Deloitte comments on the introduction of annual Master Trust authorisation
1 October 2018
Tom Partridge, partner in Deloitte’s pensions advisory practice, said:
“From today, pension master trusts will be required to apply annually to the Pensions Regulator for authorisation in order to continue operating and will have until 31st March 2019 to submit their first application.
“As some organisations will have experienced from the Pensions Regulator’s recent Readiness Review, the master trust authorisation application process poses a number of new challenges, even for the best-prepared organisations. Whilst most trusts anticipate a significant time frame to prepare their applications, some are yet to consider the additional resourcing required and different skill sets that will be essential in preparations. Most importantly, this includes expertise in project management, financial analysis and contingency strategy planning to meet the task at hand.”
Five challenges to organisations:
- Understanding the requirements of TPR’s 102-page Code of Practice in detail;
- Finding sufficient time and resource to prepare an application they can be confident in;
- Adapting existing business plans and financial forecasts to meet the particular requirements of the Code of Practice;
- Preparing a continuity strategy for the master trust that is sufficiently robust; and
- Considering how to most efficiently structure and update materials in future given the ongoing requirement of annual authorisation.
Top tips for organisations:
- Do not underestimate the amount of time and resource that is required to meet requirements of the Code of Practice. However, with appropriate planning the process is manageable;
- In many ways the process is prescriptive and, as such, it is important to thoroughly follow the guidance and templates provided by TPR. This will help ensure that the submission is complete;
- The Code of Practice is a product of the Pensions Schemes Act 2017 and the associated Regulations. Taking time to read and understand these documents will give a better understanding of the requirements of the Code of Practice. When it is not clear what is required by the Code, cross referencing to the legislation and regulations will help;
- As this is an annual authorisation process, the earlier that the Master Trust can think ahead to next submission, the better. This will allow the process to be refined and improved each iteration, and should save time; and
- Explore TPR’s website, it contains a wealth of information including additional guidance on how to complete the submission.
Notes to editors
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