Welcome to the latest edition of DLA Piper’s monthly newsletter – Pensions Round-Up – in which we provide an overview of developments in pension legislation, case law and regulatory guidance. In this edition we look at key developments from November 2016 including the following. ■ The Pensions Regulator: the publication of checklists about new information required in the 2016- 17 scheme return for DB and hybrid schemes; and, in relation to record-keeping, the results of the Regulator’s latest research, a quick guide for trustees and an announcement that trustees will be asked to report on this issue in their scheme return. ■ The Pension Protection Fund: the response to the September consultation about changes to the assumptions used in section 143 and 179 valuations. ■ Consultations: announcements made in the Autumn Statement about an upcoming consultation on options to tackle pension scams and a consultation about reducing the money purchase annual allowance; the response to consultation about the introduction of a cap on early exit charges; a consultation about changes to the general levy for occupational and personal pension schemes; and a consultation proposing amendments to the legislation on the end of contracting-out and setting out a proposed methodology for dealing with GMP equalisation. ■ Legislation: the progress of the Pension Schemes Bill through Parliament including news on timing of future developments; the latest revaluation order; clarification from HMRC in its latest newsletter about the timing of lifetime allowance protections; and a consultation on draft regulations about the provision of information. ■ Case law: a Court of Appeal judgment looking at whether the rules of a particular scheme gave the trustees power to substitute RPI with CPI and the impact of section 67 of the Pensions Act 1995. ■ Public service pension schemes: a consultation on indexation and equalisation of GMP in public service pension schemes; a consultation about the introduction of an administration levy for the NHS Pension Scheme; and an announcement about amendments to the Civil Service Compensation Scheme. ■ Other news: a statement from the Office for National Statistics on the future of consumer price inflation statistics; a call for evidence published by the Law Commission on pension funds and social investment; and some recent pensions-related developments from the Financial Conduct Authority. ■ On the Horizon: a timeline of some of the key future developments in pensions to help employers and trustees plan ahead. If you would like further information about any of the issues raised in this edition of Pensions Round-Up, please get in touch with Cathryn Everest or your usual DLA Piper pensions contact. Contact details are at the end of this newsletter. INTRODUCTION 02 | Pensions Round-Up – November 2016 SCHEME RETURN CHECKLISTS In November the Regulator published checklists of new information that will be needed before completing the DB scheme return or the hybrid scheme return for 2016-2017. The changes to the scheme return noted in the DB checklist include: a new question asking trustees to indicate whether they are a professional trustee and, if the trustee is a corporate trustee, whether any of the directors are professional trustees; a question about the guidance and assumptions used for the latest section 179 valuation; updates to reflect a change in the Statement of Recommended Practice on the Financial Reports of Pension Schemes; and updates to the questions on transfers of member benefits. The updates in relation to transfers include that: the questions have been aligned more closely with the terminology used in the underlying legislation; and in relation to DB to DC transfers the focus is only on transfers where the independent advice requirement applies. In addition to the points noted above, the checklist for hybrid schemes states that new information required in relation to the money purchase section of the scheme relates to the charge cap and the annual statement by the chair of trustees. RECORD-KEEPING On 30 November the Regulator announced that from next year, it will ask trustees to report on record-keeping in their scheme return to help improve standards. The Regulator states that adding this to the scheme return means it will be able to target its interventions more specifically at those failing in their duties. At the same time as making this announcement the Regulator published the findings from its most recent research on standards of record-keeping performance and administration which it states revealed little recent improvement in record-keeping. Findings included that: 90% of pension scheme members were in schemes where common data had been measured; 69% of members were in schemes where conditional data had been measured; administrators and trustees perceive conditional data as secondary to common data; and record-keeping is not always seen as a priority by trustees. The Regulator also published “A quick guide to record-keeping” which is designed to help trustees understand why scheme record-keeping is so important and sets out the steps they need to take to make sure their records are complete and accurate. It is worth noting (given the finding referred to above about the different types of data) that the guidance makes it clear that common data and conditional data are equally important. The guidance also looks at: accountability and responsibility; reviewing and improving scheme data; and data security. A checklist is provided at the end of the guide which trustees can use to measure the progress of their scheme. The Regulator states that it will “be providing further educational products in 