Consultations & Publications


The SPP supports the Government’s efforts to legislate for the introduction of Collective Defined Contribution (CDC) legislation for multi-employer and master trust arrangements. However, we urge the Government to revisit a small number of areas that could be improved. For example, in relation to promotion and marketing activities; the potential to inadvertently transition between the connected and unconnected employer regimes; and the proposed constraints on changes in investment strategy, with the associated requirement to sectionalise.

This SPP response explains that the PPF continues to levy £100m annually from the pensions industry which it readily admits it does not expect to ever need given it has a multi-billion pound surplus. Existing legislation prevents any future increases beyond 25% but the levy could be immediately reduced to zero whilst legislative change is sought (either now or in the future).

The SPP supports many of the proposals being put forward within this consultation and the overarching objective of improving Value for Money but is concerned about the volume of data that the proposed framework will require providers to collect and communicate, which in some cases appears disproportionate. There are many improvements that could be made to these proposals, as we have sought to constructively explain in this response.

Amongst other productive finance issues, this response highlights that the SPP agrees that scale can deliver improved investment but that there are risks, which must be guarded against; that legislative change is necessary to better facilitate consolidation and that for the LGPS, asset pooling has been successful but there is more to do. Read on for further information...

The SPP welcomes the desire to make returning surpluses to employers easier for those that wish to but the proposals are not without risk; we have serious reservations about the implementation of a 100% underpin from the Pension Protection Fund (PPF); and whilst a public sector consolidator has many potential benefits, the precise rationale for such a consolidator remains unclear.

The SPP believes that much of the information requested by TPR in the Statement of Strategy is pragmatic and supports the use of a standard template. However, TPR should consider making changes that better reflect the needs of particular types of scheme and requesting less information.