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Pension Funds

Transaction costs – what must trustees actually do?

In the last few weeks, the Financial Conduct Authority (FCA) issued a consultation document on the disclosure of investment transaction costs.

This follows from the work they began early last year and a couple of items of forthcoming European legislation (both of which are likely to impact us whether we are in Europe or not).

It sets out a framework for regulated asset managers to disclose transaction costs and includes a standardised method of calculation.

Additionally, the consultation dovetails with the Charges and Governance Regulations 2015 and with the FCA's own Conduct of Business Sourcebook (COBS). So, what's this all about and what must trustees do in response?

Transaction costs are defined in the regulations – and in a broadly similar way in the COBS – as the costs incurred as a result of the buying, selling, lending or borrowing of investments. They include items such as stamp duty and bid to offer spreads. The policy intent of disclosure is that this will facilitate a more open and therefore efficient market – allowing trustees and others to choose a fund manager who controls and optimises their costs.

The first thing to know is that the COBS do not apply to trustees, although they do apply, indirectly, to the independent governance committees that oversee workplace personal pensions and directly on most, but not all, fund managers.

The Charges and Governance Regulations do apply to trustees, but only in relation to the defined contribution (DC) schemes or sections they run.

DB trustees
Neither the COBS nor the regs apply to defined benefit (DB) trustees. In other words, DB trustees do not, technically, need do anything on transaction costs – although, of course, it is probably good governance that they do so.

DC trustees
The workload for DC trustees is a little more complex.

The first obligation for DC trustees is to ask their fund managers for transaction cost data. There is, currently, no corresponding obligation for the managers to provide that data.

Where trustees have asked for data but not received it, they must disclose this fact in their chair's annual statement and explain what they are doing to obtain that information in the future.

Where they have received it, they must assess the extent to which transaction costs represent good value for members and include in the chair's annual statement:

• An explanation of their assessment
• A statement of the levels of transaction costs applicable to the default investment strategy, and
• A statement of the range of transaction costs applicable to all investment funds that members' used during the year in question.

What's coming?
The FCA consultation proposes an obligation on regulated fund managers to provide information in response to a trustee request. It also, as mentioned previously, sets out a standardised way of assessing the impact of transaction costs. All of this is designed to make the trustees' job of assessment easier and more meaningful.

For PTL's initial views on the consultation, click here [http://ptluk.com/press-release-fcas-transparency-paper-good-start-stops-short-success-says-ptl]. The FCA consultation closes on 4 January 2017.

Written by Richard Butcher, Managing Director, PTL.

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Pension Funds

What price advice?

Following a recommendation of the Financial Advice Market Review (FAMR) last March, HM Treasury (HMT) has proposed a radical redefinition of "regulated advice".

The intended result is that consumers will receive "regulated advice" only when they are offered a personal recommendation for a specific 'product'.

This is much narrower than the current definition, in Article 53 of the Regulated Activities Order, which relates to advising on investments.

The objective is to remove confusion by aligning the definition of regulated advice with the EU MiFID (Markets in Financial Instruments Directive) definition.

FAMR found that the MiFID definition is clearer for firms and customers and is also much easier for firms to build into their compliance processes.

FAMR also found reasons why some consumers do not want financial advice: chiefly cost, unwillingness to pay and preferring to make their own investment decisions.

Although they could benefit from good, potentially cheaper financial guidance to help them make informed decisions, FAMR found that the unclear regulatory parameters meant firms were only providing simple financial guidance to these individuals, to remove the risk of straying into the regulated sphere.

After the change, HMT feels firms will be able to give more tailored information and guidance, to better serve customers without incurring additional regulatory costs.

If anything that stops short of a personal recommendation to invest in a particular 'product' can be treated as guidance, rather than advice, the shackles are off.

So far, so good. However, some have criticised the proposed change for failing to adequately clarify the distinction between advice and guidance.

The HMT consultation document acknowledges that currently, very few firms charge consumers to use their guidance services.

With the ability to provide more advanced guidance, some firms may begin to charge for the use of such services.

If an individual is asking questions and receiving answers, they might see it as advice – especially if they are being charged.

Perhaps the crucial difference is between guidance as the options available, and advice as which particular option is best for them.

