Whilst much of the information requested by TPR is fairly straightforward to provide, there are a number of areas that will be challenging and costly for schemes.
The Society response is clear that TPR should consider requesting less information. It states, “We believe that TPR is asking for some information that adds little or no value to the Trustees’ decision-making (especially in relation to well-funded schemes in a low dependency asset allocation). It is difficult to understand how providing this is proportionate or useful to TPR and therefore appears to be unnecessarily burdensome for schemes.”
The SPP have suggested TPR make the information requested better reflect scheme circumstances. For example, reducing the requirements for very well-funded schemes, and requiring less information from schemes that are going through a “Bespoke” route purely as a result of affordability constraints.
The SPP also has concerns about the impact of the proposals on small schemes, especially those that are required to go down a Bespoke route where the requirements are particularly challenging.
The Society highlights that “…the requirement to resubmit the Statement of Strategy between valuations if there has been a material change in circumstances e.g. a change in investment strategy… could prove burdensome and may deter small schemes from making strategy changes that would be in the best interests of their members.”
Chris Ramsey, Chair SPP Defined Benefit Committee, said: “Whilst, for most schemes, the information being requested is reasonable and proportionate, we strongly feel that for some what’s being asked for adds little or no real value either to trustees or the regulator itself – stripping that out would clearly benefit all parties. We also have significant concerns about the impact of additional costs on smaller, less well funded, schemes in particular.”
A full copy of the SPP consultation response can be found here
The Government consultation closes on 16 April 2024 and can be found here
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