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A response to the Consultation on Guides to support Code of practice 13

22 June 2016

Regarding governance and administration of occupational trust-based schemes providing money purchase benefits

In the first half of 2016, the Pensions Regulator carried out an Industry Consultation to determine response to its ‘How to Guides’ that accompany the revised DC Code of Practice 13: Governance and administration of occupational trust‑based schemes providing money purchase benefits.

Equiniti’s pensions Technical Development Team put together the Equiniti response to this consultation.

There are six “How to” guides covering:

  • The trustee board
  • Scheme management skills
  • Administration
  • Investment for governance
  • Value for members
  • Communication and reporting

Equiniti’s technical development team reviewed all of the guides, and made specific comments in relation to three of them (Administration, Value for members and Communicating and reporting).

Equiniti welcomes the guides as they provide a degree of much needed detail for those affected by the DC code, although much of what they contain is a restatement of the existing code, guidance and regulation. We do, however, believe that more could be done to clarify the position of small schemes and money purchase AVC arrangements within defined benefit schemes and, in particular, the proportionate approaches that they may take towards compliance.

In addition, the Regulator’s comments on the use of the latest technologies and processes to ensure the promptness of core financial transactions may be of concern to small schemes for whom such technologies might not be financially viable.