Of interest to all schemes except those providing only defined benefits is the Pensions Regulator’s (TPR’s) statement for trustees of occupational pension schemes affected by the new definition of money purchase benefits, which came into force on 24 July 2014 under the Pensions Act 2011 (Transitional, Consequential and Supplementary Provisions) Regulations 2014 (the Bridge Regulations) following the coming into force of section 29 of the Pensions Act 2011.

Where a scheme which has been treated as money purchase and, following the trustees’ review, is found to offer benefits that have the potential to give rise to a funding deficit, TPR says trustees must notify it “immediately” so that it can amend its records.

However, the immediate reporting requirement referred to by TPR is not a requirement of the Bridge Regulations, although they do require any schemes eligible for PPF entry to inform TPR by 31 March 2015 that their scheme now includes non-money purchase benefits (which may therefore affect the level of PPF compensation payable).

TPR may have based its “immediate” reporting requirement on section 62(4) of the Pensions Act 2004, which sets out the requirements for the provision of registrable information to TPR, including a change of categories of benefits under the scheme. However, the Pensions Act 2004 requirement is for the information to be provided “as soon as reasonably practicable.”

View the Statement.