15 April 2024
Sacker & Partners LLP (Sackers), the UK’s leading specialist law firm for pensions and retirement savings share their thoughts on the latest TPR consultation.
With the new funding regime edging ever closer to the finishing line, TPR’s consultation on the new statement of strategy (“the Statement”) closes today,16 April 2024. Forming an integral part of the new requirements for all DB schemes to have a funding and investment strategy, the consultation focused on the proposed form of the new Statement, including the extent of information that will need to be submitted (and evidenced) to TPR.
Sacker’s partner, Eleanor Daplyn, comments: “We welcome TPR’s emphasis on taking a proportionate approach and desire to “streamline” the information collected through the new Statement. Accompanied by an example of what a Statement might look like, there are due to be four Statement templates, depending on a scheme’s maturity, and which of the two funding tracks, Fast or Bespoke, a scheme is running along.
Whilst some concessions are made for smaller schemes, for most DB schemes, the Statement looks set to require extensive actuarial, investment and covenant input. With schemes having to delve deeper into the detail, there is a real risk of increasing the burden on already stretched schemes. Given the volume of DB scheme information gathered through the existing valuation process and annual scheme return, it remains to be seen just how useful TPR will find this new level of granularity.
In addition, although having Statement templates seems sensible, it is essential that trustees are given sufficient flexibility to tailor the information (where appropriate) to reflect scheme specifics. In particular, a lingering area of concern relates to open DB schemes, as they will need latitude to explain their particular circumstances.”
Read our Alert on the consultation here.
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