Perspectives

PPF Levy 2021/22

PPF consultation on insolvency risk scores from April 2020

The PPF has released a consultation on the Pension Protection scores that will apply to scores calculated from 30 April 2020 onwards, and which will impact the levy payable by schemes for the 2021/22 levy year. This includes important changes that will impact most schemes. Trustees and employers should consider the impact on their schemes at the earliest opportunity.

We strongly recommend that trustees and companies review the new Pension Protection scores for their scheme, and provide any updates required to the data used by Dun & Bradstreet (D&B) well in advance of 30 April 2020.

The consultation document and technical appendices can be found on the PPF website.


Background
  • Every three years the PPF conducts a wholesale review of the levy framework. In between reviews, the PPF aims to keep the levy rules relatively stable. 2021/22 is the first levy year in the next three year period. The 2021/22 levy year is based on Pension Protection scores calculated from 30 April 2020 to 31 March 2021.
  • In 2019, the PPF announced that Experian would be replaced as the provider of Pension Protection scores (i.e. insolvency risk scores) by D&B. 
  • The PPF has released its first of three planned consultations on the levy framework for 2021/22. The first covers changes to the Pension Protection scores.
  • Future consultations are expected on other aspects of the levy calculation, including the levy parameters, levy bands, and other elements of the levy framework.

Key changes to the Pension Protection scores
  • Scorecards have been recalibrated to include insolvency experience over the last three years. This is particularly relevant for employers and guarantors on Scorecard 1, which applies to the largest entities. 
  • Analysis conducted by the PPF and D&B indicates that Scorecard 1 has been under-predicting insolvencies. The recalibration will lead to worsening Pension Protection scores, and therefore a greater share of the levy, for employers on this scorecard. 
  • The approach to data collection and corporate linkages differs between D&B and Experian. This will affect the scores for some employers. 
  • The mortgage age variable has been removed from all scorecards. This has been replaced by “cash to current liabilities”. Note that for the 2020/21 levy year, schemes will still need to consider mortgage age and submit certificates where appropriate.
  • The creditor days variable has been capped at 60 days, or neutralised for certain institutions.
  • The S&P credit model, which was used to score certain financial services organisations, is being retired.

New PPF score website
  • There is a new PPF score website (https://levy.ppf.co.uk), which is now live in beta form and you can access. 
  • Registration emails were sent in December to users of the old Experian portal. New users can register on the site.
  • Trustees who themselves have access to the Portal can delegate access to an adviser.

Key actions to take

New scores will apply from 30 April 2020. Before then, companies and trustees should:

  • Register for the new portal.
  • Review the data D&B hold for accuracy and completeness, and raise any concerns with D&B.
  • Submit any voluntary information required for scoring purposes to D&B. If schemes have voluntarily submitted information to Experian in the past (ie corporate accounts data), that information will not have been passed across to D&B, and this will need to be provided again, where beneficial. 
  • Take any steps to mitigate the impact.

If you would like help in understanding the changes, or what steps you might take, please contact your normal Deloitte contact, or Andrew Watcham using the contact details in the section below.

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