It is all too easy though, for options to be presented in such a way that the individual is left in little doubt about which their informant favours.

HMT also recognizes that moving the regulatory boundary will enable some firms to provide guidance services, for which they currently require authorisation, without being authorised.

If they stop short of recommending a 'regulated product' though, HMT considers the risk to consumers will be acceptably low.
The proposed change to the definition of advice will liberate firms to offer more to clients, at a potentially lower cost.

But clients will still have to put their hand in their pocket – which they don't want to do, as the FAMR found.

In January 2014, I wrote here on PFO about the need for change, noting that one thing which really does make a difference to cost is scale.

Few people are financial experts, just as few are really knowledgeable about medical treatment.

I argued that a National Wealth Service (NWS), analogous to the National Health Service, with competent salaried advisers could help channel individuals in the right direction for each one.

I went on to suggest there was an opportunity here for the Government to make something of the much-maligned Money Advice Service (MAS).

In this year's Budget, the Government promised to restructure the statutory public financial guidance providers – MAS, The Pensions Advisory Service (TPAS) and Pension Wise – to create a new pensions guidance body and a new "slimmed down" money guidance body.

This week, the Government moved a step further to setting up the kind of NWS I proposed, with an announcement instead of a new all-in-one single body to deliver public financial guidance.

Written by Ian Neale,Director, Aries Insight.

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Pension Funds

PLSA announced three new council members

Mel Duffield will sit on the Defined Contribution Council, while Nicola Mark and Colin Richardson will join the Defined Benefit Council.

All three new members will assume their responsibilities after the PLSA AGM on 21 October.

Mel Duffield is head of pensions strategy and insight at the Universities Superannuation Scheme (USS).

Since joining USS in February 2015, her remit covers employer and member insight, product strategy and employer liaison.

Prior to her role at USS, Mel was deputy director at the Pensions Policy Institute, and before that head of research and strategic policy at the PLSA.

Nicola Mark has been the head of the Norfolk Pension Fund since 2001 and also the elected practitioner representative on the Local Government Pension Scheme National Advisory Board.

She also sits on the CIPFA Pensions Panel and chairs the National LGPS Frameworks project.

Nicola was awarded an MBE for services to local government in 2015 and over the years has contributed to a number of working parties – including the Myners review and Lord Hutton's Independent Public Service Pensions Commission.

Colin Richardson is a trustee with PTL, acting for 11 occupational pension schemes, ranging up to £1billion.

Before joining PTL, he worked as an actuary and actuarial consultant with a number of major pension consulting firms.

Colin also has extensive defined contribution experience acting as a trustee for five master trusts and is a member of the Independent Governance Committee for the workplace pension for Aegon and Blackrock.

As well as the three new members, Carol Young, vice chair, and Andy Cheseldine, have been re-elected to the Defined Contribution council.

Graham Vidler, director of external affairs, pensions and lifetime savings association, said: "The experience and expertise of all three new council members comes at a time of great change for the pensions industry."

"Having Mel, Nicola and Colin on the Council will help us to continue our work to improve the nation's retirement incomes."

The PLSA's councils have a vital role, giving members the opportunity to contribute to the strategic direction of its policy on a wide range of pension issues.

First published 13.10.2016


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Pension Funds

Pension Funds could save £800k per year

AMNT, a not-for-profit company representing 480 occupational pension schemes, says
'transparency could benefit pension funds by having a positive impact on investment strategy, helping to cut risk, and ultimately improving value for money for members.'

Independent analysis conducted earlier this year, looked at three factors; being clear about costs, measuring them, and monitoring them. The analysis, it says, enabled its members to develop the approach 'what gets measured gets managed.'

Speaking at a Transparency Taskforce conference in London, David Weeks, AMNT co-chair, emphasized the importance of transparency to the pensions industry.

He said: "Transparency is about value for money for members - it is what trustees do."

Weeks said the industry must work together to achieve much higher levels of transparency in financial services.

He said transparency would motivate more people to save during their working lives, which is essential to enable more people to fund themselves through retirement.

"We must deliver, and be seen to deliver, prudent and open costs and charges," he said, "If across the industry, we were to apply the simple mantra of 'what gets measured gets managed', we could achieve significant savings for pension schemes."

AMNT members have implemented this approach and the two key results were lowered costs and reduced risks.

