Pensions: DC trustee agenda update - for August 2022 meetings

Allen & Overy LLP

Allen & Overy LLP

Welcome to our monthly update on current legal issues, designed to help you stay up to date with key developments between trustee meetings, and to support the legal update item on your next trustee agenda.

Dashboards developments (new)

The pace of work towards the introduction of pensions dashboards is increasing: the government has published a response to its consultation on the dashboards regulations (read more), a summary of dashboards policies (read more) and a further consultation (read more). The Pensions Dashboards Programme is consulting on the standards schemes will need to meet: read more.

The Pensions Regulator (TPR) has published initial guidance on complying with dashboards requirements: read more.

ACTION: Ensure your scheme is taking steps to meet the requirements in the regulations and standards, taking TPR’s guidance into account.

TPR transfers guidance (new)

TPR has updated its transfers guidance in relation to transfers being prevented where they trigger a flag because they involve overseas investments or small-scale incentives (in particular, ‘refer-a-friend’ rewards). Among other things, the guidance encourages trustees to consider whether non‑statutory transfers should be considered where a statutory transfer is prevented. Read more.

ACTION: Consider whether your transfer processes should be updated to reflect this guidance.

TCFD reporting requirements and SIP/implementation statement guidance

Schemes in scope for TCFD reporting requirements (including GBP1bn+ schemes in the second wave of the rollout) will have to include ‘Paris alignment’ reporting from 1 October 2022 for scheme years ending after that date. The government has produced updated statutory guidance to reflect these new requirements.

The government has also updated its guidance on reporting in statements of investment principles (SIPs) and implementation statements, to provide greater clarity on stewardship. Compliance with statutory elements of the guidance is required for scheme years ending on or after 1 October 2022. Read more.

ACTION: Discuss the new requirements and guidance with your investment advisers.

TPR guidance: reporting pension scams

TPR has published a guide on reporting pension scams, including when to report, what information to provide and what will happen next. Read more.

ACTION: Make sure your scheme has processes in place for reporting suspicions of scams in line with the new guide.

Regulations on investment consultancy (IC) and fiduciary management (FM) (updated)

Regulations on strategic objectives for IC providers and competitive tenders for FM services will come into force on 1 October 2022. They largely replicate the existing requirements, but there are some changes to be aware of: read more.

ACTION: Check whether your IC/FM arrangements are impacted by the new rules.

Watch this space

  • TPR has consulted on its proposed single code of practice: watch our webinar on the proposals and read TPR’s interim response. On timing, TPR’s recent corporate plan states only that the Code will be published ‘during 2022’.
  • A revised code on transfers, and other materials from the Pension Scams Industry Group, are expected imminently.
  • TPR will be launching a joint consultation with the Financial Conduct Authority (FCA) and DWP on a Value for Money Framework by the end of the year.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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