Master trust roundtable: Masters of destiny

Master trusts are set to dominate workplace pension as they pass the regulation hurdle and achieve scale – but who will pick up the pieces if there is a no-deal exit in March? John Lappin reports

The rise of the master trust seems unstoppable. Auto-enrolment has brought 10 million new savers into these giant schemes, while pressure from the Pensions  Regulator and employer demand has seen many own-trust schemes moving to master trusts as well.

Scale and resource is not just an issue for single-trust schemes – many smaller master trusts are waiting to see if they can make the grade in terms of authorisation. Yet for the big master trusts the dominant theme remains that they are set for soaring exponential growth.

The sector is predicted to grow to more than £300bn by 2026, and delegates at a Corporate Adviser round table, held in association with Aviva, were united in the belief that master trusts will dominate the large scheme market, although caveated by the view that rumours of the demise of the GPP are premature.

PwC head of defined contribution consulting Philip Smith pointed out that master trusts are not accepting business from across the whole market. “It does depend on the size of the employer and the quality of the scheme. The commercial master trusts have been quite selective about the business they want to take on,” he said.

“It is even the case with what you might consider to be a decent quality scheme, with good contribution rates but a lower paid population. We have just finished an exercise helping an employer in that space with 800 people, average salaries in the higher £20,000s to £30,000s, and a 12 per cent total contribution rate. No interest from the commercial master trust market at all. You are left with the Nests, the Nows and the People’s.

“At the top end, master trusts are dominating, and will continue to do so for a whole variety of reasons, primarily around governance and costs. With GPPs and GSipps, it is a mixed bag. With the drive towards scale and cost reduction, I don’t see that stopping any time soon.”

Hymans Robertson head of DC scheme design and provider evaluation Jesal Mistry said: “One of the key drivers to employers moving away from their own trust is the changes in regulation and

governance requirements in the last five years or so. That is forcing companies to think about not only the costs but the risks that they face with DC arrangements. So they ask how can we share this risk with someone else? Master trusts have become the option, because it is easy to move money there.”

Mistry did suggest that where and when employer pensions get to a billion or several billions in assets they start to think about running their own administration.  “At the really large end, we may see unbundling in five to 10 years’ time, but certainly for FTSE 250 firms, the trajectory is more towards master trusts than moving things away.”

Fund choice could still favour GPPs and GSipps

However, some panel members did see GPPs and particularly GSipps retaining their appeal for at least some parts of  the market – not least the smaller intermediary sector not reflected in the make-up of the panel.

Willis Towers Watson senior consultant Mark French said: “Master trusts may appear a bit too vanilla for more sophisticated investors. That may keep the appetite for group Sipps alive for longer. Or you might see hybrid arrangements where master trusts might partner with group Sipp providers to cater to both ends of the spectrum.”

He added that resourcing remains an issue for smaller trusts as well.“In terms of development, the traditional provider market has had the resources to be able to put a lot of budget towards pension products, especially with digital developments. Will the master trust side be able to be able to keep up? That could put them ahead of some sections of the master trust market.”

Barnett Waddingham client relationship manager Martin Willis also argued that differences between the two models would see at least GSipps maintain some market share. He said: “As long as there is a distinction between the two frameworks, there will be a market for both. It is about that wider investment choice. Some employers will want to go for something more bespoke. Maybe the GPP in its traditional flavour will disappear but the GSipp bolt-on might stay.”

He also suggested that master trusts would soon face an important stress  test – whether they can respond to  change quickly.

“There is an idea that with master trusts, you have to get the go-ahead from different parties. That is going to be the first real stress test. You are getting lots of providers merging. It was always meant to be the trustees who decided who was the provider of that master trust.

“Equally what about when people want to transfer out? How easy is that going to be? You have got to get the master trust trustees to sign off as well. So, I don’t think the road ahead is completely clear for master trusts.”

That said, he still believed that master trusts should win out because of the business they will win from those transitioning from an own trust.

Sticky business

Participants suggested that providers had entered the master trust market because it was viewed as “very sticky business”. However, Aviva policy manager, workplace benefits Dale Critchley, did not agree. “If your market is large pension schemes, it is less sticky. My pricing actuaries are less happy about master trusts, because they can take all the assets under management away to another provider on a single signature – rather than having to run a direct offer exercise.”

He also suggested that while EBCs like master trusts, corporate IFAs may be sticking to what they know.

“The advisers for the larger employers are tending to move towards master trusts. The corporate IFA market is still doing what they know, which is still group personal pensions. That may be a reluctance to go into a master trust because of the lack of a safety net of a large provider, or just because they always have.”

