemes Bill”. As the consultation document is lengthy (running to 175 pages), TPR also issued a shorter companion guide alongside it. Under the proposals, trustees will be able to choose either a “Fast Track” or a “Bespoke” approach to completing and submitting their scheme valuation. As the more straightforward (and prescriptive) approach, the Fast Track will only be available to schemes whose valuation meets certain guidelines. TPR does not expect its “new proposed approach to be too onerous for most schemes to implement” but appreciates that “there could be significant impact for some schemes, particularly those that have been running excessive and unjustifiable levels of risk”. At this stage, TPR anticipates that “the final code will be shorter and more focused, simply outlining the twin-track compliance structure, proposed Fast Track parameters and the principles for those following Bespoke”. The second stage of the consultation, on the draft funding code itself, is scheduled for the end of the year. The first stage consultation closes on 2 June 2020. For more information (code of practice): https://www.thepensionsregulator.gov.uk/en/document-library/consultations/defined-benefit-funding-code-of-practice-consultation
For more information (companion guide): https://www.thepensionsregulator.gov.uk/-/media/thepensionsregulator/files/import/pdf/quick-guide-db-funding-consultation.ashx
Pension Schemes Bill – proposed climate change amendments
Amendments have been proposed to the Pension Schemes Bill (“the Bill”) published earlier this year. The proposed changes, amongst other things, include the power for regulations to “impose requirements on the trustees or managers of an occupational pension scheme of a prescribed description with a view to securing that there is effective governance of the scheme with respect to the effects of climate change”. These requirements could include reviewing the exposure of the scheme to climate change risks, determining a strategy for managing the scheme’s exposure and publishing information relating to the effects of climate change on the scheme. The committee stage (line by line examination) of the Bill’s progress through Parliament is scheduled to begin on 24 February 2020. For more information: https://publications.parliament.uk/pa/bills/lbill/58-01/004/5801004(i).pdf
Integrity • Clarity • Simplicity 19
FEBRUARY 2020 TO APRIL 2020
TPR responds to DWP letter on climate change
On 28 February 2020, TPR published its response to the DWP’s letter on climate change. The response acknowledges that TPR “has an important role to play to ensure that those that advise or manage pension schemes clearly understand the nature of the challenge and furthermore have the appropriate processes and mitigations in place in respect of climate change”. It states that TPR is developing a “strategy for dealing with the financial risks arising from climate change” and that it is “working alongside DWP colleagues, Government and industry bodies on guidance that will help trustees identify, assess and disclose their scheme’s exposure to climate risk…which is based on the framework of the Taskforce on Climate-related Financial Disclosures (TCFD)”. For more information: https://www.gov.uk/government/publications/climate-change-risks-and-opportunities
TPR response to future of trusteeship and governance consultation
On 10 February 2020, TPR published the response to its consultation on the future of trusteeship and governance. TPR now intends to review and update its Trustee Knowledge and Understanding code of practice and the Trustee toolkit to make its expectations clearer and to drive up standards of trusteeship. Once the new standards are in place, TPR plans to run a regulatory initiative to test levels of TKU, and to consider appropriate action where they fall below expectations. On diversity, TPR states that it will establish and lead an industry working group to find ways of supporting schemes to take steps to improve trustee board diversity. The consultation asked if it should it be mandatory for pension scheme boards to engage a professional trustee and if governance standards for sole trustees should be strengthened. In both areas, TPR will not immediately push for new measures but will instead support the The Association of Professional Pension Trustees (APPT’s) standards and the upcoming industry accreditation framework for professional trustees. TPR are also supportive of APPT’s intention to develop an industry code for sole trusteeship. On consolidation in the DC market, TPR states it will “continue to monitor DC consolidation activity” and work with both industry and the DWP to find solutions “to overcome barriers to consolidation”. It will not take a “blanket approach” to consolidation. If a scheme is well run and can demonstrate that it is offering value for members, TPR would not “push the trustees to consider consolidation”. For more information: https://www.thepensionsregulator.gov.uk/-/media/thepensionsregulator/files/import/pdf/future-trusteeship-governance-consultation-response-february-2020.ashx
