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DC Governance – a tale of the Good, the Bad and the Ugly

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An analogy comparing DC governance to a spaghetti western (however iconic!) may seem tenuous – but when PASA reviewed TPR’s recently published ‘Defined Contribution trust-based pension scheme research report’, it was more relevant than you might at first imagine.

There is some good going on out there. Where data issues were identified, 72% of schemes have worked on corrections, encompassing 100% of small schemes, 91% of large schemes and 88% of master trusts.
In addition, 45% have implemented a new or updated data improvement plan, with the highest proportion being amongst medium to large schemes and master trusts. This is important as we know issues go unnoticed for years and unpicking stuff is hard and costly. This is backed up by 53% giving ‘repairing administration issues’ a top rating. 88% of these were master trusts, 85% large and 64% medium sized schemes.

Levels of interaction with TPR appears good across the board, with 77% of schemes having visited TPR’s website in the last 12 months. Medium and large schemes, as well as master trusts, have a particularly high level of engagement here, indicating a strong desire to get things right and to adopt best practice.
Unfortunately, the report also highlighted some bad practice.

Of those responding to the survey, 44% said administration was on their meeting agendas only once a year and 18% never! Taking it down a level, you could perhaps argue it’s understandable 51% of micro schemes only look at annually, but disappointingly 5% of large schemes, 16% of medium schemes and 49% of small schemes also only focus on admin once a year.

Similarly, 92% overall said they had not identified any data issues over the last two years. The implication here is if they are not discussing administration and/or don’t have an administration strategy, it’s likely a good proportion are not actually reviewing their data – so how would they know?

While there are positive statistics on how schemes are looking to enhance member experiences, we’d question how they can do this it without administration input or an administration strategy. Although more of the larger schemes (57%) and Master Trusts (63%) have a strategy, 65% of schemes overall don’t. This is particularly concerning at the smaller end with only 28% of micro and 46% of small schemes having an administration strategy in place. Is it realistic to seek to improve members’ experience without a strategy, or at least input from your administrator?

Responses relating to member engagement at the smaller end is similarly a cause for concern. Of micro and small schemes, 26% believe member engagement is of low importance, and 20% of schemes saying it’s not important at all. With nearly 40% of schemes having no process in place to engage with members on their retirement plans, how can they be sure members are making the right decisions for their circumstances? How can trustees’ work in members best interests if they don’t know what members want?

What about the ugly? The number of ‘don’t know’ responses struck us as particularly concerning. Respondents should have been in a position to answer the questions. In particular, overall 37% didn’t know how administration performance was measured. While this was highest amongst micro and small schemes, in itself this perhaps reinforces why there’s a drive to push smaller schemes to consolidate.

Another area where there were a lot of don’t knows, was in relation to accreditation achieved by schemes. This was consistent at 50% across all scheme sizes, with most of the highest scores being given to the Pension Scams Industry Group’s code of good practice at 68% confirming they comply and a lower level of 30% not knowing. The lack of knowledge in this area suggests a lack of importance or value is being placed on these accreditations, which (including our own!) we would see as being hugely beneficial in ensuring high standards of governance. It was of particular interest to note 25% of Master Trusts reported their schemes to be PASA accredited, and a further 44% were unsure if they held this award. The truth is there are currently no Master Trusts with PASA accredited administration. This is an area of particular concern for us and we urge the Trustees of these arrangements to consider our accreditation programme.

In conclusion, while we aren’t suggesting Clint Eastwood is about to ride into town, this survey has highlighted there appears to be practices out there more akin to the wild west than we and members might hope or expect. To ‘turn our DC town around’ trustee boards can’t leave the responsibility to Sheriff TPR, they need to take responsibility for getting their individual houses in order.

David Pharo, PASA Board Director and Board sponsor of the PASA DC Governance Working Group