Publication
Keeping your dawn raid guidance current
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules.
United Kingdom | Publication | November 2023
The Chancellor’s Autumn Statement on November 22, 2023, included a long list of pensions announcements, although only the first three set out below have a firm starting date of April 6, 2024.
Consultations, responses, calls for evidence or reviews were published on:
Comment
After years of initiatives fiddling around the edges of forcing consolidation of pension schemes, the Government has come up with two big policies which will have a major effect on the non-retail market. Firstly, employer-originated DC pension schemes which currently offload pension pots at retirement will have to go full service, providing all the retirement options themselves or partnering with a provider to do that. Secondly, members will be able to direct employer contributions to their own scheme, to keep their savings in one place. Only the retail master trust and GPP providers are likely to have the appetite for either proposal in the long term.
Although the Chancellor made repeated references to “pensions” in his speech, there is not a great deal here that is very concrete - and little that we haven’t seen flagged over the last few weeks. It is unlikely that all these initiatives, calls for evidence and consultations will see light of day before the next election.
However, the willingness to reconsider the rules around how DB scheme surpluses could be repaid, coupled with the reduction in the authorised repayment of surplus charge to 25 per cent seeks to incentivise schemes to achieve higher investment returns. This does expose a policy schism, given the draft Funding and Investment Regulations in their current form, and the steady-state of a low-risk low dependency asset allocation they advocate.
Publication
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules.
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