Pensions Weekly Update – 7 December 2022

Authors:

Here is our weekly summary of key legal and regulatory developments relevant to occupational pension schemes that you might have missed, with links for further information.

The Pensions Dashboards Programme (PDP) has published a consultation on the design standards that will set out how information will be presented on pensions dashboards. The consultation will run until 16 February 2023. The PDP is aiming to publish the final version of the design standards “in or around summer 2023”, at the same time as the Financial Conduct Authority (FCA) finalises its regulatory framework for pensions dashboard service firms. The proposed design standards will be of interest to trustees of pension schemes seeking to understand how the information that they provide to pensions dashboards will be communicated to the relevant members of their schemes.
The FCA will be responsible for regulating commercial bodies that operate pensions dashboard services. It has published a consultation on the proposed regulatory framework for pensions dashboard service firms that will underpin this new role, explaining that a robust regulatory framework is needed to “ensure this new market does not introduce or amplify the potential for consumer harm”. The PDP’s design standards are intended to complement the FCA’s regulatory framework. Respondents to the PDP’s consultation on design standards are, therefore, encouraged to also read the FCA’s consultation. The FCA’s consultation will run until 16 February 2023.
The Pensions Regulator (TPR) has published a guidance statement for trustees of defined benefit (DB) schemes and their advisers setting out recommended actions in light of recent events in gilts markets. This follows on from TPR's October guidance, which we considered in our weekly update of 19 October 2022. The recommended actions aim to achieve and maintain an appropriate level of resilience in leveraged liability-driven investment funds and to improve operational governance of pension schemes. Trustees of DB schemes should consider TPR's recommended steps, speak to advisers and assess what action should be taken. Note that if trustees establish a line of credit with their sponsoring employer to ensure liquidity, the arrangement should be clearly documented and legally reviewed.
The Pension Protection Fund (PPF) has published its Purple Book 2022, which contains an interesting insight into the schemes within the PPF universe. The purple book covers data from all 5,131 DB schemes eligible for PPF compensation. As was the case last year, the book adopts a user-friendly interactive approach, allowing the user to search and collate results in different formats.

If you would like specific advice on any of these issues, or on anything else, please contact a member of our Pensions team.