RE: Better workplace pensions: further measures for savers
|
|
- Ariel Long
- 5 years ago
- Views:
Transcription
1 15 May 2014 Private Pensions Policy and Analysis Department for Work and Pensions 1 st Floor, Caxton House 6-12 Tothill Street London SW1H 9NA Submitted via reinvigorating.pensions@dwp.gsi.gov.uk RE: Better workplace pensions: further measures for savers Dear Sirs, BlackRock is pleased to have the opportunity to respond to the matters for further consultation within the Better workplace pensions; further measures for savers paper published in March BlackRock is a premier provider of asset management, risk management and advisory services to institutional, intermediary and individual clients worldwide. BlackRock also has extensive expertise in the fixed income markets and significant client holdings in securitised assets and serves as collateral manager to certain securitised products. BlackRock is one of the world s leading asset management firms, managing approximately 2.64 trillion as at 31 March 2014 on behalf of institutional and individual clients worldwide, across equity, fixed income, cash management, alternative investment and multi-investment and advisory strategies including the ishares exchange traded funds. Our client base includes public and private sector pension plans, insurance companies, third-party distributors and mutual funds, endowments, foundations, charities, corporations, official institutions and banks as well as individuals around the world. BlackRock represents the interests of its clients by acting in every case as their agent. It is from this perspective that we engage on all matters of public policy. BlackRock supports policy changes and regulatory reform globally where it increases transparency, protects investors, facilitates responsible growth of capital markets and, based on thorough cost-benefit analysis, preserves consumer choice. BlackRock is a member of the European Fund and Asset Management Association (EFAMA) and a number of national and sectoral industry associations 1 reflecting our European client base and activities. We support efforts to deliver enhancements to the workplace pension landscape. The proposals should generate further competition in the market and thereby deliver further benefits to individual scheme members. In supporting these efforts, there are however some key points which need to be considered before the regime can be finalised: 1. The accreditation process has the potential to add value by incentivising administrators to meet quality standards and achieve this accreditation. However, in order that the process is effective, the standards must be consistently applied, embraced by industry 1 Amongst others are: Alternative Investment Management Association (AIMA); Association of British Insurers (ABI); Association of Luxembourg Fund Industry (ALFI); Assogestioni; Bundesverband Investment und Asset Management (BVI); CityUK; Dutch Fund and Asset Management Association (DUFAS); Institutional Money Market Fund Association (IMMFA); Investment Management Association (IMA); International Securities Lending Association (ISLA); and National Association of Pension Funds (NAPF). 1
2 and subject to continual monitoring in order that the accreditation constitutes a viable differentiator between administrators. 2. The proposals will generate additional costs, impacting therefore the individual scheme members. It is important that a thorough cost-benefit analysis is performed before the requirements are finalised as this will enable a determination of the detail or flexibility which is imposed upon schemes and administrators through the new rules. 3. The proposals are due to come in to effect in April 2015, which provides less than a year until the obligations are live despite the absence of fully finalised requirements. Consequently, we would welcome a suitable transitional period within which administrators and schemes can work towards compliance with these new requirements. The new quality obligations should not be rushed in order to deliver appropriate quality; in some respects this will take time as the required standards are developed and resources sourced and obtained. Without a transitional period there is a risk that the required quality of service will not be initially available. This would not be consistent with the overall objectives of the proposals. 4. We welcome the further consultation and provider workshops as proposed at the FCA s industry workshop on Independent Governance Committees held on 30 April. We acknowledge that there are some broader challenges that need to be worked through as summarised at that meeting. Amongst these we note the issues over the potential limitations of Contract Law on the way in which independent governance committees can operate and the challenge in consistently describing value for money standards at an industry level. We respond in more detail below to the consultation questions that are of relevance to us and our end-investors reflecting where we believe we can add value to the consultation. We welcome the opportunity to address, and comment on, the issues raised by the consultation paper and the broader issues associated with implementation of the amendments to the workplace pensions landscape, and we would be happy to work with DWP on any specific issue(s) that may assist in improving the implementation of the proposals. Yours faithfully Paul Bucksey Managing Director, BlackRock Head of UK Defined Contribution 2