Costs of 1.69% of assets came down to just 0.82% of assets which, on a typical fund of £100million, could represent a saving of £800k a year.

In terms of reduced risk, many AMNT members have funds that operate on a target return of around LIBOR plus 3%.

"Transparency is not a race to the bottom, it is about creating an environment for better outcomes," said Weeks.

First published 13.10.2016


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Pension Funds

Government to launch new financial guidance service

A new financial guidance service, which will include advice on pensions, is being created by the government to replace three other services.

The government believes the new body, a single advisory service, will be more efficient but has not yet decided on the specifics.

It will provide advice on pensions, managing debts, and other money issues.

It will take on the roles of the Pensions Advisory Service and Pension Wise, which was set up in response to pension reforms last year.

The new service will also replace the heavily-criticised Money Advice Service (MAS) and will be paid for by a levy on financial services companies.

The new body as yet has no name and there is no timetable for its creation.

Pensions minister Richard Harrington said a single guidance body will be more efficient and will help consumers make the right financial decisions.

"We are committed to ensuring people can access the best free and impartial financial guidance possible," he said.

NOW: Pensions CEO Morten Nilsson said although it makes sense to have a single guidance service, he is concerned that rolling everything together will mean the service becomes a 'jack of all trades and a master of none.'

He said: "Pensions are complicated and it's important that the specialist service offered by organisations, such as The Pensions Advisory Service, isn't lost."

"With the freedom and choice reforms, pension savers have many more options to consider when they come up to retirement and face significant consequences if they make the wrong decision."

Nilsson also pointed out the new guidance body will be paid for by a levy on the financial services industry, which would require more consideration.

"While we support funding of these organisations in this way, it's important that the government considers and reviews all levies it imposes to ensure they are fair and proportionate - as ultimately these costs are passed onto savers," he said.

First published 13.10.2016


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Expected Returns 2017-2021: It's always darkest just before dawn

In December 2015, when we first set out to discuss this year's edition of our annual Expected Returns publication, we were in good spirits. The European economy had surprised everybody by growing above trend, the global economy was picking up and the Fed's first interest-rate hike had not derailed markets as many had feared. The process of monetary normalization was all set to begin.

Sure, there were issues; there always are. The ongoing decline in the oil price; positive for consumers, perhaps, but worrying for financial markets. A growing consensus among economists that increasingly high debt levels could lead to an adverse debt cycle. And the meltdown in emerging markets with the Brazilian and Russian economies shrinking significantly (by 3.8% and 3.7% respectively in 2015), plus a Chinese growth path that was looking increasingly unsustainable. But it was nothing we couldn't handle.

Black clouds
Eight months on and our spirits are not in such good shape. The hoped for normalization evaporated after a solitary rate hike by the Fed. Falling oil prices have hit the positive impetus driving the US economy and the outlook has become more uncertain. External factors have also curbed the Fed's desire to hike rates: uncertainty about China, financial market volatility and a major negative blow in the form of the Brexit vote. This shattered any hopes of monetary policy returning to normal, causing the UK to follow in the footsteps of the ECB and Bank of Japan and start quantitative easing. So unless we now regard QE as the new normal, it is clear that 2016 is not set to become the year of monetary normalization.

Is this just another temporary setback, or should we succumb to one of the numerous credible doom scenarios: disintegration of the European economy (Brexit, the rise of populist parties, Italian banks), Chinese hard landing (unsuccessful rebalancing of the Chinese economy, high debt), rise in protectionism (the Trump factor), loss of central-bank credibility (Japan), and the bursting of the debt bubble. After all, we're spoilt for choice.

It's always darkest just before dawn
But are things really so bad? You could be forgiven for thinking they are. Our impression is that sentiment among professional investors has probably never been as weak as it is right now. This is corroborated by what the financial markets have priced in: average inflation expectations in the European market for the period 2021-2026 are as low as 1.25%. Looking at the West-German track record (renowned for its tough inflationary stance), such a five-year average is pretty rare. Possible? Sure. But likely? Well, only if you really are very pessimistic about the future. And this is exactly the point we want to make.