2017, including videos and bitesized learning”. Trustees should consider reviewing their progress on record-keeping against the checklist in the quick guide and putting together an action plan of any steps they need to take. Even if trustees have previously completed a review of their data, it is worth noting that the Regulator states that it expects schemes to carry out a data review exercise at least annually. SECTION 143 AND 179 ASSUMPTIONS In September the Pension Protection Fund published a consultation proposing changes to the actuarial assumptions used in section 143 and section 179 valuations in order to bring them into line with current market pricing. The proposed changes included updates to mortality assumptions and discount rates. On 30 November the PPF reported that the response to the proposals was positive and there was acceptance that bulk annuity prices had altered sufficiently to merit a change to the assumptions. The PPF has therefore decided to proceed with the changes in line with the consultation proposals. The updated guidance documents on the assumptions were also published on 30 November and will apply to valuations with an effective date on or after 1 December 2016. THE PENSIONS REGULATOR AND THE PENSION PROTECTION FUND www.dlapiper.com | 03 CONSULTATIONS AUTUMN STATEMENT On 23 November the Chancellor delivered his Autumn Statement, with announcements in relation to pensions including the following. ■ The government will publish a consultation before Christmas on options to tackle pension scams, including banning cold calling in relation to pensions, giving firms greater powers to block suspicious transfers and making it harder for scammers to abuse ‘small self-administered schemes’. ■ The money purchase annual allowance (which applies when a member has accessed their benefits flexibly and wishes to make further DC contributions) will be reduced from £10,000 to £4,000 from April 2017. A consultation was published on the detail of this proposal seeking views on whether respondents agree that this level of allowance would neither impact on the roll out of automatic enrolment nor disproportionately affect particular groups. ■ Changes in relation to foreign pensions including that: the tax treatment of foreign pensions will be more closely aligned with the UK’s domestic pension tax regime; and the government will align the tax treatment of funds transferred between registered pension schemes, and update the eligibility criteria for foreign schemes to qualify as overseas pension schemes for tax purposes. EARLY EXIT CHARGES In the May edition of Pensions Round-Up, we reported on consultations by the Financial Conduct Authority (FCA) and the DWP about the introduction of a cap on early exit charges. There were further developments on this issue in November. ■ On 15 November the FCA published a Policy Statement and final rules confirming that from 31 March 2017, early exit charges: (i) will be capped at 1% of the value of existing contract-based personal pensions; (ii) cannot be increased in existing schemes in which they are currently set at less than 1%; and (iii) cannot apply to new personal pension contracts. ■ The Financial Services and Markets Act 2000 (Early Exit Pension Charges) Regulations 2016 were laid before Parliament on 9 November and will come into force on 31 March 2017. These regulations provide that Market Value Adjustments (MVAs) should not be treated as early exit charges for the purposes of the FCA cap provided certain conditions are met. ■ On 15 November the DWP published the response to its consultation on introducing a comparable cap for occupational pension schemes confirming that it intends: (i) to cap early exit charges for members of occupational pension schemes at 1% for existing members and 0% for new members; and (ii) to legislate to ensure that where the existing contract or the rules explicitly specify that an early exit charge will be applied and this is below 1%, it cannot be increased. This cap will be introduced using existing regulation-making powers together with a power in the Pension Schemes Bill. It is intended that the government will consult on draft regulations in early 2017 with a view to them coming into force in October 2017. GENERAL LEVY On 24 November the DWP published a consultation proposing changes to the levy on occupational and personal pension schemes which recovers the core funding the DWP provides for The Pensions Regulator, The Pensions Advisory Service and The Pensions Ombudsman. The consultation looks at three options with the preferred approach being: (i) to create a new levy rate for schemes with 500,000 members or more, pitched at a level 25% lower than the current rate for schemes with 10,000 members or more; and (ii) for the levy rates for schemes with fewer than 500,000 members to remain frozen. It is proposed that the changes would apply from 1 April 2017. 