IN THIS ISSUE
02 Introduction 03 The Pensions Regulator and the PPF 04 Consultations and legislation 07 Case law
09 HMRC 10 On the horizon 11 Contact details
Welcome to the latest edition of DLA Piper's Pensions Round-Up newsletter 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 October 2017 including the following.
The Pensions Regulator: the launch of new online messaging in relation to pension scams.
Pension Protection Fund: a consultation about contingent assets in the PPF levy which sets out changes the PPF is proposing to make to its standard form agreements.
Consultations and legislation: a consultation on draft regulations proposing new disclosure requirements concerning costs, charges and investments for occupational pension schemes providing money purchase benefits; a consultation on draft regulations to simplify the bulk transfer of DC pensions without member consent; and guidance from HMRC relating to requirements in anti-money laundering legislation for trustees to register information with it.
Case law: a Court of Appeal judgment concerning equalisation; and a High Court judgment relating to an appeal from a Pensions Ombudsman determination which includes consideration of the level of the award for distress and inconvenience.
HMRC: an announcement from HMRC about its policy on VAT treatment of pension fund management services provided by regulated insurance companies; and the publication of a pension schemes newsletter and a countdown bulletin about the end of contracting-out.
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.
02 | Pensions Round-Up October 2017
PENSIONS REGULATOR AND PENSION PROTECTION FUND
PENSIONS REGULATOR PENSION SCAMS
On 16 October the Regulator issued a press release announcing the launch of "new online messaging urging consumers to keep their eyes and ears open for pension scams". One of the animations reminds viewers to watch out for scam sites that dress themselves up with anti-scam messaging to pose as legitimate businesses and the other focuses on the need to hang up immediately on pension cold callers. The press release also reports that between July and the beginning of October the Regulator's Industry Liaison team spoke at a number of events around the country for financial advisers highlighting the warning signs of scams, how advisers can ensure their clients don't fall victim to them and what to do if they think one of their clients has been scammed.
PENSION PROTECTION FUND CONTINGENT ASSETS
In September the PPF published its response to its March consultation on the third PPF levy triennium and the consultation on the draft Levy Rules for 2018/19. The response stated that the PPF had revised the proposals it made in March in relation to updating the standard forms for contingent assets and would publish a further consultation on this issue in October. On 19 October the PPF published that further consultation together with draft agreements. The consultation refers to two main issues being covered by the proposals.
Cap Interpretation. The PPF has become aware that it is possible to argue that the current wording in the Type A and Type B agreements means that any payments made (whether by the guarantor in the absence of a demand under the guarantee, the employer, another guarantor or otherwise) in respect of the guaranteed obligations would erode a fixed cap. Whilst the PPF does not agree with this interpretation, it is proposing amendments to put the matter beyond doubt that the fixed cap is not reduced as a result of any subsequent deficit top up payments made by the employer, the guarantor or another guarantor.
Cap Operation. The consultation looks in particular at whether payments made under the guarantee but outside of insolvency scenarios should erode the cap and if so how to ensure appropriate levy credit is given. The PPF considers that the right approach for the fixed cap is for agreements to cover all employer obligations but with a cap that only applies in the event of employer insolvency. On this issue the PPF has focused on Type A and Type B agreements and will consider Type C agreements in light of the conclusions on Type A and Type B agreements. The draft forms do not yet contain wording on this point in relation to multi-employer schemes and the consultation seeks input in order to help the PPF finalise its approach to these schemes.
The consultation also notes a number of other changes to the draft agreements including for Type A and Type B agreements: a provision that the guaranteed employers will include all employers from time to time that are associated with the guarantor, which it states should avoid the need for an amendment to be made to the agreement if the list of named employers needs to be changed; and a relaxation of the requirement that the representations given by the guarantor are deemed to be repeated on a daily basis.
The next steps should be noted by employers and trustees of schemes that are putting in place a contingent asset, considering doing so or already have one in place.
The PPF expects to publish the final version of the standard forms in January 2018 and new contingent asset agreements entered into after that date will have to be in the new form.
