In defiance of the current logic that says we can all only eat, sleep and think Brexit, somehow the regulatory wheels continued to quietly turn throughout March. Colin Jamieson of Barnett Waddingham takes a brief look at some of the hotter pension topics.


HMRC: Countdown bulletins 43 and 44

For schemes still in the thick of their GMP reconciliations (many, many schemes), HM Revenue & Customs (HMRC) published two countdown bulletins within days of each other in March. Countdown bulletin 43 covers the following:

> Information about asking future questions relating to the Scheme Reconciliation Service (SRS)

> A reminder that the deadlines for SRS queries and contracted-out contribution service requests was the 31 October 2018, and that the deadline for refreshed SRS data was 31 January 2019

> Confirmation that HMRC will stop issuing paper GMP statements from April 2019

Countdown bulletin 44 states that for schemes in deficit following financial reconciliation, letters will now be with scheme administrators in the week commencing 1 April 2019. This is earlier than as advised in Countdown bulletin 42, to give schemes more time to make payment to HMRC. Refreshingly, the deadline for payment of 21 May 2019 has not changed

DWP: Collective defined contribution schemes

The Government has confirmed that legislation to facilitate collective defined contribution (CDC) schemes will be introduced in the UK. The initial priority will be to deliver a legislative framework for single employer schemes, to allow the proposed Royal Mail CDC scheme to be set up. However, it is expected that this framework will be expanded in due course to accommodate other types of CDC schemes.

Primary legislation will be introduced ‘as soon as Parliamentary time allows’ and this will be followed by draft regulation containing detailed CDC scheme provisions.

New name for SFGB

Time to re-draft your already re-drafted standard retirement paperwork as the Single Financial Guidance Body (SFGB), which launched in January 2019, has now been renamed the ‘Money and Pensions Service’ from 6 April 2019. The Money and Pensions Service will deliver what was previously provided by the Money Advice Service, the Pensions Advisory Service and Pension Wise.

TPR annual funding statement

In its latest Annual Funding Statement, the Pensions Regulator (TPR) provides guidance for trustees of defined benefit (DB) schemes and their sponsoring employers on how to approach a scheme valuation. The statement includes TPR’s view on some of the topical issues (such as Brexit’s uncertainty), along with sections on its expectations of trustees and what they can expect from TPR. In particular, TPR expects schemes to follow the principles in its DB code of practice and associated guidance.

As explained in the White Paper, ‘Protecting defined benefit pension schemes’, published in March 2018, it is TPR’s intention to review and update the DB funding code as part of a package of measures to optimise scheme funding. TPR will be consulting in summer 2019 ‘on various options for a revised funding framework under the new code’ and ‘shortly after’, consulting on the revised code itself.



Colin Jamieson

Technical Analyst – Barnett Waddingham

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