Pessimism is a risk in itself. There is plenty of self-reinforcing momentum in the way economies work, so a move in one direction is not easily reversed. Once growth weakens, producers and consumers become more cautious, investment, employment and consumption levels all contract, reinforcing the downward trend.
Stock markets normally hit bottom when things are at their bleakest. If earnings evaporate, companies collapse, people get fired and there is talk of 'the end of capitalism as we know it', that's when the tide turns. The bad news may still continue, but the market has by then already discounted it. The bleaker the expectations, the better the odds that the surprise will be a positive one.
It's always darkest just before dawn. And if the mood of investors is anything to go by, it is already pretty dark out there.

The full publication gives a prognosis for the major asset classes and three potential scenarios (baseline, stagnation and high growth). Read more about these scenarios in the full report.

Click to read more
Expected Returns 2017-2021 (full report available)


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Pension Funds

Pension administration is a wise investment

Pension administrators are the key touch point between two very different realms.

A world peopled with Actuaries, Investment Consultants, Asset Managers and Pension Lawyers and the citizens of our country who rely on us to invest their hard earned money and pay them an accurate sum of money month after month once they retire.

It is possibly the least appreciated link in the pension's value chain and offers our 'masters' the least margin, if any at all.

Yet, it is the face of pensions that the world sees when they get their annual benefit statement, their retirement quote and, again, when they receive their pension.

Pension administrators come into work every morning wanting to do their very best.

However, many are faced with poor quality data, legacy administration platforms and are driven by SLA targets rather than quality of service and often 'supported' by poorly drafted Trustee rules & deeds. Despite this, when faced with a potential error, I have found that it is usually the member, their IFA or even the Client who has created the issue, rather than the administrator.

It is time that we recognise the administrator's plight, support them appropriately and allow them to deliver to the standards that they would like to meet and members would like to receive.

The world has moved on from the Trust-based non-contributory defined benefit pension scheme to the fully-automated and online auto-enrolment-minimum defined contribution scheme.

Pension administration is following, morphing from a world of dusty files and calculators to one of Robo-advice and pension dashboards.

However, for legacy Trust-based pension schemes to deliver to the high standards of service expected in 21st century Britain, they need investment.

Data needs to be cleaned, scheme rules need to be streamlined, calculations need to be automated, communication needs to be simplified and systems need to be integrated.

Good quality pension administration firms invest in their pension administration platforms, administrator training, their standard communication and their online functionality.

They work closely with their Trustee partners to clean scheme data, automate calculations and offer member self-service.

In a world of increasingly requested transfer value quotations and de-risking exercises, these investments are more than merely good governance.

They reduce cost and enhance the service provided to our members.

Recognising a gap between the practices of well-run administration schemes from the rest, the Pensions Administration Standards

Association was set up with the core purpose of bringing the industry together and agreeing a set of standards that we could all be proud of delivering and members would be happy to receive.

It is essential that Trustees and Sponsors recognise the enormous importance of increasing the standards of pension administration and support our pension administration firms with the financial investments required for these projects and possibly a small premium in running costs.

The Pension Regulator expects higher standards from schemes. Our members have increased expectations in a world of self-driving cars and 3D printers.

The investment will prevent expensive and embarrassing errors. But most importantly, it will allow our pension administrators to feel the pride of a job well done.

Written by Girish Menezes, PASA Board Member.

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Pension Funds

White paper says pension funds can reduce deficit

A new white paper has been published showing the impact private debt market investments could have on UK pension funds' ability to meet liabilities.

The paper, published by Macquarie Infrastructure Debt Investment Solutions (MIDIS), looks specifically at how infrastructure debt can play a significant role in a liability-driven investment (LDI) strategy.

In recent years, persistent low interest rates have prompted UK pension funds to increase allocations to the private debt market – including real estate debt, direct corporate lending and infrastructure debt – to help achieve the main objective of earning enhanced returns relative to investments in public corporate or government bonds.

According to Macquarie, for every £1 billion that UK pension funds allocate from corporate bonds to infrastructure debt, a reduction in pension fund deficits of approximately £270 million could be achieved.

The white paper presents a framework for pension funds to appraise opportunities to invest in private debt markets.

It goes beyond comparing the headline yield on a debt investment and also considers the liability matching properties - which support a pension fund's ability to generate additional returns by mitigating the need for cash and gilt allocations for interest rate and inflation hedging.

