The new Mastertrust Assurance Framework (MAF)

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Amidst the deluge of new consultations, the joint consultation on the Mastertrust Governance has been pretty well lost to sight. Published last week it can be found here. It’s the work of a group of accountants (organised by the ICAEW) and the Pensions Regulator and it looks to build on the 6 good DC outcomes/6DC Principles and 31 Characteristics framework. Which is good in terms of continuity with the past but not so good as the future is taking us way beyond the limited vision of a Risk-based Regulator.

A joyless document

It’s a joyless document which defined the three principals at the party as being the Responsible Party (the trustees), the intended users (the employers) and the Practitioner (the auditor). You get a feel for what’s going on here. This is governance three steps removed from the person saving money. The language is obscure, the syntax tortuos and the document refers to rafts of previous standards , most of which don’t have names but only numbers.

One for the grey squirrels

This is what pushes Governance into a place where no one wants to go. It is why the “red squrrel” member nominated trustees – with an agenda to maximisie member outcomes are being driven out by the “grey squirrel” professional corporate trustees.

In this world of internal controls, mapping a framework around 31 characteristics of a good DC scheme makes sense. Yet this peice of work is lost to Appendix I and 2. The bulk of the document is simply telling us the procedure that was followed to get the document out.

Any document that relegates its output to an appendix has some serious “prioritisation issues”.

Ignoring the Command Papers

And the sad thing is that this document, following in the wake of the excellent Treasury and DWP Command Papers reads as if the proposals for 2015 which directly impact on the MAF simply weren’t out there.

Presumably, having decided that process was more important than output, they weren’t going to let a couple of documents focussing on what people want get in the way of the principal objective of risk based governance.

The substance of the document in the two appendices works for the world of yesterday. But it does not work for tomorrow’w world where the emphasis is shifting towards clarity,transparancy and open governance. Governance behind the closed doors of the ICAEW and the Pensions Regulator has become so sterile and disconnected from what matters to ordinary folk that I wonder if it is not (in a strange way) bringing pensions into disrepute.

But helpful nonetheless!

All of which is bound to get me into trouble with the ICAEW and tPR and will go down like a lead balloon with most corporate and professional trustees.

If you are interested in the points raised in this blog, you might also be interested in this.  The Assurance Summit is a FREE virtual event which offers you the chance to listen to a great range of speakers (including me) – and engage with the discussions – without leaving your desk!

The Summit will address topics which are important to all of us involved in governance, audit or assurance or just interested in the new Master Trust Assurance framework. 

The theme this year is “Building Trust – taking assurance to new heights!”   If you would like to find out more and to register, go to http://www.assurancesummit.com

The Summit, which is being hosted by Andrew Riley from Assure UK, will run for 5 days from 19 May 2014.  You can find out more details about the speakers and their topics on the website, but here’s a taster:

Andrew Riley – Assure UK, Innovations and challenges in auditing Master Trusts, culture and compliance 

Frank Curtiss– RPMI Railpen Investments, Ways to improve governance reporting and assurance over the UK Stewardship Code

Sue Applegarth – Ensign, Building trust with your clients: how the new PASA pension accreditation demonstrates the latest thinking in assurance

Marc Wright, simplygroup, “Escape from Audit Groundhog Day” – the role of social media in creating trust-building audit practices

Richard Owen – Compaso Innovative tools in learning: new technology for better audits through shared real-time scenarios and experiences

John Webb – Webb Sight Consultancy Ltd, What to do when your internal controls go wrong

Phil Yeoman – The Pensions Regulator, The case for DC Master Trust AAF 02/07 Assurance

Henry Tapper, First Actuarial and the Pension PlayPen, What makes for good governance from a Master Trust?

Ezri Carlebach Communications consultant and the IAB, How to ‘nail’ pension communications to achieve and surpass the AAF 02/07 Master Trust assurance standard

Tim Roberts – Good Measures, Securing pensions long-term: taking account of the new world order

Ian Armfield, Taking ISAE 3402 and AAF’ assurance to a new level including the new Master Trust framework

Jeremy Evans, Veriscan Security UK and Jeremy Evans Associates Ltd, How to get the best assurance and assurance reporting from ISO 27001

And here’s a taste of what they’ll be covering:

Innovations and challenges in auditing Master Trusts, culture and compliance 

Ways to improve governance reporting and assurance over the UK Stewardship Code

Building trust with your clients: how the new PASA pension accreditation demonstrates the latest thinking in assurance

“Escape from Audit Groundhog Day” – the role of social media in creating trust-building audit practices

Innovative tools in learning: new technology for better audits through shared real-time scenarios and experiences

What to do when your internal controls go wrong

The case for DC Master Trust AAF 02/07 Assurance

What makes for good governance from a Master Trust?

How to ‘nail’ pension communications to achieve and surpass the AAF 02/07 Master Trust assurance standard

Securing pensions long-term: taking account of the new world order

Taking ISAE 3402 and AAF’ assurance to a new level including the new Master Trust framework

How to get the best assurance and assurance reporting from ISO 27001

Good listening!

 

Ths post was first published in http://www.pensionplaypen.com/top-thinking

 

Better hid

About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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