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DC Administration Governance?

17 November 2017

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Lucy Collet asks: What do you think of when you think of DC Governance?

For many, exciting fund strategies and investment performances being discussed in swishy city offices will spring to mind - the fun and glamourous side of pensions. But the importance of administration in DC governance is vital, if not quite as exciting.

The PASA Standards were put in place as an outcome based guide to what good administration should look like, and they cover all types of pension scheme. However, there are some challenges and topics which are unique to DC arrangements. PASA feels there is a place, and a need, for additional DC specific administration standards, which could eventually be brought in to the PASA Accreditation process.

Good DC administration is not simply the responsibility of a scheme's administrator. Oversight and governance is at three levels – the administrator/provider, the employer and the trustees. Regular communications and input from the scheme's employer and trustees are required to ensure that processes are holistic and effective, members are engaged, data is good, issues are identified quickly to avoid the dreaded rectification and that reporting is useful and clear - as well as understood by all parties.

We all know DC is on the rise, and there is more choice in terms of the type of arrangements available. Group DC arrangements such as Group Personal Pensions (GPPs) and Master Trusts have led to confusion for some employers in terms of defining responsibilities and rights to access for certain information. What belongs to the employer and what belongs to the trustees – where do the employer's responsibilities end and where do the administrators/trustees' start?

The arrival of automatic enrolment has led to a whole new market of employers appointing a pension provider, often for the first time. Many of these employers will not have a dedicated pensions or reward resource. If employers with established pensions departments are experiencing confusion over where the lines of responsibilities lie, what hope do employers with no experience of pensions and only a desire to do the right thing by their employees have?

Clear, useful and meaningful administration reporting is essential for good DC Governance to all involved. All stakeholders need to understand the content of the reporting and be able to identify what is essential, what is useful, what is a 'nice to have'. More importantly, robust, relevant and meaningful Service Levels (SLAs) need to be agreed. Skilful interpretation of the regular reporting will allow the administrator, employer and trustees to identify any service issues in amongst the detail.

Employers in a group arrangement should be aware providers produce administration reporting at a combined level. Knowledgeable interpretation of this reporting will identify where data is referring to activities across the book of business, rather than data directly relating to the service their employee members are receiving. Trustees are more likely to receive more scheme specific reporting, but is the information they are receiving meaningful and helpful to them in ensuring their members receive good outcomes?

As a first step towards producing DC specific Standards, PASA has invited key individuals from across the industry with wide ranging skill sets and expertise to form the DC Governance Working Group (DCGWG). With Board sponsorship, PASA has brought together people with a rich and diverse perspective who can ensure nothing falls through the gaps. The DCGWG met for the first-time last week (09/11/2017) to discuss the main issues impacting on DC administration, and agree key areas of focus.

The Group agreed six initial areas of focus; Data, Employers, Transitions, Decumulation, Reporting, and Controls and Procedures. The DCGWG is not a talking shop, its task is to produce meaningful standards and guidance for trustees and employers which are applicable across the DC universe. TPR is a welcome observer and is keeping a close eye on the group's findings as they develop. It is anticipated our initial findings will be published in Spring 2018.

Lucy Collett, member of the DC Governance Working Group and Secretary to the PASA Board & Kim Gubler, Deputy Chair of PASA