“There is a degree of ‘you don’t change what you are doing everyday unless you have a reason to do it’ and the ability to do that additional choice,” agreed Willis.

Mistry added: “If you are working with a client who is not really interested in a master trust, who doesn’t have a big bulk of assets to transfer across and who wants something hands off and risk averse, a GPP or GSipp still works. Looking at pricing, GPPs come in a little cheaper when you are working on a like-for-like contributions-only basis, though as soon as you add assets, that is different.”

Panellists did not quite agree that  GPPs were a last resort with French saying that a low cost, fixed price master trust such as the People’s Pension could fit the role as well.

Smith said it also required an insight into how master trusts were managing the flows of business. This could of course affect the wider market as well depending on who would accept that business.Panellists noted how Smart Pension were second only to Nest in terms of numbers of employers attracted, the majority of which had come late in the rollout process.

Mistry said much of this was down to the links to payroll providers given its technology, while French suggested that a lot of master trusts need to invest in their architecture and infrastructure due to requirements to trade and manage an audit trail of communications online.

Smith agreed that he saw a technology threat to traditional providers saying it is “really difficult to reconfigure systems for those cloud-based models”.

Critchley said: “If you are integrated with the major payroll providers which deliver to SMEs, you are going to have an advantage and if you don’t charge the employer anything, you are going to have an advantage. It doesn’t matter what your charge to the member so as long as it is compliant [with the charge cap].”

Panellists were clear that with master trust authorisation, standards will rise. But some won’t get over the new hurdles and that could have consequences for the industry’s reputation more generally.

Smith said: “The master trust authorisation is going to sort a lot of the mess out. I can only see the big getting bigger and the small disappearing, bringing higher standards to the master trust area next year. The bad guys are getting out.”Yet French asked whether there would be an orderly exit with bigger trusts acting as lifeboats or trusts consolidating.

Smith said: “I have seen evidence of smaller master trusts consolidating but whether they make it through the authorisation regime is open for debate.  I don’t see any evidence of the big guys queuing up to take on dodgy data and poor records from poorly-run, small master trusts. TPR will have to manage something here.” French added: “The larger trusts will pick and choose who they take on.

Reputational damage might be a big factor in not taking on smaller master trusts. But what happens to the rest? Is there an issue for small single employer trusts in terms of winding up and discharging those benefits? What if the trustees have gone away? There are barriers in the way of dealing with the issue of large volumes of single employer-based trusts.”
There may also be more accidental master trusts than one might think with neither the means nor the inclination to jump through the authorisation hoops, said delegates.
Willis said: “The framework is a really good thing, but there are unintended consequences. I have come across quite a few organisations who didn’t even realise they were a master trust and have no desire to register for authorisation. What do they do? Winding up a normal, trust-based scheme is challenging but winding up where there are lots participating employers – do you engage with them or take the decisions away from them?
“There are non-associated multi-employer schemes – they might be charitable bodies. The employers are not technically linked,  but they are having to extract some employees from their membership so as not to run foul of this, or to get authorised or wind up and now they are having to set up another master trust or find a master trust provider or GPP in a short time frame.”
So what if the regulator said to other big players ‘come and take this off our hands’? Critchley said: “We may say thanks, but no thanks. If a larger trust failed with attendant admin issues, we would have to look at it from a commercial point of view. Can we sort that mess out and it still make
commercial sense?”
Willis noted that no-one had an obligation to take on this business, and indeed that the governance framework for trusts could prevent trusts taking on bad business.
Smith said: “It feels it will be the smaller players, who haven’t got the sophistication or understanding to go through the authorisation process who will need to exit. I don’t feel any real anxiety that anyone big is not going to be authorised.”
Yet Mistry said he had heard some big providers had had some shocking feedback. Critchley added: “There has to be a chance that a master trust of a significant size will not be able to satisfy the regulator because no one gets a free pass. This is on capital adequacy but also because they can’t demonstrate they have all the controls in place – not just saying it but proving it.”
He also said there was a question of where some smaller trusts get the money to wind up. He suggested that trustees might be confronted with a choice of working pro-bono or facing legal liability in the event that the ongoing costs pot ran dry.
Willis said one of the biggest challenges was the pressure of time. “How long have you got? If it becomes deauthorised, there are penalties that have to be paid, you can lose a chunk of assets,
where does the money come from, the scheme, or the members’ pots?” he said.
He added that it wouldn’t technically be a winding-up charge – which can’t come from members – but a deauthorisation charge. Mistry said: “It is a shame that it is only seen as commercial thing or a risk thing and that there is no real thought about the individual members or thought about their experience. “Often it’s the people who don’t know anything about savings who are left on their own.”
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