For existing Type A and Type B agreements, the PPF will not require re-execution in 2018/19 (as had originally been proposed in the March 2017 consultation) but is likely to require action to adopt the new standard forms to be taken for 2019/20.
CONSULTATIONS AND LEGISLATION
DISCLOSURE OF COSTS, CHARGES AND INVESTMENTS
On 26 October the DWP published a consultation on draft regulations proposing new disclosure requirements for occupational pension schemes providing money purchase benefits. It is proposed that there will be some exceptions so that the new obligations will apply to the same schemes that are required to produce a chair's annual statement. These exceptions include executive pension schemes, certain small schemes and schemes in which the only money purchase benefits are attributable to additional voluntary contributions.
Costs and charges
In September the Financial Conduct Authority published new rules which will come into force on 3 January 2018 and will require firms managing money on behalf of DC workplace pension schemes to disclose administration charges and transaction costs to the trustees of those schemes using a standard approach. The DWP consultation seeks views on proposals to ensure that when trustees are making this information available to members, it is presented meaningfully and via appropriate channels.
The DWP proposes that the information which trustees are required to include in the chair's annual statement about costs and charges will be expanded so that it should: (i) set out the costs and charges for each default arrangement, rather than just the range of the levels where there is more than one default arrangement; (ii) state the levels of costs and charges for each fund which members are able to select rather than just the range of the levels; and (iii) include an illustrative example of the cumulative effect over time of the application of charges and costs.
Currently the Disclosure Regulations require a copy of the chair's annual statement to be provided on request but the consultation proposes a requirement for the information in the statement about charges and costs and about the default investment strategy to be published on a website. The DWP does not propose to be prescriptive about where
the information is published as long as it is published on the internet for public consumption. The draft regulations also make provision so that each member who receives an annual benefit statement must, at the same time, be provided with the web address where members can find the information for their scheme. The chair's annual statement must be produced within seven months of the end of the scheme year and the DWP states that trustees should, as a minimum, publish the information on costs and charges on a similar annual cycle. Draft statutory guidance about these requirements was also published.
It is proposed that the regulations will come into force on 6 April 2018 or the last day of the first scheme year to end on or after that date. The FCA will consult on corresponding rules for workplace personal pension schemes in 2018.
The consultation also proposes introducing a duty on trustees to disclose on request to members and recognised trade unions the top level of funds for which public information is available in which members are directly invested, and that these disclosure requirements should look through `unit-linked contracts' to the first layer of underlying funds for which public information is available. The information must be prepared within seven months of the end of the scheme year and trustees will be required to respond within two months of a request. It is also proposed that each member who receives an annual benefit statement must be informed that they can request this information.
Trustees of schemes to which the requirements would apply should be aware that they may soon be subject to new disclosure requirements which, if the draft regulations are introduced, will require them to provide additional information in the chair's statement, publish certain information about costs and charges, provide certain investment information on request and provide additional information with the annual benefit statement.
04 | Pensions Round-Up October 2017
CONSULTATIONS AND LEGISLATION
On the same day that the DWP published the consultation about disclosure of information on charges it published a report on a survey which looks at how charges in DC workplace pension schemes have changed since the introduction of the charge cap on default arrangements in workplace schemes and the ban on consultancy charges in contract-based schemes in April 2015 and the ban on Active Member Discounts and member-borne commission in DC workplace schemes in April 2016. Findings of the survey included that: (i) the charge cap had lowered charges in qualifying schemes to the level of the charge cap or below; (ii) members of qualifying trust-based schemes paid 0.38% on average with 99% of members paying within the cap; (iii) in non-qualifying trust-based schemes, which are not subject to the cap, the average charge was 0.70%; and (iv) charges that were banned under the measures had been eliminated from qualifying schemes by April 2016 and remained extremely rare even among non-qualifying schemes.
BULK TRANSFERS OF DC PENSIONS
Following a December 2016 call for evidence, on 26 October the DWP published a consultation on draft regulations intended to simplify the bulk transfer of DC pensions without member consent from one occupational pension scheme to another occupational pension scheme. In order for such a transfer to take place under the current legislation an actuary must certify that transfer credits in the receiving scheme are "broadly no less favourable" than
the rights to be transferred and requirements must be met concerning the relationship between the transferring and receiving scheme. The DWP reports that the majority of responses to the December 2016 call for evidence indicated that the requirement for an actuarial certificate is seen as a barrier to efficient DC transfers and respondents generally felt that the scheme relationship condition creates a barrier and serves no purpose in a pure DC landscape.