04 | Pensions Round-Up – November 2016 CONTRACTED-OUT RIGHTS On 28 November the DWP published a consultation (which closes on 15 January 2017) about several issues concerning contracted-out rights. Proposed changes to legislation The first chapter of the consultation relates to draft regulations which are proposed to apply from 6 April 2017 and will make further changes to the legislation about administering accrued contracted-out rights including the following: (i) clarification of when certain provisions about revaluation of GMPs after a transfer apply; (ii) giving HMRC the discretion to extend the notification and payment periods to allow late Contributions Equivalent Premiums identified as a result of the Scheme Reconciliation Service; (iii) changes to the provisions about restrictions on alterations of scheme rules in relation to post-1997 contracted-out rights; (iv) amendments to the provisions about survivors’ GMPs consequential on changes to State bereavement benefits; and (v) a change to the fixed rate of revaluation to 4% for those who leave pensionable service on or after 6 April 2017. Schemes with accrued contracted-out rights should be aware of the proposal for change in certain areas. In particular, where schemes are planning rule changes to be made in relation to post-1997 contracted-out rights, we suggest that they seek advice about the impact of the proposals in this area. Reviews of legislation The consultation also seeks views on the following areas of the legislation which the DWP previously stated that it would review: (i) the regulations that restrict alterations to scheme rules in respect of post-1997 contracted-out rights; and (ii) the transitional arrangements introduced in 2012 in relation to the end of contracting-out on a DC basis. The DWP also notes concerns that the legislation on bulk transfers without member consent does not allow such transfers to a scheme that has never been contractedout, and reports that it is working with stakeholders on this issue but any changes to the legislation will not be introduced before autumn 2017. GMP equalisation In January 2012 the DWP published a consultation on draft regulations reflecting its view that the requirement for equal treatment in relation to GMPs is not dependent on there being a comparator. It also published draft guidance on a standard methodology for equalisation, but this guidance was met with concern from industry that the methodology would be particularly onerous to implement. The draft regulations were therefore withdrawn while the DWP investigated whether a less onerous process could be used. This consultation provides an update on work undertaken by an industry working group on this issue and seeks views on a new proposed methodology which involves a one-off calculation and actuarial comparison of the benefits a man and woman would have, with the greater of the two converted into an ordinary scheme benefit under the GMP conversion legislation. It is made clear that the proposed methodology simply describes one way of equalising and the government is not placing any obligation on schemes to use this method. The consultation also reports on changes to the GMP conversion legislation proposed by the working group to make it easier to use. On the impact of the UK’s decision to leave the EU, the consultation notes the government’s position that the UK remains a full member of the EU and during this period it will continue to negotiate, implement and apply EU legislation. In relation to the draft January 2012 regulations, the DWP states that this consultation focuses only on the new methodology and that it will consider the regulations further in light of this consultation and consult on them again in due course if necessary. At this stage, trustees of schemes that have not yet equalised for the effects of GMPs may find it useful to start considering whether this approach would be appropriate for their scheme and to include this issue in their plans for further consideration once the response to consultation is published. CONSULTATIONS www.dlapiper.com | 05 LEGISLATION PENSION SCHEMES BILL The Pension Schemes Bill makes provision in relation to the regulation of master trusts and contains a regulationmaking power that it is intended will be used to introduce the cap on early exit charges and extend the ban on member-borne commission charges. The Bill continued to progress through Parliament in November, having its second reading and Committee stage debates in the House of Lords. During the debates the following points were made about future developments. ■ The authorisation and supervision regime for master trusts is likely to be commenced in full in 2018. However, some provisions will have retrospective effect from 20 October 2016 – in summary these are provisions that apply when certain “triggering events” take place in relation to existing master trusts, such as the insolvency of the scheme funder. It is anticipated that the initial consultation to inform the regulations in relation to master trusts may take place in autumn 2017. ■ The consultation on the regulations in relation to the cap on early exit charges and on member-borne commission charges will take place in the new year. ■ The government intends to publish a Green Paper this winter on the challenges facing defined benefit schemes. REVALUATION On 21 November the annual Occupational Pensions (Revaluation) Order 2016 was made setting out the revaluation required for people who will reach their scheme’s normal pension age in 2017. The Order reflects the CPI figure for the year to 30 September 2016 of 1.0%. This is also the relevant percentage for the minimum increase for post-1997 defined benefit pensions in payment. LIFETIME ALLOWANCE The Finance Act 2016 contains provision in relation to Individual Protection 2016 (1P2016) and Fixed Protection 2016 (FP2016). In its Pension Schemes Newsletter published on 4 November, HMRC states that it has been asked to provide some clarification on the date a member is protected for lifetime allowance purposes. The newsletter provides the following. For IP2016 and FP2016 the date a member’s protection is effective from is: ■ 6 April 2016 ■ the date the IP2016 or FP2016 became active (if previously dormant) following the loss of an earlier form of lifetime allowance protection. It also states that for Individual Protection 2014 (IP2014) the date a member’s protection is effective from is: ■ 6 April 2014 ■ the date the IP2014 became active (if previously dormant) following the loss of an earlier form of lifetime allowance protection. PROVISION OF INFORMATION On 7 November HMRC published draft regulations for technical consultation which propose amendments to the legislation on provision of information in order to: (i) introduce new requirements where certain lump sum death benefits are paid to a trust (other than a bare trust); and (ii) make minor amendments to the requirements for pension savings statements in light of the tapered annual allowance and the transitional rules for 2015/16. 