In a comment on a recent blog, Derek Scott mentioned correspondence between the Pensions Minister and the FCA, correspondence that was referred to by Guy Opperman in his Zoom to the FCA yesterday.
Since Martyn Lewis challenged the “national disease of official letter writing“, we have been offered a prime example of how politician and civil servants write official letters in epistolary ping-pong.
The FCA and DWP did finally get “together” about TCFD by emails on 22 and 30 September 2020:
Derek’s comment informs on the TCFD letters
...this was already 5 weeks in to DWP’s very short period consultation (6 weeks in total, including weeks of extended schools holidays) on imposing TCFD reporting on pension trustees from 2021, when the FCA is only requiring fund managers to report, maybe, from 2022.
The TCFD recommendations published in 2017 run to some 66 pages. I suspect very, very few trustees will have read all of them, or even a summary of them. In April, one of the leading UK consultants on ESG matters (he/she must remain nameless, however) wrote this to me when I enquired about the Pensions Climate Risk Industry Group (PCRIG) consultation launched on 12 March 2020:
“Regarding the TCFD, their flagship recommendations paper is indeed 2-3 years old. Most of their work since then has been encouraging uptake of the recommendations [by translating them into Spanish, Portuguese, etc. it seems to me] although they are working on a number of updates (due this year, I believe, [but there’s still no sign of them in mid-October]). The recommendations aren’t tailored to UK pension schemes in any way, so I wouldn’t recommend looking at them in detail. Instead please take a look at …. PCRIG’s interpretation of them for pension trustees …..”
PCRIG was only formed in 2019. A Google search reveals no website, and I believe we may have been one of the very few boards of trustees even to be aware of their 2020 consultation.
That larger DB trustees are being asked to report TCFD from 2021, before UK fund managers may be required to report to their clients from 2022, still seems to me cart before the (race)horse by Mr Opperman’s over-reaching department. And whether overseas fund managers will report to similar standards, and from when, remains to be seen.
My other gripe is that these days the single largest holding for nearly all DB pension schemes will be issues by UK Government’s Debt Management Office, ie gilts. Promises that UK Government will do TCFD reporting are so far limited to CDC (formerly the Commonwealth Development Corporation) and UK Export Finance. Few DB trustees may have heard of either of these, and are even less likely to be investing with them. (I did once try to arrange a CDC loan from London for a bus company in East Africa at the beginning of the 1990s, at a time when one of the leading SRI services, of which I was also a subscriber – yes, my personal ESG credentials go back a long way – preferred British companies not to do any business with despotic politicians. I think they meant the ones in East Africa, not politicians closer to home.)
But it’s great business for the pensions consultants who want to do the ESG analysis for their put upon clients. It was no surprise to me that ESG consultants made contact within hours of Thérèse Coffey announcing DWP’s TCFD consultation in Glasgow on 26 August 2020. The consultants were eagerly offering their services to us and following up with summaries and more detailed papers on the disclosure projects they clearly want to sell to us.
From our members? Not a dicky-bird.
Those letters in full.