Commenting on the DWP consultation, as the formal response draws to a close, Mark Jaffray, Head of DC Consulting, Hymans Robertson, says:

“We agree with the ambition this consultation is trying to achieve and welcome any change which raises the average level of governance. However we remain concerned that the challenges to meeting the government’s timetable for change – provider bandwidth, small schemes not being able to find a master trust to transfer to, loss of legacy guarantees and technical issues such as contracting-out underpins – have been underestimated.

"Guidance on Value for Members will be helpful, but would have liked the proposed criteria to cover a broader range of areas which drive good member outcomes. We question the use of past performance as a measure of the value of investment options, particularly given the events of 2020, and believe this could lead to behaviour which is not in members’ best interests. Developing the TPR’s current measures compared against a broader selection of similar schemes would be beneficial.”

The full consultation response can be found here.