06 | Pensions Round-Up – November 2016 CHANGING FROM RPI TO CPI In the September 2015 edition of Pensions Round-Up we reported on a High Court judgment looking at whether the rules of a particular scheme permitted the trustees to substitute RPI with CPI for the purposes of pension increases and revaluation. That judgment was the subject of an appeal and a cross-appeal to the Court of Appeal which issued its judgment on 2 November 2016. Background The key definition in the rules which the court had to consider was that of “Retail Prices Index” which means “the General Index of Retail Prices published by the Department of Employment or any replacement adopted by the Trustees without prejudicing Approval. Where an amount is to be increased “in line with the Retail Prices Index” over a period, the increase as a percentage of the original amount will be equal to the percentage increase between the figures in the Retail Prices Index published immediately prior to the dates when the period began and ended, with an appropriate restatement of the later figure if the Retail Prices Index has been replaced or re-based during the period”. The question is whether the reference in the definition to “or any replacement adopted by the Trustees without prejudicing Approval” means: (i) the RPI or any index that replaces the RPI and is adopted by the trustees (this is a two stage process in which RPI is replaced by something else which the trustees then adopt); or (ii) the RPI or any index that is adopted by the trustees as a replacement for the RPI (this is a single step whereby the trustees simply choose another index whether or not RPI itself has been replaced). The High Court concluded that (i) was the correct answer which meant that, as RPI has not been replaced, the trustees cannot adopt a different index. The Court of Appeal decision The employer appealed this decision but its appeal was rejected by the Court of Appeal (albeit on a majority basis, with one judge giving a dissenting judgment). The court’s reasoning included that the word order and grammatical construction of the first sentence in the definition lead to the conclusion that the natural meaning of the phrase is that replacement precedes adoption by the trustees. The court also noted that the second sentence refers to “replaced or re-based” and stated that: RPI can only be re-based by the authority responsible for publishing it; the natural meaning of the phrase “replaced or re-based” is that the same person is doing the re-basing or replacing; and not only “might” it be thought that the concepts of “replacement” and “replaced” were intended to be the same in each sentence (as the High Court had stated) but that is “the obvious meaning to give to the recurrence of a cognate expression in the same definition”. The question in the cross-appeal arose if the Court of Appeal had instead decided that interpretation (ii) was correct. However, as the Court had heard argument on this point and had formed a view on it, the judgment still addresses this point. The question was whether, under interpretation (ii), the selection of CPI or some other index in place of RPI would be a “detrimental modification” for the purposes of section 67 of the Pensions Act 1995 which protects members’ subsisting rights. To determine this, it is necessary to identify the subsisting rights. The Court of Appeal was unanimous on this point. It agreed with the High Court’s reasoning in two previous cases and held that, under interpretation (ii) the trustees have a choice, and until that choice has been exercised, it is not possible to say that the member has a right to an increase measured in any particular way. This means section 67 would not prevent a change to the index had interpretation (ii) been the correct interpretation. It is useful to see the Court of Appeal’s view on the construction issue and its confirmation of the view previously taken by the High Court on section 67. However, the position for each scheme on construction and section 67 will depend on the wording of its rules and therefore trustees and employers should seek legal advice before making any changes to the index used for their schemes. CASE LAW www.dlapiper.com | 07 INDEXATION AND EQUALISATION OF GMP On 28 November the Treasury published a consultation on indexation and equalisation of GMP in public service pension schemes. By way of background, the consultation explains that under the arrangements that applied prior to the introduction of the new State Pension on 6 April 2016, the public service pension and the Additional Pension system worked in tandem, providing a mechanism that fully indexed and equalised pension payments of public servants. The removal of the Additional Pension when the new State Pension was introduced means that this mechanism no longer works. However, on 1 March 2016 the government announced that it would continue with the previous practice for public service pensioners reaching State Pension age after 5 April 2016 and before 6 December 2018 and fully index their GMPs earned in public service. This latest consultation: (i) examines