Whilst assessing good value for members of DC pension schemes is not a new subject for trustees and the pension industry, the rise of several contrasting transparency initiatives has begun to muddy the waters on which transparency standards a pension fund decision maker should prioritise.
Investment governance committees (IGCs) are obliged to scrutinise the value for money of the provider’s workplace personal pension schemes, taking into account transaction costs.
The DWP’s “schemes”, published on 26 February 2018, places a duty on DC trustees to report costs and charges via the chair’s statement. Failure to adhere to the DWP legislation to disclose on investment costs to members, could result in a £50,000 fine.
And in addition, after years of planning, EU MiFID II finally came into effect on 3 January 2018 across all EU territories. Pension trustees will now be presented with more information from their investment managers on best execution practises and increased cost disclosures.
The need for an improved cost disclosure regime is agreed upon – the question is how can the industry best support trustees in meeting their governance and regulatory obligations?
The Dutch pension fund industry is widely considered to be the frontrunner in governance and transparency. One reason for their success is a well-structured cost reporting system as a part of their governance framework.
In the UK, initiated in May 2017, the Local Government Pension Scheme Advisory Board’s ‘Code of Transparency’ has been instrumental in standardising a consensus on cost transparency, with 65 asset managers signed up to the code.
Then in December, the DC Workplace Pensions Template (DCPT) was issued by the Investment Association (IA), to meet the minimum data requirements of COBS 19.8. This initiative set out to enable governance bodies of workplace pension schemes to meet their obligations, and provide asset managers with a standardised cost disclosure methodology.
Following the FCA asset management market study, the regulator established the institutional disclosure working group (IDWG) to build on the progress of the LGPS code of transparency. The group has worked on a cost disclosure template for UK pension schemes, to be published towards the end of the summer.
Despite this rapid and important progress, we as an industry should remind ourselves of the potential disruption that these simultaneous and potentially conflicting regimes may have on its end users: the trustees, governance committees and ultimately the members.
And at this point, another question arises; how are the end users going to be able to cope with the additional amount of data they will be receiving from asset managers?
The DWP DC legislation dictates that “it remains the burden of trustees to report on the level of charges (including transaction costs), for each fund which members can select, via the Chair’s statement”. This ultimately means that trustees will be further responsible for the calculation and presentation of these transaction charges as they are best able to. Beyond reporting, trustees are also obliged to make a value for money assessment on these costs, and illustrate the cumulative effects over time to its members – not an easy ask.
With regulatory obligations and several streams of new data, schemes must think carefully about how they dedicate resource to this exercise. Some may look to reconcile this data in house. Others may look to outsource this process to a specialised provider. Either way, the time and resource dedicated to fulfilling these obligations will be a further cost incurred by the scheme, which may ultimately impact member outcomes. With transparency comes the responsibility to carry it out cost-effectively.
With the influx of multiple reporting requirements and contrasting methodologies, , the first half of 2018 is proving to be a turning point for cost reporting in the pensions industry. While each of these regulatory frameworks has noble aims, more work needs to be done to ensure that demanding trustee obligations are made clear and that implications are managed carefully if they are to actively deliver transformational benefits. Without this, we risk adding a further layer of red tape and may miss out on the very value we are trying to create.