3 Responses to questions 1. We would welcome views on the potential benefits of accreditation of administrators, and what role government and regulators could play in supporting this. The accreditation of administrators can potentially provide some benefits through raising standards within the industry. However, in order for this to occur, the accreditation must be meaningful and supported by market participants with thorough standards that are recognised and adopted by the industry. There is also a need to ensure an effective mode of assessment is in operation if the accreditation is to remain meaningful over time. The delivery of a robust accreditation process will enable employers to distinguish the difference between administrators that have or do not have that accreditation. If this process is not sufficiently robust, the ability of trustees to differentiate between two administrators will be limited and driven largely by costs. The central role of regulators in any accreditation scheme will be to ensure that a standard approach is adopted. This will generate consistency and thereby allow employers to see value in the receipt of any accreditation. However, any accreditation process will incur costs, both initially and on an ongoing basis. These costs will need to be taken into consideration as the process is finalised in order that the outcome delivers benefits which significantly outweigh the costs. 2. We would also welcome suggestions of other approaches to helping trustees and Independent Governance Committees (IGCs) ensure that their scheme is being administered to a good standard. The trustees and IGCs should be responsible for establishing the standards which they expect the scheme to adhere to. These should be based on minimum standards to which the industry must adhere, but allow trustees and IGCs to raise standards further in pursuit of the appropriate outcome for their individual members. In order that this may operate efficiently, there is a need for some form of benchmarking exercise to be performed. This could be through the periodic publication of examples of good practice which have been observed by the regulatory authorities. The publication through this means would provide the added value of independence when compared against any information which the scheme could provide internally to the trustees and IGCs, and would be in keeping with the objectives of establishing the IGCs. The information which could be used to provide an indication of the quality of administration could include: complaints; error rates; administration charges; staff retention rates; and qualifications of key individuals, as well as other measures trustees may find of use. 3. Should mastertrusts have to meet the same independence standards as providers of contract-based schemes? The two models are not the same, and should not therefore be subject to the same levels of independence. It would be of greater benefit to the individual members to ensure that the overall levels of governance to which these two scheme types were exposed are equivalent. This would allow the different models to exist but provide choice over the adoption of individual requirements to reflect the nature, scale and complexity of the individual scheme. 4. We would welcome views on the proposed definition of independent at Annex B. The concept of independence is something which is already in existence through other governance arrangements; an example of such being the UK Corporate Governance Code. It is not clear why the proposed definition of independence within the paper is more onerous than 3
4 that which is already an accepted term within use elsewhere. We consider therefore that any definition should be consistent with that which is already in use elsewhere. This would ensure there was consistency of approaches throughout corporate governance arrangements and deliver a solution which had synergies with existing governance. Such synergies would engender an approach which could be more easily considered alongside, and compared with, those governance arrangements which already exist within UK corporations. The proposed definition could also create practical challenges in implementation. The requirement for the IGC to have at least seven members, the majority of which are independent, will create challenges for schemes when seeking to identify and recruit these individuals, especially given the ban on recruitment of IGC members who have an existing material relationship with the company within the last three years. The pool of suitable and available candidates is likely to be limited, at least initially. We support the emerging view across many providers that a membership of no more than five would provide a workable option. We also request that implementation provides for: (a) a transitional period after implementation of at least a further year during which recruitment can be performed; and (b) for situations thereafter where the membership of the IGC falls below the minimum required (for whatever reason) there is a grace period within which the recruitment process for the new member(s) may be performed. Given the size and scope of BlackRock s activities, we anticipate that the ban on recruitment of members who have a material business relationship with the firm during the past three years could limit the availability of candidates for our IGCs. Consequently, we would welcome guidance on the definition of what constitutes a material business relationship and would suggest that this definition should permit members to be recruited where no material conflicts exists between the parties, but allowing a business relationship to exist. This is an area of potential ambiguity that should be clarified. We also note that members views should be directly represented, suggesting that candidates from consumer groups and technical groups / industry bodies should be considered for inclusion in the IGC. We would welcome guidance here in order to ensure that any potential conflict with existing business relationships are avoided. 