the options open to the government to avoid introducing an inequality for payments to men and women reaching State Pension age after 5 December 2018 who accrued a GMP as a member of a public service pension scheme; and (ii) considers whether the government should meet the past commitments made to public service employees regarding full indexation of their pensions including the GMP, in light of the wider gains many members will receive from the transition to the new State Pension. The consultation looks at three options: case-by-case calculations; full indexation (that is, extending the interim solution that currently applies for those reaching State Pension age after 5 April 2016 and before 6 December 2018); and conversion of the GMP to scheme benefit. (It is worth noting that the basis proposed for conversion here is different to that set out in the DWP’s consultation on a proposed methodology for equalisation reported earlier in this newsletter.) The government is also interested in views on other solutions. The consultation closes on 20 February 2017. NHS PENSION SCHEME On 10 November the Department of Health published a consultation about proposals to introduce an NHS Pension Scheme administration levy from 1 April 2017. The consultation explains that currently the Department funds the cost of scheme administration services but it is intended that in the future the cost of these services would be met by participating employers. It is proposed that the scheme regulations will be amended to require each participating employer to pay the levy. The Department projects that the cost of scheme administration over the next two years is £35 million a year and that, given the size of the scheme, this translates into a levy rate of 0.08% of a member’s annual pensionable earnings. The proposals include that the rate will be fixed until 31 March 2019 and thereafter reviewed every four years. The consultation reports that, at the next review, the levy is expected to reduce as cost savings and efficiencies from the NHS Business Services Authority’s service modernisation programme are realised. The consultation closes on 9 January 2017. CIVIL SERVICE COMPENSATION SCHEME In the September 2016 edition of Pensions Round-Up we reported on the response to a consultation about measures to address exit payments in the Civil Service Compensation Scheme. On 8 November in a Written Ministerial Statement, the Minister for the Cabinet Office stated that he had laid an amended Civil Service Compensation Scheme before Parliament. He stated that the terms outlined in the Civil Service Compensation Scheme 2016 would come into effect from 9 November 2016, and that the amended scheme is in line with the government’s response to consultation that was published on 26 September and the offer made to trade unions on the same day. PUBLIC SERVICE PENSION SCHEMES 08 | Pensions Round-Up – November 2016 OTHER NEWS OFFICE FOR NATIONAL STATISTICS On 10 November the National Statistician and Chief Executive of the Office for National Statistics (ONS) issued a “Statement on future of consumer price inflation statistics in the UK” which constitutes his formal response to the June 2015 consultation on the future of consumer prices indices. Points of note in the statement include the following. ■ The ONS will make CPIH (the Consumer Price Index including owner occupiers’ housing costs) its preferred measure of consumer price inflation from March 2017. By this time, all the planned improvements to CPIH will have been implemented. The importance of the preferred inflation measure being of recognised National Statistics status is acknowledged, and therefore the ONS will continue to work towards redesignation for CPIH as early as possible. ■ The ONS will cease publication of RPIJ from March 2017. This decision has been made because although RPIJ addresses some problems relating to RPI, it shares other shortcomings of RPI. The statement also includes a link to a comprehensive list of which sub-indices of the Retail Prices Index will continue to be published and which will be discontinued. LAW COMMISSION In November it was reported that the Minister for Civil Society has asked the Law Commission to look at social investment (that is, investment which combines financial and social objectives) by pension funds. In particular, the question of how far the law does or should allow pension funds to select an investment because it would make a positive social impact. The Law Commission has been asked to provide an accessible account of the law in this area and to consider the legal or regulatory barriers to social investment. The Law Commission has started this work with the publication of a call for evidence dated 7 November 2016. The Commission explains that this project builds on its 2014 report “Fiduciary Duties of Investment Intermediaries” which concentrated on DB schemes and provided guidance on when trustees can take environmental and social factors into account. In contrast, this latest project is focused on DC pensions, particularly where funds are chosen by the individual concerned, and rather than look at negative screening it considers when pension funds may be invested positively for social good. The Law Commission plans to publish its report by May 2017. FINANCIAL CONDUCT AUTHORITY In November the FCA published a number of publications relevant to the issue of pensions. ■ The interim findings of its asset management market study in which the FCA proposes a significant package of remedies that seek to make competition work better in this market. The remedies include: requiring increased transparency and standardisation of costs and charges information