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We believe there is a need for greater clarity about Expected Retirement Income (ERI)and how the ecosystem is going to comply with Data Protection requirements and be compatible with providers' Application Programming Interface (API) for effective planning around sharing data and verifying members.
We support the work being done by TPR and others in seeking to protect the benefits of pension scheme members, to reduce the risk of calls on the Pension Protection Fund (PPF), and to promote the good administration of work-based pension schemes. We note that the government's policy intent in introducing the two new alternative 'act' tests to the existing CN power is to focus on the effect of an act on an employer, which in turn affects its capacity to support the scheme. We consider that both new tests meet the policy intent.
We believe that additional checks are required when schemes are transferring, including how they can be identified for the purposes of the regulations.
Do people have access to a range of pension options to meet their needs for later life and how might these needs change in future?
We support the work being done by The Pensions Regulator (TPR) and others in seeking to address serious intentional and reckless behaviour and improving standards of governance and conduct in relation to pension schemes.
We are grateful for TPR’s confirmation that it does not intend for its guidance to change commercial norms or accepted standards of corporate behaviour in the UK (i.e. consistent with the government's policy intent). However, we are concerned that the current drafting of TPR policy does not achieve this aim. In particular, we do not believe it addresses the concerns raised by the industry during the development of the law, in relation to the broad and ill-defined scope of the new powers, and the circumstances when they will apply. We believe that this will have the impact of altering or reducing normal commercial activity.
The PMI welcomes this consultation and Government efforts to tackle climate change. The climate challenges facing our planet pose an existential threat and it is only right that institutional investors, including pension funds, are at the forefront of building a more climate-friendly and sustainable future.