The consultation therefore proposes that in relation to `pure' DC to DC transfers (that is, where there are no potentially valuable guarantees or options) the requirement for an actuarial certificate and the scheme relationship condition will be removed. New requirements will instead be introduced so that bulk transfers without member consent of `pure' DC benefits from one occupational scheme to another will be permitted where: (i) the receiving scheme is authorised under the new authorisation and supervision regime for master trusts; or (ii) where the receiving scheme is not an authorised master trust, the trustees of the transferring scheme have obtained and considered the written advice of a "suitably qualified professional" who is independent of the receiving scheme. The consultation also notes that trustees will be subject to their fiduciary duties. Further member protection is also proposed so that if members are protected by the charge cap in the transferring scheme and are transferred to a scheme where they would not be, the protections under the charge cap will transfer into the new scheme. The consultation closes on 30 November and the draft regulations are expected to come into force on 6 April 2018.
CONSULTATIONS AND LEGISLATION
ANTI-MONEY LAUNDERING REGULATIONS
New anti-money laundering regulations came into force on 26 June 2017 which include obligations on trustees in relation to information about "beneficial owners" including record-keeping requirements and requirements to register information with HMRC. For these purposes "beneficial owners" include the settlor, the trustees, the beneficiaries and any individual who has control over the trust, with the definition of control for these purposes relating to certain powers under the trust instrument or by law. In the June/July edition of Pensions Round-Up we noted that it is not clear whether these obligations only require confirmation of the classes of beneficiaries or will require detailed information about all beneficial owners. HMRC has introduced the Trusts Registration Service for trustees to use to comply with the requirement to register information and in October it issued Frequently Asked Questions (FAQs) about that service which include some information about how the requirements apply to occupational pension schemes.
Registering information with HMRC
The requirement to register information with HMRC applies to "taxable relevant trusts". The definition of "relevant trust" encompasses "UK trusts" (the definition for which depends on residency of the trustees and settlor) which are express trusts and certain "non-UK trusts" which are express trusts. The FAQs state that HMRC expects that most registered pension schemes will be express trusts.
A relevant trust will be a taxable relevant trust in any year in which its trustees are liable to pay any of a list of certain taxes in the UK in relation to assets or income of the trust. This list includes, for example, income tax, capital gains tax and stamp duty land tax. The FAQs state that registered pension schemes will not need to register if the scheme administrator has to pay UK income tax solely because they are liable for certain charges under the Finance Act 2004 or tax under PAYE on a member's pension or lump sum benefits or on death benefits. As an initial step, trustees should therefore ascertain whether their scheme is a "taxable relevant trust".
Trustees of taxable relevant trusts must provide HMRC with specified information relating to the trust (such as full name, the date it was set up and a statement of accounts) and specified information about the beneficial owners, with the information to be provided depending on whether the beneficial owner is an individual or a legal entity (for example, in relation to an individual, the information includes full name, national insurance number, date of birth and role in relation to the trust). However, the HMRC FAQs state that to help keep administrative burdens to a minimum for business type trusts with particularly large numbers of beneficiaries, such as occupational pension schemes, the trustees will only be asked to identify the class of beneficiary if the number of named beneficiaries exceed ten. The FAQs also provide some further information in relation to the requirements to provide information on the settlor and a statement of accounts for the trust.
The relevant information has to be provided on or before 31 January 2018 or 31 January after the tax year in which the trustees were first liable to pay any of the taxes that can make it a taxable relevant trust. However, trustees should be aware that in certain circumstances where income tax or capital gains tax are incurred for the first time, the first deadline may be earlier. The legislation also contains obligations to notify HMRC whether or not there have been changes to certain information.
