
DESTINATIONS
Whilst the PPF, DWP and Select Committee have listened and adjusted in light of some of our and others’ feedback, we believe there is an important wider role we can fulfil because the pension system is in constant flux and often the outcomes of policies follow the laws of unintended consequences. This is especially the case when key players such as TPR, the PPF, the ONS and independent experts are basing their decisions and policies on very different data sets. The regulator’s data is between two and four years out of date. Gaps between some measures between TPR and the ONS are huge – approaching £300 billion.
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The Group argues that pushing forwards with reforms in DB Pensions should be halted until TPR, the PPF, the ONS and independent experts can agree the scale of assets, liabilities in the system, the proportions of schemes in surplus or deficit and those capable of buyout.


We note that the PPF is hugely over-funded because the levies were set too high. Whilst the tax levied on returning a surplus to the sponsor has been reduced from 35% to 25%, it ought to be refunded to sponsors with interest to bolster their investment.
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We are concerned that the idea from the PPF of becoming a public consolidator for small schemes will be unattractive to the private sector because the regulator is planning far too high a bar on entry. We are not confident that the PPF has the skills to manage consolidated funds.
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We constantly monitor political and policy development across the DB Pension landscape, reach out for insights and expertise and feed these into the policymaking process.