19 Apr 2024

Consultation

In February 2024, the Department of Works & Pensions (DWP) published, in relation to Defined Benefit (DB) schemes, a consultation on the treatment of scheme surpluses and a model for a public sector consolidator. With the assistance of AREF's Public Policy Committee, AREF submitted a response to the call for evidence on 19 April 2024. In the response we asked for an approach that would enable sponsors to benefit from surpluses whilst also encouraging investment in the real economy and providing scheme members with a greater buffer against market volatility. We believed this could be achieved by allowing partial withdrawal of surpluses on an ongoing basis spread over
time funded by investing current surpluses in higher returning illiquid assets.

Call for Evidence

On 22 November 2023, DWP published a response to its call for evidence on how DB pension schemes could use their assets more flexibly.

The call for evidence focused on three areas:

  • DB investment in productive finance, including international comparisons and incentives for trustees to invest more in productive finance;
  • building surplus, including current and potential future conditions for extraction of surplus from DB schemes, encouraging scheme investment in productive finance, and transferring surplus between DB and Defined Contribution (DC) schemes where an employer sponsors both types of scheme.
  • public consolidation, including the need for and potential impacts of a public consolidator on the current DB pensions landscape, a potential role for the Pension Protection Fund (PPF) as a public consolidator, the potential impact of a public consolidator on productive finance investment, and the mechanics of a potential public consolidator.

With the assistance of AREF's Public Policy Committee, AREF submitted a response to the call for evidence on 5 September 2023. This focused on our observations regarding disincentives to trustees and sponsors of DB schemes to consider investing in productive assets. We pointed out that investments in assets that do not fit within the Solvency II Matching Adjustment regime are generally not attractive to participating insurers. Without change, DB schemes will continue to dispose of productive assets to facilitate transfers to insurers. Also, we asked for wider range of options for DB schemes. Consolidation of DB schemes would allow greater access to the skills needed to invest in less liquid assets. It may also facilitate the run-off of pension liabilities outside an insurance regime and this may, in turn, facilitate greater investment in productive finance.

In the Government's response, they noted that "As the funding position of many DB pension schemes has improved, many schemes have pursued insurance buy-out as a long-term solution to securing member benefits. While we believe that buy-out will remain an attractive option for many schemes, responses to our call for evidence suggest 'running on' may have benefits for sponsoring employers and the wider economy. We are keen to work with all stakeholders to ensure extracting surplus that may build up if such schemes are investing in productive assets can be made easier, while always protecting member benefits."

 

Author

Jacqui Bungay

Jacqui Bungay

Head of Policy and Company Secretary, AREF

Jacqui is AREF’s Company Secretary and provides policy guidance and secretariat services to AREF’s Board and Management Committee as well as many of AREF's committees and working groups.

Jacqui joined AREF in 2014 after working for over 25 years in fund compliance, client relationships and administration in the trustee and depositary sector.