The record-keeping requirements have a broader application as they apply to "relevant trusts". The requirements cover certain information about beneficial owners and potential beneficiaries. Much of the information may already be held as part of trustees' other record-keeping obligations but there is some information (for example, which apply if somebody does not have a national insurance number or unique taxpayer reference and their usual residential address is outside the UK) which may not currently be held. The FAQs suggest that it may be possible to comply with these requirements by identifying the class of beneficiary but the position is not entirely clear. We will report again if further guidance is issued.
06 | Pensions Round-Up October 2017
The requirement to equalise Normal Pension Ages (NPAs) for men and women applies for service from 17 May 1990. In terms of terminology used in relation to equalisation, if a scheme previously had an NPA of 60 for women and 65 for men: (i) women would be the advantaged class; (ii) if NPAs are equalised at 65, the benefits are levelled down; (iii) if NPAs are equalised at 60, they are levelled up; and (iv) the period between 17 May 1990 and the date that a scheme's rules are amended to equalise NPAs is known as the Barber window and benefits must be in line with those of the advantaged class during this period.
In the February 2016 edition of Pensions Round-Up we reported on a High Court judgment looking at the question of whether the NPAs of men and women in the Safeway Pension Scheme were equalised at age 65 with effect from 1 December 1991 (the date referred to in an announcement dated 1 September 1991 and a letter dated 1 December 1991) or from 2 May 1996 (the date that the NPA of 65 was formally reflected in a deed). The High Court concluded that the relevant date was 2 May 1996. The employer appealed and the Court of Appeal issued its judgment on 5 October 2017.
Court of Appeal judgment
The first issue considered was the construction of the scheme's amendment power which stated that the company could, with the consent of the trustees, amend the scheme by supplemental deed and "may exercise such powers so as to take effect from a date specified in the Supplemental Deed which may be the date of such Deed or the date of any prior written announcement to Members of the alteration or addition ...". The Court of Appeal agreed with the High Court that the power could only be exercised by deed and not by written announcement. The Court of Appeal thought that the language of the power "is not merely plain, it is unmistakable" and stated that the first part of the clause defines the "single mode" by which amendments can be made (that is, by deed) and the second part is concerned with the date from which amendments can be effective.
The second question was whether European law prevented the amendment power from being used retrospectively to level down benefits by amending NPA to 65 for men and
women. The High Court concluded that European law did prevent this and therefore equalisation did not take place until the deed was executed on 2 May 1996. The Court of Appeal thought that the High Court had: (i) analysed a 1994 judgment of the European courts as one in which it disallowed retrospective levelling down; (ii) thought that this 1994 case was in all material respects indistinguishable from the present case; and (iii) concluded that retrospective levelling down was not permitted even where there was power to do so under domestic law. However, the Court of Appeal was not persuaded that this is necessarily what the 1994 judgment had decided. It noted that the power of amendment in the 1994 case did not appear to permit such retrospective amendments. The Court of Appeal also stated that the rights of the advantaged class are meant to be the benchmark for equalisation during the Barber window, but disallowing retrospective levelling down appears to give both the advantaged and disadvantaged classes better pension rights than those of the advantaged class. This is because during the period 1 December 1991 to 2 May 1996 the advantaged class (women) had only a defeasible right in domestic law to an NPA of 60 because the announcement increasing NPA to 65 could be implemented by use of the retrospective amendment power. However, by giving men and women an NPA of 60 during this period, the right of women to an NPA of 60 becomes indefeasible and men's rights are improved by reducing NPA to 60 and making those rights indefeasible. The Court of Appeal therefore decided to refer to the Court of Justice of the European Union (CJEU) the question of whether the relevant 1994 judgment had established a principle requiring defeasible rights be to rendered indefeasible even where there is a power under domestic law to retrospectively level down. Depending on what the CJEU decides, this judgment could have an impact for schemes with similar amendment powers to the scheme in this case.
The Court of Appeal thought that the final question concerning whether section 62 of the Pensions Act 1995 (which provided for schemes to be treated as containing an equal treatment rule) had the effect of closing the Barber window is a matter of statutory construction of domestic law which would be better resolved once the CJEU has dealt with the issue referred to it.
