The latest Command Paper, ‘Better workplace pensions: Putting savers’ interests first’, has recently been published. This Command Paper follows prior consultations by the Department for Work and Pensions (“DWP”) on charges, transparency and quality standards in workplace defined contribution pension schemes. The DWP has consulted on at least two further occasions regarding defined contribution pensions since the start of 2013. The DWP has not had a monopoly on changes and consultations though. The Financial Conduct Authority (“FCA”), HM Treasury and others have been in the defined contribution pension consultation mix too. There has certainly been opportunity to provide input into the re-shaping of the defined contribution pension environment – an inclusive approach that I welcome.
This latest Command Paper does overlap, in part, with the FCA’s recent consultation on Independent Governance Committees. The overlap is a function of the roles of the FCA, DWP and The Pensions Regulator (“TPR”) in governing the UK pension industry. This overlap is the outcome of multiple changes to the governance regime over time rather than a ‘clean sheet of paper’ design. TPR and the FCA helpfully published the ‘Guide to the regulation of workplace defined contribution pensions’ earlier this year to assist in navigating this governance arrangement.
We can’t change where we’ve come, from in terms of this governance set-up, but we can certainly (try) influence the future. Would a single point of pension industry governance not be in savers’, regulators’ and other industry participants’ best interests? This single point of accountability might result in fewer consultations (effectively covering the same ground though), greater ease of ensuring consistency across the industry and greater leverage of the available operating resources, among other benefits. The potential consolidation sounds like an occasion where one plus one might well equal more than two or is this case of double vision is going to be followed by a hangover?