“Nothing to see here” -TPR quietly publishes its 2022 stakeholder research.

The Pensions Regulator  published in March its annual stakeholder research produced by Savanta ComRes which can be accessed from a link at the bottom of this blog.

In this blog I argue that this document has been produced  by TPR to provide comfort that it’s house is in good order. We don’t know the 50 stakeholders and they spoke a long time ago.  TPR appears to be  pulling winter wool over its own eyes, and  ours.

I suspect that it finds this research a little embarrassing.  For it appears to have been published and forgotten. Summer research published the following spring sound unseasonable. A lot has happened in the meantime though you wouldn’t guess so.

Last Autumn,  tPR has had to deal with the biggest market failure ever created by occupational pensions. LDI is not mentioned in this document.

How this research would be  judged by stakeholders in May 2023 (when I became aware of it)  is likely to be markedly different from perceptions last summer. Which makes reading the document surreal.

Here is the summary.

I may have been one of the 50 Stakeholders interviewed – I have been on TPR stakeholder panels in the past, but I can’t remember having any of the perceptions above. I am more in line with Robin Ellison who considers tPR over resourced and under-delivering.

If this “industry-body stakeholder” is me, then I’d stand by my comment

While this research was being conducted, margin calls were being made to occupational schemes that were committed to the objectives of self -sufficiency or buy-out that underpinned the DB funding code.

Shortly after this research was carried out, the de-risking strategies blew up. The funding code, which had been expected to land at the end of 2023 has been delayed again, it may never be published.

Writing in the Spring of 2023, the Pension Regulator responds complacently

We are pleased to see from the research that stakeholders recognise the effort and progress in many of the workstreams we are undertaking to address these challenges and to improve outcomes for savers. We have taken on board the feedback which informs our thinking and planning.

Presumably we are supposed to gently clap our hands and agree.

A stakeholder writes!

I do not agree with the tone, perceptions or conclusions in this document. I think it inadequately expresses the genuine concerns of stakeholders like me and many readers of this blog,

What has happened in the seven months since LDI blew up shows that the majority of the 50 stakeholders who contributed to this survey were endorsing the regulatory failings  that the Work and Pension Committee, the Treasury Select Committee, The Industry and Regulation Committee and parliament as a whole has discovered since the mini-budget.

  1. That the leverage in LDI was toxic and not properly stress tested by TPR
  2. That the amount of leveraged LDI in corporate DB pensions created a systemic risk
  3. That when the unexpected happened, it took the Bank of England’s intervention to steady the ship.


We have a CDC funding code but it has only approved one scheme since mooted in 2018. That scheme has yet to open

We have a superfund approval system that has only approved one scheme since the 2018 consultation – Clara – which has yet to announce a deal

There has been no formal response to the 2018 superfund consultation.

As mentioned above, the DB funding code looks likely never to see the light of day.

On the plus side, it is good to see TPR and FCA working better together. I agree that the co-operation on the VFM framework is a good example. The master trust authorization process is criticized for its slowness but is the only process that has actually authorised any pensions that are actively helping “savers”. Auto enrolment continues to be well managed.

I can live with this statement with regards policy.

This co-operation came only when Guy Opperman demanded it and after he had taken the VFM framework back from the regulators and demanded it be managed by the DWP. The DWP and FCA have a long way to go when it comes to more mundane matters. Efforts to create a restitution scheme as an option for ill-advised steelworkers are showing little sign of progress.

Hearing what you want to hear.

The Pensions Regulator, by dint of its powers, gets told what it wants to hear. The point of the stakeholder panel (when launched) was to hold TPR accountable by listening to stakeholders who were not in TPR’s thrall. But the original intentions seem to have diluted in intent.

There is still some value in this Stakeholder Research –   the quotes do sound authentic.  But they are selective quotes and editing of the document means that few will get beyond the overall perceptions (quoted above).

2022 was not a good year for TPR.  This document makes is sound like business as usual.

If the Pensions Regulator continues to promote itself through selective feedback while ignoring its own failings – it  will create more problems in the future, as if we haven’t had enough already.

Link to the publication

The document is downloadable as a PDF, from this link.



About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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1 Response to “Nothing to see here” -TPR quietly publishes its 2022 stakeholder research.

  1. jnamdoc says:

    Not unexpected. Even with the benefit of hindsight, a complete lack of self-awareness. But understandable – the lawyer gateway within TPR will not allow anything to be published that points to responsibility or culpability for the monumental loss of value wrought by the Sept/Oct22 LDI meltdown, or the terminal malaise that TPR funding policy has / is inflicting on our economic prospects. All self-interested bodies work against the greater good.

    If/once you understand that TPR considers that the solution to its (myopic) remit is the Insurers (and indeed I’ve heard a number “professional” trustees (still) advocating recently that the buy-in is of course still the “gold-standard” for funding objectives), then you can appreciate why TPR is effectively seen as the trade-body for the Insurers. Think – who does it benefit?

    Certainly, under its direction, one major growth area in pensions has been the Insurers and consolidators scrambling to take over Trustees’ assets on a very fully funded basis, while of course the provision of DB pensions (the actual gold standard for the working people) have declined, as has DB support for the wider economy.

    Uncomfortable though it may be, time for the TPR to think about how to increase workers’ pensions and its role in the broader economy.

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