Integrity • Clarity • Simplicity 20
FEBRUARY 2020 TO APRIL 2020
TPR guidance on preparation for future EU relationship
TPR has provided updated guidance for DB schemes and DC schemes on how to prepare for the end of the transition period, which came into effect on the withdrawal of the UK from the EU and is due to end on 31 December 2020. The guidance states that TPR expects trustees to focus on the following areas (and provides an explanation of what it expects trustees to consider for each area), as well as any other scheme-specific issues:
• investment
• employer covenant (DB schemes only)
• operations and administration and
• member communications. For more information (DB schemes): https://www.thepensionsregulator.gov.uk/en/trustees/managing-db-benefits/prepare-your-db-scheme-for-brexit
For more information (DC schemes): https://www.thepensionsregulator.gov.uk/en/trustees/managing-dc-benefits/prepare-your-dc-scheme-for-brexit
New Issues – PPI briefing note: the pensions implications of COVID-19
On 30 April 2020, the PPI published a briefing note on the impact that COVID-19 “may have on pensions now and in the future”. It explores “likely impacts” in terms of:
• stock market volatility and its effects on DC pot sizes and DB scheme sponsors’ ability to deliver on member promises;
• employment and the Government Job Retention Scheme (GJRS);
• the effects on different age groups. For more information: https://www.pensionspolicyinstitute.org.uk/media/3479/20200430-bn-120-the-pensions-implications-of-covid-19.pdf
New Issues – TPR blog on protecting savers
On 15 April 2020, TPR published a blog on how “we can protect savers by working together”. The blog refers to guidance from TPR and other regulators on “the heightened risk of members being targeted by scammers during the pandemic”. It also discusses pension transfers, reassuring trustees of DB schemes that “they’ll have the time they need to deal with cash equivalent transfer value (CETV) requests, whether because they need to reassess how transfers are calculated or because they need to prioritise pension and bereavement payments”. It refers to the easement granted for trustees who suspend CETV quotations and states that “now industry must step up and protect savers using every possible means”. TPR also refers to the FCA’s guidance for pensions providers on requirements where savers are looking to access their pensions and “urges” all providers and trustees to use that guidance. For more information: https://blog.thepensionsregulator.gov.uk/2020/04/15/we-can-protect-savers-by-working-together/
Integrity • Clarity • Simplicity 21
FEBRUARY 2020 TO APRIL 2020
New Issues – Scams guidance from TPR and the PPF
TPR has published updated guidance on avoiding pension scams. The guidance explains how pension scams work and what the warning signs of a scam are. It then goes on to set out steps for trustees, business advisers and employers to take to help avoid pension savers falling for a scam. The advice includes a note that, due to Coronavirus, savers “might increasingly look to transfer their pension, prompted by the instability of their employer or the financial markets”. This means they “could be increasingly targeted by scammers attempting to lure them to ‘safe havens’”. If a saver asks about transferring their pension, TPR states that they should be urged to “exercise extreme caution and visit ScamSmart which has specific guidance relating to COVID-19”. Separately, the PPF has issued guidance for its members on how to avoid scams. This includes an explanation of various types of scams, advice on how to spot fraudulent communications and how members can protect themselves. For more information (TPR guidance): https://www.thepensionsregulator.gov.uk/en/pension-scams
For more information (PPF guidance): https://www.ppf.co.uk/news/how-avoid-fraudulent-scams
New Issues – Guidance on good practice for virtual board and committee meetings and new legislation on AGMs
The Chartered Governance Institute (“ICSA”) has published guidance on “what constitutes good practice in the conduct of virtual board and committee meetings”, which aims to help companies struggling with the impact of COVID-19. The purpose of the guidance is to “offer a brief guide to the practical and legal issues that need consideration, and to offer insight into how virtual meetings can be made as effective as possible”. Key points covered in the guidance are:
• choosing the right technology and communication channel;
• structuring virtual meetings and avoiding complexity;
• the value of preparation;
• establishing ground rules for the meeting;
• clear instructions on accessing the meeting;