AWARDS FOR DISTRESS AND INCONVENIENCE
In June 2015 The Pensions Ombudsman ("TPO") published a factsheet about redress for applicants for nonfinancial injustice caused by maladministration. In relation to the amount of such awards the factsheet includes that: (i) if non-financial injustice is significant, awards should properly reflect this with the usual starting point for awards being 500 or more, and in most cases redress is likely to range from 500 to 1,000; (ii) sometimes higher awards are necessary, for example, where there was ill-health or lifestyle choices were affected; and (iii) although the courts have historically held that an award over 1,000 should only be given in exceptional circumstances, there has been a recognised general shift in attitudes to make higher awards, with the guidance giving examples of 2011 determinations in which 5,000 and 4,000 were awarded.
In March 2017 the High Court issued a judgment in relation to an appeal against a determination of TPO in which it noted that a 1998 judgment stated that an award in excess of 1,000 should not be made unless there are very exceptional circumstances. However, the judge in the March 2017 case went on to state that, by reference to the Bank of England's online inflation calculator, the present equivalent of 1,000 in 1998 is in excess of 1,600 and, in his view, "after two decades it is time to rebase the upper limit for compensation falling short of being very exceptional at 1,600" and urged TPO to do so.
October 2017 High Court judgment
In October the High Court issued a judgment in relation to an appeal against a determination of the Deputy Pensions Ombudsman ("DPO") concerning the provision of incorrect information relating to whether the member benefitted from a special status in a public service pension scheme which would have meant that she had an entitlement to an unreduced pension at age 55, rather than 60. In 2014 the member was provided with estimates of benefits based on her having such an entitlement which referred to a pension of 7,345 and a lump sum of 48,971. The member states that she relied on this information when deciding to retire. However, she was not in fact entitled to an unreduced pension at age 55 because she did not meet
one of the criteria needed to have the relevant special status (that she had been in the type of job that could attract this status for the whole of the last five years of her pensionable employment). In 2008 and 2010 the member had been provided with information which failed to mention this criterion. The benefits that were brought into payment a pension of 6,147 and a lump sum of 40,981 were lower than the estimates because the benefits had to be reduced as they were being paid before age 60. The DPO concluded that in the circumstances of this case, the member had not demonstrated financial loss but that she should be awarded 500 for distress caused.
The High Court dismissed the member's appeal against the DPO's finding in relation to financial loss but allowed the appeal on the ground that the DPO was wrong in law to award only 500. The judge identified a number of factors that meant he was satisfied that the award of 500 probably results from an error in the application of principle including that the DPO appears to have found only one instance of maladministration, the number of instances is material to the likely level of distress and the evidence shows a chain of estimates and summaries which overlooked the need to have been in a special class status job for the whole of the last five years of pensionable employment, each of which amounts to maladministration. The High Court therefore exercised the compensating power afresh and awarded 2,750. The judge stated that the top end of the "normal" band for awards may be taken to be 1,600 and the award in this case should be above that because of the number of opportunities there were to correct the misinformation given, the relative ease with which the true position could be ascertained and the period through which the maladministration persisted.
This case is notable both in providing an example of the factors that can lead the court to conclude that the award for distress and inconvenience should be above the standard range and in following the March 2017 case by stating that 1,600 can be regarded as the top end of the standard band. It will be interesting to see whether TPO updates its guidance on redress to reflect the 1,600 figure.
08 | Pensions Round-Up October 2017
VAT SERVICES PROVIDED BY REGULATED INSURANCE COMPANIES
On 5 October HMRC announced a change in its policy about the VAT treatment of pension fund management services provided by regulated insurance companies. The Brief explains that HMRC policy has allowed all pension fund management services provided by regulated insurance companies to be exempt from VAT and goes on to provide further background about case law and previous considerations of the policy in this area.
In relation to the change of policy, the Brief states that the policy of allowing insurers to treat their supplies of non-special investment fund pension fund management services as VAT exempt insurance is to be discontinued from 1 January 2018. However, it also states that HMRC understands that the great majority of pension fund management services provided by insurers are supplied for DC pension funds and therefore qualify for exemption as special investment funds.
