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PMI
7 July 2021

The PMI response to TPR consultation: 'Circumstances in relation to the material detriment test, the employer insolvency test and the employer resources test'

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.

PMI is the professional body that supports and develops those who work in the pensions industry. PMI offers a range of qualifications designed to meet the requirements of those who manage workplace pension schemes or who provide professional services to them. Our members (currently some 6,000) include pension managers, lawyers, actuaries, consultants, administrators, and others. Their experience is therefore wide-ranging and has contributed to the thinking expressed in this response. Due to the wide range of professional disciplines represented, our members represent a cross-section of the pensions industry as a whole.

PMI is focused on supporting its members to enable them to perform their jobs to the highest professional standards, and thereby benefit members of retirement benefit arrangements for which they are responsible.

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