• the necessity for good boardroom practices. Separately, the Business Secretary has announced that the Government will introduce legislation to ensure that those companies required by law to hold Annual General Meetings (AGMs) will be able to do so “safely, consistent with the restrictions on movement and gatherings introduced to address the spread of Coronavirus”. Companies will “temporarily be extended greater flexibilities, including holding AGMs online or postponing the meetings”. For more information (guidance on meetings): https://www.icsa.org.uk/assets/files/pdfs/guidance/good-practice-for-virtual-board-and-committee-meetings-web1-002(1).pdf
For more information (AGM announcement): https://www.gov.uk/government/news/regulations-temporarily-suspended-to-fast-track-supplies-of-ppe-to-nhs-staff-and-protect-companies-hit-by-covid-19
Integrity • Clarity • Simplicity 22
FEBRUARY 2020 TO APRIL 2020
PASA announces new cybercrime and fraud working group
PASA has launched a new working group focussed on cybercrime and fraud. The working group will include representatives from a variety of pensions administrators as well as those with a range of related professional skills. Chair of the group, Jim Gee, commented “fraud and cybercrime threaten the value of pensions at a time of life when sources of income become more limited and the chances of financial recovery diminish. Our aim is to develop clear practical standards which can help pensions administrators to protect themselves and the scheme members who rely on them”. For more information: https://www.pasa-uk.com/pasa-announces-crowe-uk-as-expert-partner-for-cybercrime-and-fraud/
EIOPA publishes model pension benefit statements
On 27 March 2020, EIOPA published two model pension benefit statements for DC schemes to provide “practical guidance on how to implement the annual information document that IORPs are required to send to their members following the implementation of the IORP II Directive”. The models were developed “in line with the principles identified by EIOPA in its Report on the IORP II Pension Benefit Statement”. EIOPA notes that the models are voluntary and may be further developed and adapted to the national specificities and/or characteristics of each pension scheme. For more information: https://www.eiopa.europa.eu/content/model-iorp-ii-pension-benefit-statement
PLSA publishes updated Stewardship Guide and Voting Guidelines
The PLSA published its updated annual Stewardship Guide and Voting Guidelines on 21 February 2020. The updated documents offer “practical guidance for schemes in acting as good stewards of their assets, including how to exercise votes on key issues of concern during AGM season”. The PLSA states that the 2020 version has “been extensively updated to better support schemes in light of disclosure requirements on stewardship, and to help them hold their managers and service providers to account”. The Guide includes a “toughened-up section” on climate change, with the PLSA commenting that “pension fund investors must be prepared to hold the directors of the companies in which they invest individually accountable on how well they manage climate change risks”. Following findings in the PLSA’s recent AGM Voting Review, that executive remuneration remains “one of the largest sources of shareholder discontent”, the updated Voting Guidelines also urge investors to consider executive pension contributions, which the PLSA says should be in line with percentages applied to the overall workforce. For more information: https://www.plsa.co.uk/Policy-and-Research/Document-library/PLSA-Stewardship-Guide-and-Voting-Guidelines-2020
Integrity • Clarity • Simplicity 23
FEBRUARY 2020 TO APRIL 2020
General levy increase revoked
On 27 March 2020, the DWP published an update in respect of its consultation on the Occupational and Personal Pension Schemes (General Levy) review 2019. The general levy on occupational and personal pension schemes recovers the funding provided by the DWP in respect of the core activities of TPR, the activities of TPO, and part of the activities of MAPS. Following consultation with industry in autumn 2019, the Government made regulations that were due to increase the general levy with effect from 1 April 2020. The Government has now laid regulations to revoke these Regulations “given the unprecedented circumstances following the Coronavirus (COVID-19) outbreak”. The levy rates will, therefore, not increase on 1 April 2020. The Government “will now focus on reviewing the structure of the levy and will be engaging with industry over the course of the next few months”. For more information: http://www.legislation.gov.uk/uksi/2020/355/introduction/made
PPF guidance on trustee contingency planning
