The Society of Pension Professionals (SPP) has called on The Pensions Regulator (TPR) to lighten the burden of the proposals in its Statement of Strategy consultation.

TPR’s consultation sought feedback on proposals to help trustees of defined benefit (DB) pension schemes to meet new requirements for submitting a Statement of Strategy.

New DB pension regulations, which will apply to scheme valuations from September, will introduce requirements for trustees to set a long-term funding and investment strategy for their scheme, including a Statement of Strategy to set out this long-term funding strategy and their approach to managing associated risks.

The SPP stated that while much of the information requested by TPR was “fairly straightforward” to provide, there were several areas that would be “challenging and costly” for schemes.

It urged the regulator to consider requesting less information, stating within its consultation response that it believed TPR was asking for some information that added little or no value to 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 society said.

The SPP suggested that TPR should change the information it is requesting to better reflect scheme circumstances, such as reducing the requirements for very well-funded schemes and asking for less information from schemes that are going through the ‘bespoke’ route of the DB Funding Code as a result of affordability constraints.

Furthermore, the society raised concerns about the impact of the proposals on smaller schemes, especially those required to go down a bespoke route where the requirements are “particularly challenging”.

“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,” the SPP said.

SPP DB Committee chair, Chris Ramsey, commented: “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.”

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