The Pensions Regulator (TPR) and the Financial Conduct Authority (FCA) have confirmed that further refinements to the proposed value for money framework are expected, emphasising that "nothing is set in stone" at this point.

Speaking at the PLSA Annual Conference, TPR executive director of strategy, policy and analysis, Nina Blackett, stressed that TPR is working "really closely" with the FCA and Department for Work and Pensions (DWP) on the VFM framework, and have been "for many years".

"We're committed to continuing to work closely together because we're regulating one industry," she continued. "We have different parts of it, but it's really important that we stay aligned. We work together really closely and we intend to continue to do that."

Adding to this, FCA head of asset management and pensions policy, Nike Trost, said: "You always have that challenge that sometimes the timelines don't quite align between consultations, legislative processes and the time frames given for implementation.

"But on this project, we've worked on it together from inception, so I'm very confident that we can then deliver framework that works across the board."

Trost also emphasised that the consultation is "really just the beginning of the process", with plans to further streamline and refine the framework as part of the next steps.

And whilst Trost acknowledged that this is a "maximalist" consultation, she argued that "it's much easier to set out a whole range of options and streamline from there than to talk about it in high levels and try to work through the detail afterwards".

"I think there's real opportunity to streamline here," she continued. "But we really needed to put all of that detail into the public domain to have a detailed discussion with the wider industry and with those representing savers of what are actually the right metrics that will drive value.

"We probably have a good year now or so to work through some of that detail... so we really have a good period to work through that industry feedback. We are really interested in hearing that and evolving the proposals as necessary."

"This is an ongoing dialogue," Blackett agreed, emphasising that "nothing is set in stone at this point".

And some insights are already emerging, as Trost noted that the FCA has already heard early commentary and "quite a lot of questions" about forward-looking metrics, for instance, which were not included in the consultation.

"And then also what is the right action that needs to be taken if a scheme is not providing value, and we've also had a lot of commentary around the red amber green ratings," she said.

Indeed, when asked whether there was scope to evolve the proposals for a red, amber or green end assessment, particularly given industry concerns around the stark step between amber and green, the pair agreed that there is.

"What we're looking for is something that is simple," Blackett clarified, "and if three isn't the right number, 33 is definitely not the right number - so do come back to us with your thoughts on that."

This was echoed by Trost, who said: "What we are clear about is that we need a framework that will drive action.

"So where there are subset of schemes that or arrangements that do not provide good value, then of course change needs to happen.

"It should be as simple framework but does it have to be red amber green, not necessarily."

The pair were also asked about concerns the framework won't take into account those employers that subsidise the cost of running the scheme for members, which would appear to contribute pretty directly to good value.

However, Blackett explained that this is not covered in the framework as the regulators "don't want that to mask poor performance".

"We want the schemes to be able to be judged on their performance, and we want that to be clear across the board," she continued.

"We have proposed that there may be additional disclosures that employers may make to reflect the added value that they add because there are lots of different ways of contributing value, we wouldn't want that to be lost.

"I hope that does offer some reassurance, as we do see the value of those other measures."

---