The PPF has found that trustees who plan for employer distress are more likely to provide a better experience for members at what may be a worrying time. The PPF often sees schemes entering PPF assessment where this planning has not taken place, so has published ‘Contingency planning for employer insolvency’ to support trustees in being better prepared.
For example, the PPF has seen in-house pensioner payrolls put at risk because the employer has entered insolvency without warning and the trustee has lost access to the premises, along with the IT, finance and banking functions. In more than 10 per cent of cases in recent years the PPF has had to step in to ensure pensioners were paid.
Sue Rivas, Director of Scheme Services at the PPF said: “The guidance we’ve published today gives information about the simple but effective steps we recommend trustees put in place to mitigate some of the risks resulting from employer distress, particularly those areas which affect members and risk delaying completion of a PPF assessment period. We know that running a pension scheme is challenging, and as this guidance makes clear, we are here to help.”
David Fairs, Executive Director of Policy at The Pensions Regulator, commented: “We are pleased to have worked with the PPF on its new contingency planning guidance. It highlights the need for trustees to maintain the high standards of governance and administration we expect, even during unexpected situations such as employer insolvency or a loss of infrastructure. Adequate risk management is vital so trustees should read our and the PPF’s guidance and update their contingency plans.”
A checklist for trustees
• Collate all governing documents and keep them in more than one place
• Make sure you have access to payroll information and a way of paying pensioners that does not depend on the employer
• Set up a separate bank account, ideally containing funds to cover three months’ payroll, especially if employer insolvency is imminent
• Have a complete list of employers attached to the scheme and which member is attached to which employer
• Make sure you have an up-to-date list of scheme documents and a back-up of all electronic data
• Create a strategy for communicating with members and the media in the event of employer insolvency
• Speak to the PPF to make sure you’re adequately prepared for entering PPF assessment
The PPF is inviting trustees and scheme advisers to find out more at an event in central London on the morning of 14 May. Find out more here.
The guidance document, Contingency planning for employer insolvency
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