Response to TPR Statement of Strategy consultation

Commenting in response to TPR’s statement of strategy consultation, Laura McLaren, Head of DB Actuarial Consulting, Hymans Robertson, said:

“We’re glad to see TPR publish detailed guidance for the statement of strategy, but we’re concerned that completing the template as proposed will create a lot of extra work. We estimate a typical scheme could add 20% to its valuation costs as a result.

“TPR can make completing the template easier, with pre-populated sections or automation where practical. But our main concern is around the amount of detail TPR is requesting. This would be onerous for schemes and disproportionate to what TPR needs to regulate them, especially in an environment with many well-funded DB schemes targeting buy-out.

“As a submission for the regulator’s eyes only, the statement of strategy has little value for the schemes themselves beyond compliance. It would be helpful to know what TPR, as a ‘proportionate’ regulator, is going to do with all the information that schemes will submit.

“The requirements for Fast Track in particular could be scaled back.  Asking for so much information misses the point of what’s meant to be a regulatory ‘filter’. A better approach could be that, once TPR has screened schemes it wishes to investigate further, it can ask for more information where relevant.”