When it comes to poor practice “sunlight is the best disinfectant”. But the sun never shines on the whereabouts of occupational DC schemes, which are supposed to run their own websites for the benefit of all, but whose whereabouts on the inter-web are lost to the nether pages of search engines.
There are supposed to be 1200 occupational schemes which are meaningful enough in size to trouble the DWP but which do not have £100m in assets. So which schemes are they and how could I find out if I was in one. If I was a forward thinking data analyst looking to help trustees with their net performance, data quality testing and IRR calculations, how would I put together my marketing campaign.
The answer is that the only databases that you could consult are private , belonging to the PLSA (their membership list) and Philips, whose Blue Book now costs the thick end of £500 for each annual copy.
This ridiculous state of affairs results from the incapacity of the Pensions Regulator to share the information it gets in its scheme returns with the public. I wrote to them and got this reply
TPR does hold a register of occupational schemes and the trustees, but we don’t share it as it’s restricted information under the Pensions Act 2004. The only trustee details we publish are those of the ITs (independent trustees) on our register of trustees that we appoint to schemes in certain circumstances – it’s not available on line but a copy can be requested (About the trustee register | The Pensions Regulator).
We don’t currently hold website details, though we are hoping to start collecting the urls for the VFM, charges and investment information that trustees are (or will shortly be) required to publish on line, via the annual scheme return. We have not yet taken a decision on whether we will publish that information – I think it’s something we would like to do but there are a number of hurdles that we may or may not be able to clear.
We really need to do something about this and immediately. If an occupational pension scheme , managing many millions of pounds of people’s money cannot be identified by a simple search on your browser then it’s small wonder that we have £20bn missing in DC benefits.
With the pensions dashboard a minimum of 2 years away, the DWP pension finder service is still dependent on the most primitive of matching of inputs.
Every time a scheme return references a microsite set up by or for trustees, that URL should be cut and pasted onto a register of schemes available for public scrutiny regardless of Pensions Act 2004.
Why the register of occupational pension schemes held by the Pensions Regulator is restricted information is a matter for a separate blog. Here I am concerning myself with the stated aim of the Pensions Regulator for schemes to publish information about the charges members pay and the value they get for those charges, and their inability to point us to where this information is available.
Protecting the family
The GDPR was supposed to put us in contact with information that was in the public domain, but the pensions industry seems to have found ways to hide the information to all but immediate family.
By immediate family, I mean the small number of advisers and regulators to whom the information circulates and perhaps the active membership of the scheme. Circulation of information to deferred members of pension schemes is as rare as finding hen’s teeth and as the majority of occupational pension scheme members are deferred, it is almost impossible for a deferred member to find out about their scheme, their charges and their investment performance. Nor will they find out any of the declarations on TCFD, statement of investment principles or the Chair Statements themselves, all of which are supposed to be publicly available and on-line.
It is hard to work out why this information is not in the public domain and readily accessible via a web-based register such as the register maintained by the FCA on regulated advisers.
My suspicion is that for anything to happen in this area, there would need to be support from the scheme advisers who control the trustee’s output. It is absolutely not in the interest of scheme advisers to make public, information on who is advising and what they are advising on. The family sticks together and mans the barricades against incoming searches.
Impact on consolidation
If the Government are serious about changing the current state of affairs and moving on the small poor governed occupational DC schemes, they are going to have to find some means of disrupting the status quo.
Simply leaving the provision of information as it is , is to allow the millions of words and numbers published in Trustee Chair Statements to rot and fester in the private drives of the trustee and its secretariat.
The IGCSs and GAAs have a publishing season and have websites on which Chair Statements are readily available. But there is no such accessibility of information on occupational schemes and if you want to find a list of what you can find, you will have to pay dearly for it.
Which means that the innovation which the DWP are calling for , will be restricted to the usual suspects who know where their clients are, and those – like AgeWage – who have new and interesting ways of looking at performance, data quality and member disclosures will be locked out.
It is imperative that the DWP looks to its own regulator to deliver information on the websites of the schemes it regulates to the general public and that this is done without delay. Barriers to success in its endeavors include the “hurdles” that the Pension Regulator feels “it has to clear”. Let’s hear about those hurdles and see if we can help!