END OF CONTRACTING-OUT
On 12 October HMRC published its latest Countdown Bulletin in relation to the end of contracting-out which includes: (i) a reminder that HMRC will no longer track contracted-out rights after 5 April 2016 and therefore schemes do not need to advise HMRC of any transfers that take place after that date; and (ii) an update on some of the automated solutions in relation to the Scheme Reconciliation Service.
FLEXIBLE PAYMENT STATISTICS
On 25 October HMRC published updated statistics about flexible payments which show that in the third quarter of 2017 435,000 payments were made to 198,000 individuals and the total value of payments was 1,590 million.
PENSION SCHEMES NEWSLETTER
On 31 October HMRC published its latest pension schemes newsletter.
In previous newsletters HMRC has reported on its plans to introduce a new pensions online service in two stages in April 2018 and April 2019. From April 2018 HMRC will move pension scheme registration and registering as a scheme administrator onto the new service and, to allow existing administrators to register new schemes on the new service, it will also transfer existing scheme administrator data onto the new service by April 2018. In this latest newsletter HMRC provides a further request for administrators who have not already done so to log on and check that their details are complete and up to date in order to ensure that HMRC has enough information to move them to the new service. HMRC also reports that over the next six to eight weeks it will start work on building prototypes for the new service and provides contact details for administrators to use if they would like to take part in HMRC's user research or get involved in user testing of the prototypes.
Other updates in the newsletter include:
that HMRC will be publishing draft regulations about relief at source and Scottish income tax for a technical consultation in November;
a reminder to ensure that all payments that administrators make contain the relevant charge reference number and noting the issues that can arise if these are not included; and
that a February 2017 newsletter included an article about extended drawdown pension tables which should be used for calculations undertaken after 1 July 2017 but this date should not be confused with the nominated date that the scheme administrator uses to perform the calculation.
ON THE HORIZON
2017/18 January 2018 6 April 2018
25 May 2018 2018/19 2019
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 other reforms.
In March 2017 the Government published a response to its consultation on equalisation for the effect of GMPs noting that a number of issues will be considered with the industry working group. The date that any final form documents will be published is not known.
Following a consultation issued in April 2017, amendments to the employer debt legislation were expected to come into force on 1 October 2017 but the response to consultation and final form regulations have not yet been published.
A Finance Bill including the new tax exemption for employer-arranged pensions advice and the reduction in the money purchase annual allowance to 4,000 was introduced to Parliament in September 2017.
The government will publish its Autumn Budget on 22 November 2017.
In December the PPF is expected to publish the final PPF Levy Rules for 2018/19.
A review of automatic enrolment is taking place in 2017. A report setting out policy recommendations is expected towards the end of 2017.
The DWP is expected to consider further measures in relation to transfers of contracted-out rights to schemes that have never been contracted-out.
Following the DB Green Paper published in February 2017, a White Paper setting out options for reform is expected this winter.
Following its October consultation the PPF is expected to publish updated forms for contingent asset agreements.
The lifetime allowance is due to be indexed annually in line with CPI.
Regulations are expected to come into force introducing new requirements in relation to disclosure of information on costs, charges and investments for trustees of occupational pension schemes providing money purchase benefits. Subject to these regulations coming into force, the FCA intends to consult in the second quarter of 2018 on its proposals for workplace personal pension schemes.
Regulations are expected to come into force to simplify the requirements on bulk transfers of DC pensions without member consent from one occupational pension scheme to another occupational pension scheme.
Changes to the legislation on valuing safeguarded benefits for the purpose of the advice requirement and to require risk warnings to be given to members with safeguarded-flexible benefits are due to come into force.
Changes to the Finance Act 2004 are expected to be made which will allow HMRC to refuse to register or to de-register a scheme if it is an occupational pension scheme and a sponsoring employer is a dormant company.
The new EU General Data Protection Regulation will apply.
The government intends to implement the master trust authorisation regime in late 2018, with the regime fully rolled out in 2019. Changes to limit the statutory right to transfer in order to tackle pension scams are expected to be coordinated with the roll out of the master trust authorisation regime.
Member States must transpose the IORP II Directive into national law by 13 January 2019.
The Government will ensure the industry designs, funds and launches a pensions dashboard by 2019.
10 | Pensions Round-Up October 2017
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