5. Should the independence requirements be applied in different ways to different models of mastertrust? In particular, how should the independence requirements be applied to mastertrusts that use an independent trustee firm to act as their corporate trustee? The relationships under a mastertrust can be complex and therefore there is a need to ensure careful consideration of any proposal before its introduction. It may be appropriate here to define at a high level the concept of independence for all trust-based schemes but allow the individual scheme to determine how exactly this should be applied having regard to any specificities associated with the scheme. 10. We would welcome views on how these transparency requirements could be made to work effectively in unbundled trust-based arrangements (including mastertrusts). By increasing the transparency obligations that are placed on unbundled trust-based arrangements, the compliance costs associated with that transparency would increase. This would be a result of the additional level of data collation which the administrator would need to perform in order to report on the transaction costs per individual member. The benefit which would be generated through the additional transparency must be considered against the increase in costs per member which would be associated with this transparency and therefore we request that a thorough cost-benefit analysis is performed before further progression of this matter. 4
5 11. We would welcome views on whether the transparency requirements we propose for DC schemes should, in the future, be extended to DB schemes, to enable sponsoring employers to further scrutinise the costs of such schemes. In general, there is a less direct correlation between individual cost components and the outcome for pensioners in a DB scheme when compared to a DC scheme. With the former, the outcome for pensioners is more affected by factors such as the cost of providing guarantees and the investment return. This has the consequence that the imposition of similar transparency requirements on DB and DC schemes may not provide the employer with comparable information. For this reason, and whilst we support harmonisation to the extent that it provides benefit, we do not believe that the transparency requirements for DC schemes should be applied verbatim to DB schemes unless this is justifiable based on a thorough costbenefit analysis. 5
Chris Hodge Financial Reporting Council Aldwych United Kingdom London WC2B 4HN
Chris Hodge Financial Reporting Council BLACKROCK Fifth Floor 12 Throgmorton Avenue Aldwych House London, EC2N 2DL 71-91 Aldwych United Kingdom London WC2B 4HN London, 13 July 2012 Consultation Paper on
More informationBlackRock appreciates the opportunity to provide comments on the Department s proposals on workplace pension charging.
12 Throgmorton Avenue London EC2N 2DL Tel 020 7743 3000 Fax 020 7743 1000 www.blackrock.co.uk 28 November 2013 Charges Team Private Pensions Policy and Analysis 1 st floor, Caxton House 6-12 Tothill Street
More informationIOSCO Consultation Report on Principles of Liquidity Risk Management for Collective Investment Schemes
2 August 2012 Mr. Mohamed Ben Salem General Secretariat International Organization of Securities Commissions (IOSCO) Calle Oquendo 12 28006 Madrid Spain RE: IOSCO Consultation Report on Principles of Liquidity
More informationEuropean Securities and Markets Authority 103, Rue de Grenelle BLACKROCK Paris 12 Throgmorton Avenue London, EC2N 2DL United Kingdom
European Securities and Markets Authority 103, Rue de Grenelle BLACKROCK 75007 Paris 12 Throgmorton Avenue France London, EC2N 2DL United Kingdom London, 23 March 2012 Discussion paper on key concepts
More informationRE: Transaction Costs Disclosure: Improving Transparency in Workplace Pensions: Call for Evidence
6 May 2015 Department for Work and Pensions Transparency Team Department for Work and Pensions 3rd Floor West, Zone G Quarry House Leeds, LS2 7UA Submitted via email to: Ms Carol McGinley and Mr Michael
More informationRE: The future of retirement A Consultation on investing for NEST s members in a new regulatory landscape
National Employment Savings Trust Riverside House 2A Southwark Bridge Road London SE1 9HA 2 February 2015 Submitted via email to: nestresponses@nestcorporation.org.uk RE: The future of retirement A Consultation
More informationESMA DISCUSSION PAPER ON SHARE CLASSES OF UCITS (23 December 2014) (the Discussion Paper )
European Securities and Markets Authority www.esma.europa.eu 12 Throgmorton Avenue 26 March 2015 Dear Sir/Madam ESMA DISCUSSION PAPER ON SHARE CLASSES OF UCITS (23 December 2014) (the Discussion Paper
More informationRE: Wholesale sector competition review call for inputs
9 October 2014 Becky Young Policy, Risk and Research Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted via email to: wholesalecompetition@fca.org.uk RE:
More informationSubmitted by to:
11 June 2014 Freedom and Choice in Pensions Consultation Pensions and Savings Team HM Treasury 1 Horse Guards Road London SW1A 2HQ Submitted by e-mail to: Pensions.Consultation2014@hmtreasury.gsi.gov.uk
More informationBlackRock is pleased to have the opportunity to respond to the Financial reporting Council s (FRC) consultation on directors remuneration.
