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The Association of Consulting Actuaries (ACA) in our response to the DWP consultation on Occupational Pension Schemes (Collective Money Purchase Schemes) Regulations 2021 has said it is essential that CDC scheme designs incorporating age related accrual rates and age-related contribution rates (in a single section) are clearly allowed under the initial regulations as it is expected sponsors will favour such a design. “Soundness” too in the assessment of such schemes needs to be defined better. |
ACA Chair, Patrick Bloomfield, comments: “It is essential that CDC scheme designs incorporating age related accrual rates and age-related contribution rates (in a single section) are clearly allowed under the initial regulations. We expect this sort of design to be particularly popular with potential scheme sponsors “The draft requirements are extensive and will need significant resources, expertise, and appetite for CDC - this might deter employers without such resources from setting up a CDC scheme “Although "soundness" is a key concept in the assessment of such schemes, there is no definition provided and the proposed structure of assessing soundness requires the actuary to consider legal matters and accuracy of member communication, in addition to actuarial issues”
The ACA response also suggests that the provisions allowing for post valuation experience be removed – and if they are retained changes are essential. |
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