Industry calls for greater focus on adequacy and member outcomes in TPR strategy

The pensions industry has urged The Pensions Regulator to provide clarity and focus on adequacy and member outcomes in its new Corporate Strategy, alongside more extensive references to new solutions such as surplus release and collective defined contribution (CDC) pensions.

Responding to the regulator’s consultation on its new five-year strategy, The Investing and Saving Alliance (TISA) welcomed its system-wide approach but called for closer collaboration between regulators and the government.

It argued this would ensure major reforms are properly sequenced, tactical regulatory change is minimised, and the existing pipeline of pension policy delivers on its potential.

“The next five years could reshape DC pensions for a generation,” said TISA head of policy: products & long-term savings, Renny Biggins.

“Consolidation, scale, technology, digitalisation and AI can all improve saver outcomes, but only if government and regulators act in a joined-up way.”

TISA also called for a reduction in inconsistencies between trust-based and contract-based pension journeys, for regulatory churn and unnecessary administrative cost to be minimised, more targeted employer engagement to address undersaving, and for adequacy to be made ‘central’ to the regulator’s pensions vision.

“While we welcome the TPR’s system-wide view to encourage sustainable outcomes, its strategy should be bolder in its ambition,” Biggins added.

“The ultimate aim must be a pensions system which delivers adequate retirement outcomes for consumers, supported by robust defaults, increased opportunity for informed choice and flexibility.”

The Pensions Administration Standards Association (PASA) agreed there should be greater clarity on how improved member outcomes will be achieved.

The association said it supported the ambition to improve member outcomes and recognise the ongoing changes across the pensions landscape, but argued that the strategy would benefit from greater recognition of the role administration plays in delivering these outcomes.

“Administration isn’t simply an operational support function,” PASA stated. “It’s the infrastructure through which policy, governance, communications, data quality, dashboards, consolidation and retirement support are ultimately delivered to members.

“As schemes become larger, more digital and increasingly reliant on third-party providers, the quality of administration becomes ever more important. Greater prominence for administration throughout the strategy and its supporting outcomes framework would therefore be appropriate.”

Meanwhile, the Association of Consulting Actuaries (ACA) called for several “important issues” to be referenced more extensively in the regulator’s strategy.

It argued that the new flexibilities for defined benefit (DB) surplus distribution warranted additional comment in the strategy, including emphasising the need for regulatory balance.

Furthermore, the ACA said potential challenges relating to the greater prevalence of professional trustees, such as appropriate conflict management, should be explicitly mentioned in the strategy.

“CDC will be key to achieving TPR’s vision of a sustainable income in retirement,” said ACA chair, Chintan Gandhi.

“TPR will need to devote adequate resources to ensure that new CDC arrangements can be considered and (if appropriate) authorised in a timely manner.

“It will also be important for the development of retirement CDC to be integrated with the development of guided retirement. Suitably aligned timings will be key – and these could have a significant impact on TPR achieving its vision.

“In addition, we think that the strategy should more clearly state that TPR will be actively supporting CDC innovation as one of its key priorities. We anticipate that this will be the case in practice, but it would be helpful to make this clear in the strategy.”



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