James Wilson, co-Head of MIDIS, said: "Pension fund solvency levels have been impacted by recent falls in gilt yields and they need to find more affordable ways of hedging their interest rate and inflation exposures.

"In view of the LDI benefits identified in the white paper, and the scale of financing requirements for UK infrastructure, we believe that infrastructure debt represents an asset class which can play a significant role in addressing the record deficits being reported by defined benefit pension schemes."

MIDIS was first launched in 2012 from London and has subsequently built a significant presence across the UK and Europe.

It has been awarded mandates in excess of £4 billion globally, including through the first ever pooled fund with a specific focus on UK inflation-linked infrastructure debt.

First published 06.10.2016


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Pension Funds

Young people are biggest personal pension savers, says HMRC

The figures show that under 35s now represent the largest group, making up 34% of those who contribute to a personal pension.

HMRC says they challenge the perception that the younger generation lives for the moment and neglects the need to save for the future.

2.7million under 35s are reported to be contributing to a personal pension – the highest number since records began, and up 35% on the previous year.

Alistair McQueen, savings and retirement manager at Aviva, said: "The financial challenges facing the younger generation are well reported – including rocketing property prices, student debt and job insecurity - so it is therefore hugely to their credit that they are leading the way in Britain's pension revival."

One area of concern, however, is the decline in saving amongst the self-employed community.

The number of self-employed people saving in a personal pension has fallen to 380,000 in 2014-15 – the lowest number since records began in 2001, down from a peak of 1.2 million in 2002-03.

"As the number of people who are self-employed continues to increase – reaching 4.7 million in the latest official statistics – it is concerning to see the number of savers in this community continues to fall," McQueen said.

He added that automatic enrolment has played a big part in this pensions revival.

"In 2017, the government will review the future of automatic enrolment and we are committed to its continued success and have launched our own Pre-Review ahead of the government's formal review."

By contrast, a separate report by Now Pensions found nearly half of 18-30 year olds admit to poor knowledge of pensions, while three in five don't know what a workplace pension is.

Now Pensions CEO Morten Nilsson, said: "This pensions blind spot amongst younger people should be raising a warning flag for the government and industry.

"Auto enrolment is going to bring thousands of younger people into workplace pension saving, but if their understanding is poor, there's a real risk that the policy will be undermined.

"The industry needs to work harder to eradicate jargon, making pensions more understandable for young people so the benefits are better understood."

First published 06.09.2016


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Pension Funds

ICI Pension Fund completes five buy-ins

Two of the buy-ins, £390m with Legal & General and £590m with Scottish Widows, took place in September.

They bring the total liabilities insured since 2013 to more than £8bn across 11 transactions.

The Fund has insured more than twice the amount of liabilities through buy-ins than any other UK pension fund.

Heath Mottram, CEO of the ICI pension fund, said the Fund has benefited from competitive pricing: "Competitive pricing benefits us on a frequent and ongoing basis, due to the strength of our governance and unique contract documentation."

"We see this becoming a blueprint for how larger schemes will insure their liabilities at scale through buy-ins in the future," he said.

Pension consultant LCP, estimates the Fund has saved more than £100m in the past two years through insuring liabilities over time with a panel of insurers through umbrella contracts – an approach that has a number of advantages.

It means insurers know the fund can transact quickly if pricing is competitive – and they reward this certainty with keener pricing, effectively placing the Fund at the front of the queue.

The Fund can also move quickly to lock in market opportunities as they arise, such as the £750m buy-in executed with L&G in the week after the EU referendum vote in June.

Clive Wellsteed, partner at LCP, said: "With a knowledgeable and proactive trustee board, well-rehearsed processes and umbrella contracts with insurers already in place, we have been able to achieve considerable savings in insurer pricing – even a conservative estimate would put the saving for the Fund at well over £100m over the past two years."

"We have seen an increase in insurer appetite and activity since the referendum in June, and for schemes holding bonds or gilts there are compelling opportunities to de-risk at attractive levels through buy-ins," he added.

First published 06.10.2016


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Pension Funds

Small businesses have 'pensions stage fright', says FSB

It says despite fines of £500 per day for businesses with between 5 and 49 employees, until compliance with the legislation is proved, there is a low level of understanding about what pensions auto-enrolment means for them.