On 17 March 2020, the PPF released guidance for trustees on contingency planning. The guidance advocates contingency planning “to think through what challenges might surface should there be an issue with the employer”. It recommends doing this thinking “while the employer is stable, and having articulated procedures and responses to issues in advance”. It sets out suggested steps for contingency planning, depending on the strength of the employer covenant, and a checklist of key points for trustees to make sure they have in place. For more information: https://www.ppf.co.uk/news/how-trustees-can-prepare-unexpected
PLSA guidance on diversity and inclusion
On 13 March 2020, the PLSA published guidance on diversity and inclusion aimed at trustees of occupational pension schemes. The guidance “introduces some of the concepts and good practice associated with diversity and inclusion (“D&I”)”, including:
• what D&I means;
• a summary of the benefits of D&I; and
• some practical steps for trustee boards to help promote greater inclusivity. For more information: https://www.plsa.co.uk/Portals/0/Documents/Made-Simple-Guides/2020/Diversity-and-Inclusion-Made-Simple.pdf
FCA updates guidance on how to avoid pension scams
The FCA updated its guidance on how to avoid pension scams on 28 February 2020. The guidance now gives extra information on how scam schemes work and on identifying scams. For more information: https://www.fca.org.uk/scamsmart/how-avoid-pension-scams
Integrity • Clarity • Simplicity 24
FEBRUARY 2020 TO APRIL 2020
TPR blogs on “positive change” in 2020 and diversity
TPR published a blog on 10 February 2020: “2020 will be a year of positive change”. The blog includes discussion of:
• the consultation on a revised DB funding code (due in March)
• TPR’s plans to “continue to work closely with the DWP, the Pension Protection Fund (PPF) and other regulators on an authorisation and supervision framework” for “DB superfunds”
• TPR’s launch (later this year) of a “long-term strategy to consider the future shape and needs of the pensions landscape” and
• the implementation reports required from October 2020. TPR released another blog on 13 February 2020 entitled “Breaking down barriers to create diverse boards of trustees”. This follows on from TPR’s response to its Future of Trusteeship and Governance consultation, which said that TPR will establish and lead an industry working group to find ways of supporting schemes with making improvements to trustee diversity. The blog describes research which “points to the fact that diverse groups achieve better decisions through debate and challenge”. It then goes on to discuss unconscious bias, role models, changing diversity and inclusion and the industry working group being established. TPR encourages anyone wishing to take part in the industry group to contact it by 29 February 2020. For more information (2020 will be a year of positive change): https://blog.thepensionsregulator.gov.uk/2020/02/10/2020-will-be-a-year-of-positive-change/?_ga=2.266761102.1874859852.1581871610-1216560619.1572888222
For more information (Breaking down barriers to create diverse boards of trustees): https://blog.thepensionsregulator.gov.uk/2020/02/13/breaking-down-barriers-to-create-diverse-boards-of-trustees/?_ga=2.135228465.184685712.1581526309-1216560619.1572888222https://blog.thepensionsregulator.gov.uk/2020/02/13/breaking-down-barriers-to-create-diverse-boards-of-trustees/?_ga=2.135228465.184685712.1581526309-1216560619.1572888222
TPR blog on pension scams
TPR issued a blog on 6 February 2020 entitled “PSIG needs you to help beat pension scams”. The blog outlines a research study being undertaken by the Pension Scams Industry Group (“PSIG”) and the Police Foundation, to “help [them] to further understand pension scams”. The study “looks at the action industry is taking to protect pension scheme members and will also provide valuable views on where resources should be focused in future” and TPR is encouraging all schemes to participate. The survey will be open until 14 February 2020. The blog also discusses PSIG’s initiative on sharing intelligence. Their aim is to “build a system where PSIG members can see intelligence from other members without having to reinvent the same wheel time and again”. For more information: https://blog.thepensionsregulator.gov.uk/2020/02/06/psig-needs-you-to-help-beat-pension-scams/?_ga=2.241034118.440294895.1581337850-1216560619.1572888222
Integrity • Clarity • Simplicity 25
FEBRUARY 2020 TO APRIL 2020
TPR spot checks on large employers
On 5 February 2020, TPR announced that it is carrying out spot checks on “a number of large employers who were among the first required to comply with automatic enrolment when the roll-out started in 2012. The short notice inspections, which started in January this year, will continue in the coming months”. The announcement says that TPR will use information gathered from the inspections “to identify any common themes and lessons to be learned”. For more information: https://www.thepensionsregulator.gov.uk/en/media-hub/press-releases/2020-press-releases/spot-checks-on-large-employers-to-protect-savers
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