Atkin trustees, actuaries, consultants & administrators

Current Issues - August 2019

New investment governance requirements: Various changes will need to be made by October 2019, December 2019 and October 2020. It is likely that additional questions will be added to the annual TPR Scheme Return to check compliance and we would therefore recommend that you speak to your advisors to ensure that you will be compliant. Some of these requirements may require that Schemes engage with their investment managers to confirm how they are managing issues such as environmental, social and governance matters. More information on these different requirements can be found by reading our special update.

Fewer deaths in 2019 could increase DB liabilities: Data collected in the first half of 2019, suggests that there have been less deaths than would have been anticipated under the CMI_2018 improvement table introduced earlier this year and that the CMI_2019 improvement tables may see much of the reduction in liabilities using the 2018 improvement table being reversed. Whilst this is not based upon data for the full year, this volatility in the assumptions made about future life expectancies does suggest that schemes should be cautious when making their mortality assumptions.

Pension Transfers – ban on contingent charges: Whilst many may question why it has taken so long to address this issue, one potential consequence is that it will become even more difficult for members to obtain advice on DB transfers at a reasonable cost. This, along with the huge variation we see in both the quality and cost of this advice, means that there might be some value in schemes considering appointing a “appropriate IFA” with whom they might be able to agree beneficial rates and a more efficient review process.

TPR publishes analysis of Tranche 12 funding: This refers to schemes with valuation dates in 2016/17 and therefore is somewhat out of date. However, it does include some interesting statistics as to what approaches have been adopted for funding by different schemes.

GMP Reconciliation: HMRC expects to start issuing invoices and refund letters to schemes in respect of any outstanding payments/balances from their contracted out liabilities any State Scheme Premiums in August. Where payments are due, schemes will have until 17 October to pay them.

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