Under workplace pensions law, introduced in 2012, all UK businesses were allocated a staging date by which they must set up a workplace pension scheme.

Paul Baker, senior partner of IFS employee benefits at FSB, said it's essential smaller businesses comply:

"It is wrong to think no action is required if you only have one employee, or all your employees are opting out of having a Workplace Pension.There's no point shying away from Workplace Pensions and doing nothing."

Around 1.8 million smaller businesses need to set up a scheme between now and 2018 and it is calculated that fines levied on these businesses for non-compliance are likely to be in the region of £22million.

The FSB has set up a workplace pension scheme in conjunction with Legal & General, which it says is already helping its member businesses get over stage fright.

More than 4,500 FSB members have already taken advantage of the member-only scheme and a further 18,000 are currently going through the enrolment process for their individual staging dates.

Baker says smaller businesses should consider the scheme because not all workplace pension providers want to work with them.

He said: "This reduced the options available, which could be a critical factor when the last-minute scramble to set up a scheme occurs. It can take three or four months for some schemes to be up and running, so smaller businesses getting over their stage fright on a just-in-time basis need to beware of being stuck in a back-log, or not being offered a pension scheme at all."

First published 29.09.2016


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Pension Funds

One in three people has pension through auto-enrolment

A survey from workplace pension provider, Smart Pension, found that one in three British employees now have a pension set up through auto-enrolment.

The independent poll, conducted by YouGov on behalf of Smart Pension, found 36% of employees questioned said their pensions were created under auto-enrolment.

It also found 28% of employees said they had a non-auto enrolled pension, 17% had a standard personal pension (SPP), and 8% had a self-invested personal pension (SIPP) and 7% had a stakeholder pension.

6% didn't know what sort of pension they had, and 17% didn't have a pension at all.

Will Wynne, co-founder and managing director of Smart Pension, said: "Auto enrolment has already overtaken every other form of pension, including personal pensions, in a very short space of time."

"We will be keeping a close eye on this with a regular biannual independent State of the Nation poll."

According to the Pensions Regulator more than six million workers have been automatically enrolled into a workplace pension since 2012.

Regional variation

A second YouGov poll of eleven cities showed that Bristol has the highest percentage of workers with an auto enrolled workplace pension – at 52%- compared with London, where only 26% have auto enrolled.

One in five (19%) of the British workforce said they either had or would be opting out of their workplace scheme, exceeding the government's forecast of 15% opt out rate overall.

The survey also revealed almost six out of ten (56%) believe they are not saving enough, despite growing uncertainty over the future of the state pension and falling savings rates.

"It seems everyone understands the need to save for their retirement, yet many are simply brushing the issue of pensions under the carpet," said Wynne.

"In a period when savings are being hammered by falling interest rates, workplace pensions are an effective way of funding retirement."

First published 29.09.2016


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Pension Funds

PASA call on industry to raise standards

The campaign is calling on pension industry individuals and organisations to join them in raising standards in pension administration.

PASA says the industry is in "unprecedented" times, due to a number of factors, including auto-enrolment, GMP reconciliations and the end of contracting out.

All of these factors mean it has never been so important to ensure the highest possible standards, it says.

PASA will campaign throughout October and wants key industry stakeholders to support them.

Margaret Snowdon, chair of PASA, said: "We have strengthened the voice of the pensions administration industry so that it is now heard and listened to in government, government departments and by our industry regulators."

The campaign will focus on a different group each week.

Week one will be focused on the role of PASA experts, week two - committee members, week three will look at workgroup members, and the final week focuses on becoming a PASA member.

"While we are already in a fantastic position, we want to do more, and we have big ambitions for the future," said Snowdon.

"The things we will be focusing on include: supporting more members in achieving accreditation; responding on government consultations; initiating thought leadership pieces through our policy and strategy committee; and continuing our lobbying efforts within the industry."

Throughout October, PASA will be talking directly to key stakeholders and prospective members.

"We have been fortunate to work with members and volunteers who share our passion to make a difference and to adopt standards which make for better outcomes for the members of pension schemes, but we want to make our voice stronger and louder."

"The more our membership grows, the stronger we will be and the more impact we can have," Snowdon.

You can follow PASA on Twitter or join their LinkedIn group.

First published 29.09.2016


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