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Code of Practice 13/ DC Regulatory Guidance
Agenda
Background
Code of Practice 13 v. DC Regulatory Guidance
DC Focus areas
Action: Timeline
2
Private and Confidential3
• Consultant & Client
Manager
• Spence & Partners
Limited
• Founding representative
on DC Governance
Committee
• Experienced in historic
and recent Trust based DC
pension reviews
Chris Roberts
Introduction
Confidential: internal use only 4
Background
Auto Enrolment: the starting gun (and we haven’t finished yet!)
Plethora of Consultations / guidance notes
Particular TPR concern around smaller schemes governance
2010 - Investment Governance Group: 6 DC investment principles
‘Good Member Outcomes’
Significant increase expected in DC scheme members placing Trustees under spotlight
DC modules added to Trustee Toolkit
Background
Private and confidential
Code of Practice 13 v. DC Regulatory Guidance
Private and confidential 6
Code of Practice 13 v. DC Regulatory Guidance
Private and confidential
Both
Effective 21.11.13
Applicable to Trustees of:• DC schemes, including those
with DB underpin• DC sections within DB trust• AVC arrangements
Help deliver Good Member Outcomes
Code of Practice
Draws on TKU / Internal Controls CoPs
23 Quality Features across 5 core governance areas
Quality Features: linked to pension legislation
Structure: legal requirements / practical guidance
No penalty for non-compliance, but...
Regulatory Guidance
Read in conjunction with CoP 13 - greater DC focus
9 Quality Features across 4 core governance areas (2 from CoP)
Quality Features: those reflecting ‘good practice’
Structure: best practice guidance / occasional reference
to legal requirements
DC focus areas
Private and Confidential
• Investment (CoP/RG)
• Governance (RG)
• Administration (CoP/ RG)
• Member communications (RG)
DC focus areas
Private and Confidential
(i) ‘Set investment objectives; default strategy’
• Identify / document each fund’s investment objective
• Fund options and default meet needs of actives and deferreds
• Review investment objectives for each fund options
Investment (CoP 12 OF; RG1 QF; 70 paragraphs
Private and Confidential
(ii) ‘security / liquidity of scheme assets’
• Assets traded on regulated markets
• Understand financial protections for members (e.g. FSCS)
• Mitigate impact of business / commercial risks on members
Investment (Contd.)
Private and Confidential
(iii) ‘monitor / review default strategy and fund performance’
• Performance / ongoing suitability
• Agree triggers for review
• New DC investment products
• Changing membership profiles
• Changing regulatory requirements
Investment (Contd.)
Private and Confidential
(iv) ‘communication with members’
• Regular communication re. member’s investment strategy and
implications
Investment (Contd.)
Private and Confidential
Governance
(i) ‘ensure members receive value for money’ (VFM)
• 4 Step VFM review:
• Collect information (benefits and costs of membership)
• Criteria for assessing VFM
• Compare criteria with other schemes
• Evaluate and act
Private and Confidential
Governance (contd.)
(ii) ‘transparency of costs and charges’
• Clearly disclosed to members
• Clearly disclosed to employer at point of product selection
(iii) ‘contribution levels’
• Offer flexible contribution structures
• Advise members of impact of contribution level on pension
pot/ ability to pay more, etc.
• Monitor efficiency of contribution amendment process
Private and Confidential
Administration
(i) ‘Focus on internal controls given particular risks in DC schemes’
• Provision of SMPI
• Review lifestyling mechanics
• Review contributions and investments
• Maintenance of Payment Schedule
Private and Confidential
Administration (contd.)
(ii) ‘establish robust retirement process’
• Help members optimise income at retirement
• Options clearly communicated so as to support member in
selecting most appropriate option
• Any insurer drafted communications to be compliant with ABI
Code of Conduct on retirement choices
• Information regarding appointment of advisor / annuity broker
• 5 Stage Retirement Process suggested
Private and Confidential
Member communications
• Improve retirement outcomes through communications which are:
• Accurate
• Clear
• Understandable
• Engaging
Actions: timeline
Actions: timeline
Private and confidential
Now
• Plan in place to deliver governance statement y/e after 31.12.14
Autumn 2014• Secondary
legislation confirms new quality / charges measures – awareness of potential further compliance actions required
During 2015• Governance
statement to be published
April 2015• New
governance standards go live
• Qualifying Scheme default fund 0.75% charge cap (so AVC arrangements not affected)
??
• CoP / RG to be updated
2017
• Charge cap review