for institutional investors; and exploring the potential benefits of greater pooling of pension scheme assets. The FCA seeks views on its findings and proposed remedies. The FCA also reports that it found concerns about the way the investment consultant market operates. It is consulting on whether to make a market investigation reference to the Competition and Markets Authority on the investment consultancy market and recommends that the Treasury considers bringing the provision of institutional investment advice within the FCA’s regulatory perimeter. ■ A consultation on proposals to introduce new rules in September 2017 requiring firms to inform consumers how much they could gain from shopping around and switching provider before a potential annuity purchase. ■ A consultation on proposals to introduce two new regulatory returns in 2018 to collect retirement income data from providers of retirement income products. www.dlapiper.com | 09 10 | Pensions Round-Up – November 2016 ON THE HORIZON DATE DEVELOPMENT Unknown The reforms in relation to Defined Ambition, Collective Benefits and automatic transfers of small DC pots will be revisited once the market has had time and space to adjust to the other reforms underway. A consultation on a proposed methodology for equalising pensions for the effect of GMPs closes on 15 January 2017 but the date for the final form of any guidance to be published is not yet known. The date for legislation on this issue to be finalised is also not yet known. 2016 The Regulator intends to review its guidance on transfers. The Regulator intends to publish guidance on DB scheme investment strategy. In February 2016 it was stated that a new requirement would be introduced in the summer for trust-based schemes to report regularly on their performance in processing transfers but no further detail has yet been published in relation to this. Late 2016 or early 2017 A consultation is expected in relation to the PPF levy rules for the third triennium including any proposed changes to the insolvency risk model. 2016/17 The Pension Schemes Bill 2016-17 is currently progressing through Parliament. It contains provisions in relation to the regulation of master trusts and regulation-making powers to support the plans to introduce a cap on early exit charges and extend the ban on member-borne commission payments. Consultation on the charges provisions is expected in early 2017. 31 March 2017 The FCA rules imposing a cap on early exit charges for contract-based schemes will come into force. April 2017 It is expected that a pensions advice allowance will be introduced allowing members to make specified withdrawals from their DC pension pot to redeem against the cost of financial advice. The money purchase annual allowance is expected to be reduced to £4,000. Regulations making amendments to the legislation on administering accrued contracted-out rights are expected to come into force. (There are some issues still to be addressed but changes on these issues are not expected before autumn 2017.) Second quarter of 2017 The FCA is expected to publish rules aimed at standardising the disclosure of transaction costs incurred by pension investments in a Policy Statement. October 2017 The cap on early exit charges for occupational pension schemes is expected to come into force. 2017 The measures on DC charges and governance standards will be reviewed. End of 2017 The transitional period in which employers and schemes may continue to use the VAT treatment in VAT Notice 700/17 ends on 31 December 2017. 6 April 2018 The lifetime allowance is due to be indexed annually in line with CPI. May 2018 The new EU General Data Protection Regulation will apply. 2018/2019 The IORP II Directive is awaiting formal approval and, after that, it will be published in the Official Journal and will officially enter into force. Member States will have 24 months to transpose the Directive into national legislation. 2019 The Government will ensure the industry designs, funds and launches a pensions dashboard by 2019. A prototype is expected by March 2017. www.dlapiper.com | 11 CONTACT DETAILS Ben Miller Partner, Liverpool T +44 (0)151 237 4749 email@example.com Claire Bell Partner, Manchester T +44 (0)161 235 4551 firstname.lastname@example.org Tamara Calvert Partner, London T +44 (0)20 7796 6702 email@example.com Jeremy Harris Partner, Manchester T +44 (0)161 235 4222 firstname.lastname@example.org Vikki Massarano Partner, Leeds T +44 (0)113 369 2525 email@example.com Kate Payne Partner, Leeds T +44 (0)113 369 2635 firstname.lastname@example.org Matthew Swynnerton Partner, London T +44 (0)20 7796 6143 email@example.com David Wright Consultant, Liverpool T +44 (0)151 237 4731 firstname.lastname@example.org Cathryn Everest Professional Support Lawyer, London T +44 (0)20 7153 7116 email@example.com www.dlapiper.com | 11 DLA Piper is a global law firm operating through various separate and distinct legal entities. Further details of these entities can be found at www.dlapiper.com. This publication is intended as a general overview and discussion of the subjects dealt with, and does not create a lawyer-client relationship. It is not intended to be, and should not be used as, a substitute for taking legal advice in any specific situation. DLA Piper will accept no responsibility for any actions taken or not taken on the basis of this publication. This may qualify as “Lawyer Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome. Copyright © 2016 DLA Piper. All rights reserved. | DEC16 | 3186190 www.dlapiper.com
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Pensions Round-Up: November 2016
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