Master Trusts exiting the market – things to consider

Nov 29, 2019

The UK pensions market is heading into a big period of consolidation – something compounded by master trust authorisation, which has seen the master trust market alone reduce by nearly 60%. It’s time for ‘exiting’ master trusts to execute their succession plan. The Pensions Regulator will be paying close attention to exiting master trusts to ensure the focus remains on best member outcomes and employer compliance.

If you’re one of the 36 master trusts getting ready to exit the market, there are several things you should consider when preparing your exit plan. Here’s our top 5…

1 Establish your requirements – timescales, costs and strategy

Who will need to be involved in the project? This is likely to include trustees, the scheme administrator, advisers and investment managers and other independent consultants. Define their roles and activities and how long you expect it to take. You’ll also have to consider how you’ll continue to operate in the meantime. What assurances will you have in place to prepare for TPR reviews on progress? And how will you manage the cost of transferring and who will pay?

TPR’s guidance on strategic steps to take once they’ve been notified of a triggering event highlights key areas to be included in your plans.

2 Analyse and prepare your data

The condition of your data will impact who wants to absorb your scheme. If your data is in bad shape it could have a negative impact on the receiving scheme, pulling down their TPR data scores. Not all schemes will be willing to take that risk. Taking a close look at your most recent TPR data scores will give you an indication of current data quality. Either way, this is an opportunity to improve data quality ahead of a transfer.

A data audit will need to be more than an accuracy check – you’ll have to think about how your data will be mapped across from your systems to the receiving scheme, as well as identify discrepancies and missing data, analyse overall data quality and look at options to improve your data. Good quality data can make a big difference to outcomes for members – helping with investment decisions, at retirement solutions as well as better member communications. Of course, improved data quality also gives you wider access to master trusts continuing to operate and allow you to find a scheme which aligns to your members’ needs and investment principles.

Carrying out a data audit and cleanse will get your data in order and make future migration easier.

3 Assess the reliability and governance of potential receiving schemes

How will you choose a receiving scheme? Looking at a schemes governance against TPR’s good governance topics can give you a great basis for comparison. You can find out more about key focus areas on TPR’s website.

Whilst you’re identifying potential receiving schemes it will also be worthwhile looking at how your current master trust governance aligns. Whilst many authorised master trusts are open to taking on exiting master trusts, some can afford to be pickier, so it’s worth thinking about how you will get the best deal for your members.

4 Compare what potential receiving schemes can offer for members and employers

Clients we’ve helped have told us they pay careful attention to what might be important to members and employers. This includes;

  • costs and charges
  • potential for ongoing contributions – particularly for auto enrolment and maintaining compliance
  • digital capability and access
  • customer service support
  • options provided at retirement
  • investment options and their environmental, social and governance credentials

…there are many others, but these are top of the list right now.

5 Consider when and how you’ll communicate with members and employers

Firstly, check the scheme rules around your power to transfer on the members’ behalf – you might need to make an amendment and communicate to members (without up-to-date contact info, this may be harder than you think). Think about whether you need a consultation process with members, and possibly employers too, to ensure you know what they expect from a new scheme. You’ll also need to communicate with members before a transfer takes place.

As you’re preparing your data it’s a good idea to tie in a tracing project to track down members you’ve lost touch with. It’ll make your communications easier and will demonstrate good practice to both members and the TPR.

Having clear and concise communications can make a big difference to how your members react and engage. It’s a good idea to:

  • Tailor specific messages to different members, for example active and deferred, by segmenting your data you can ensure your members receive the information that is relevant to them.
  • Use clear, everyday language. Pensions can be confusing enough, so keep it simple and only include what is necessary.
  • Tap into what your members care about – using insight your data can provide as well as listening to them. If during early consultation your members said responsible investment was important, mention the investment aims of the new scheme when you introduce them.

It may seem like a mighty task is at hand! But with a combination of guidance from TPR, and teaming up with independent experts, you’ll be well on your way to a seamless transfer.

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