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The PPF has the key role in determining DB options going forward.

This is the part of the pensions market where Government has little to lose and much to gain out of intervention and its key player is the PPF. While the DWP set the law and TPR the guidance that enables it, the PPF is the consolidator of last resort. As I have said several times recently, the PPF is an actor but it guarantees nothing. If the PPF fails, people get lower pensions, the taxpayer is not on the hook.


The DB end-game (King Lear Act V)

In the envisaged landscape (the Mansion House fantasy version), those schemes that are acceptable to insurers, buy-out.  Or they “run off” – meeting the guidance of tPR’s DB funding code.

Schemes that don’t make the cut on funding , don’t get a shot at “buy-out” but can consolidate using a superfund. They can choose to run-off but are unlikely to get a bespoke funding path and will need to follow TPR’s “fast-track” (a route-march ).

Schemes that don’t make the cut on funding and struggle on “fast-track” head for PPF assessment and their sponsors to administration.

Consolidation is a win for the DWP and Government. Insurers do not embrace productive finance as the Government thinks of it. For the Mansion House reforms to happen , there need to be large consolidated schemes with the time, capital and expertise to manage these lucrative but difficult assets.  Britain needs consolidation along with buy-out.

This is how it’s supposed to work but this is the “fantasy pensions” of the Mansion House vision.

What we saw on Wednesday was that the only actors  with control are  the insurance companies that “strut and fret their hour upon the stage”. In this case – the stage was a parliamentary committee room, the audience a group of MPs led by Chair Stephen Timms.

To say that insurers have a strong hand is to understate matters. In the second act of the drama, after the ABI and PIC had pushed off, Luke Webster, Adam Saron and Simon True turned up. It was like the final act of King Lear, the actors still live but they do so in a world seemingly devoid of hope. No business has been transacted by superfunds nor is likely to so long as the Pensions Regulator’s guidance offers no means for them to open their doors.

Simon True (CEO of Clara) told a particularly sorry tale. Thier 2002 pipeline, which they had hoped to conduct to the insurers over 5 to 10 years , announced they had been bought out rendering Clara redundant. What is the purpose of a superfund that is working for  masters who eat your lunch?

Luke Webster of Pension Superfund may have surprised MPs by being even more direct. He told them that he and his organisation had no intention of re-applying to be a superfund until the rules of the game were made clear and the prospect of acceptance worth the application.

All that was left for MPs to hear, were the sad whimperings of a couple of asset managers , forlornly hoping that their master trusts might offer some short term relief to small DB schemes. Appearing alongside Tracy Blackwell and Yvonne Braun , they were extras to the main event.


Where was the PPF?

Life goes on after King Lear, but it is a life devoid of hope. So with the DB landscape, there is only hope of buy-out or the unimaginable terror of the “other”.

But of course this is fantasy pensions, pensions as played out by the insurers and their stage manager, the Pensions Regulator.

In the real world there is a Fortinbras come from Norway (the PPF) , or a Donald come from England (the PPF) to restore order.

The PPF want to become a consolidator and in a recent conversation with them , it became clear that they don’t just want to be the guys that drag dead bodies of the stage.

No rapture

N or do they see themselves as the “deus ex machina” envisaged by the Tony Blair Institute, stepping in with God-like authority to create a “rapture” for small schemes.

Instead, they see the options available to DB schemes much like the options open to employers when staging auto-enrolment.


Restoring order

It is clear to me and to many like me that there are precious few options open to DB schemes that do not start and end with insurance buy-out.

The consolidation market seems no closer to happening  than in 2018 when the DWP announced it. The villain of the piece, the ABI and its membership, has been abetted by TPR who seem unable to countenance commercial consolidation, any more than they could see past Nest when the workplace pension market was forming.

But order did come to the workplace pension market. Government brought Nest to the table and table agreed how it would play with and against commercial workplace pension providers. The result is what we have today, a well-formed market.

For Nest – read the PPF.

It is now time for the PPF to get on the front foot in this debate as Nest did in 2010 and make it clear to the Pensions Regulator that it cannot consolidate alone but needs to work with commercial consolidators. It must also make it clear that the rules must make it possible for commercial consolidators to transact business.

Whether the PPF weren’t invited or didn’t want to appear, they were the actor missing from the 2 Act drama in parliament on Wednesday.

The PPF has produced a robust and readable submission to the DWP on the vision it has for DB options. I hope that it will get well read and that from it, we can have options for DB which best suit the needs of trustees, sponsors and most of all members.

Hope to a dying man

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