SPP


The SPP supports the overall direction of proposed changes to Technical Actuarial Standard 310 (TAS 310) covering actuarial work for collective defined contribution (CDC) pensions.

However, it is important that the standards remain principles-based and proportionate, allowing actuaries to exercise professional judgement while ensuring that key issues such as cross-subsidies, assumptions and scheme sustainability are clearly communicated.

This SPP response sets out its support for aligning the 2015 CARE scheme revaluation date of 1 April, with the start of the tax year (6 April) for the purposes of revaluing active members pensions.

This is because it will align the revaluation date with the tax year, simplify administration, improve consistency between tax and pension calculations, and remove an unnecessary misalignment in the current framework.

However, it will have administrative and communication implications and we therefore recommend its implementation be delayed until 2028/29.

This SPP response to the FCA consultation on ESG ratings welcomes their objective of enhancing transparency and providing robust reliable ratings and minimum disclosures for ESG rating providers.

However, the SPP warn of possible practical challenges that will require further consideration including the impact on smaller providers, access to data as well as legal and governance concerns.

This response sets out SPP's views on proposals designed to ensure that trusteeship, governance and administration standards keep pace with the evolving pensions landscape.

The SPP response emphasises that the UK’s current trusteeship framework is working well for the vast majority of members, delivering secure benefits and governance standards that are proportionate to scheme size and complexity.

This response sets out SPP's views on TPR's draft code of practice that will amend the existing CDC code which applies to single and connected employer CDC schemes (‘single-employer CDC schemes’).

Whilst expressing support for TPR’s intention to move towards a single code of practice, the SPP provides a number of comments intended to improve the code of practice and support its effective implementation.

The potential of Collective Defined Contribution (CDC) pension schemes is generating widespread interest across the pensions industry.

This SPP paper provides clear, actionable insights on the practicalities of administration, cost management, and governance for CDC schemes, setting out how these can be delivered in a way that makes CDC accessible, resilient, and trustworthy for both employers and savers.

The SPP recognises that a sustainable LGPS is in the best interests of scheme members, employers and local taxpayers and so has provided a range of technical comments that should prove helpful in ensuring that government policy intentions are met and that unintended consequences are minimised.

This response acknowledges that there are arguments for and against Retirement CDC schemes being made available in the retail environment; strongly supports the introduction of a ‘cohorting’ approach; and agrees that there is a strong case for a charge cap to be introduced.

If the Government introduces their Guided Retirement requirements on DC schemes in advance of Retirement CDC being made available, schemes may not have much appetite to revisit their Guided Retirement options in the short term. This could represent a substantial missed opportunity.

This paper examines issues relating to pre-1997 indexation in DB pension schemes including the costs of protection, scheme member perspectives, trustee duties and considerations for employers.

It also highlights some of the issues with a proposed across the board legislative change and comments on various potential solutions – including the possibility of discretionary payments.