13 December 2013 Catherine Woods Financial Reporting Council Fifth Floor Aldwych House 71-91 Aldwych London WC2B 4HN Submitted via email to: remcon@frc.org.uk RE: FRC Directors Remuneration Consultation
More informationIMA RESPONSE TO DWP CONSULTATION. Better workplace pensions: Further measures for savers
IMA RESPONSE TO DWP CONSULTATION Better workplace pensions: Further measures for savers May 2014 1 Better workplace pensions: Further measures for savers IMA Response to DWP Consultation The IMA 1 welcomes
More informationBlackRock is pleased to have the opportunity to respond to the Call for Evidence AIFMD passport and third country AIFMs.
8 th January 2015 European Securities and Markets Authority 103 Rue de Grenelle 75007 Paris France Submitted via electronic submission RE: Call for evidence AIFMD passport and third country AIFMs Dear
More informationESMA s policy orientations on possible implementing measures under the Market Abuse Regulation
24 January 2014 European Securities and Markets Authority 103 rue de Grenelle 75007 Paris France Submitted online at: www.esma.europa.eu RE: ESMA s policy orientations on possible implementing measures
More informationFRC Proposed revisions to the UK Corporate Governance Code
27 June 2014 Catherine Woods Financial Reporting Council Fifth Floor Aldwych House 71-91 Aldwych London WC2B 4HN Submitted via email to: codereview@frc.org.uk RE: FRC Proposed revisions to the UK Corporate
More informationRe: Response to the OSC Staff Consultation Paper Disclosure Requirements Regarding Women on Boards and in Senior Management
400 Howard Street San Francisco, CA 94105 Tel 415.670.2000 www.blackrock.com The Secretary Ontario Securities Commission 20 Queen Street West 22nd Floor Toronto, Ontario M5H 3S8 Submitted via Email: comments@osc.gov.on.ca
More informationSubmitted via
AE 2017 Review Team, Private Pensions Directorate Department for Work and Pensions First Floor, Caxton House Tothill Street, London SW1H 9NA 24 March 2017 Submitted via email: 2017AUTOMATIC.ENROLMENTREVIEW@DWP.GSI.GOV.UK
More informationRe: Call for evidence on the future structure of the Local Government Pension Scheme
Department for Communities and Local Government Eland House Bressenden Place London SW1E 5DU Submitted via email to LGPSReform@communities.gsi.gov.uk 27 September 2013 Re: Call for evidence on the future
More informationResponse to the Consultation by Commission Services on legislative steps for the Packaged Retail Investment Products (PRIPs) initiative
Response to the Consultation by Commission Services on legislative steps for the Packaged Retail Investment Products (PRIPs) initiative BlackRock welcomes the opportunity to respond to the European Commission
More informationThe draft Occupational Pension Schemes (Employer Debt) (Amendment) Regulations IFoA response to Department for Work and Pensions
The draft Occupational Pension Schemes (Employer Debt) (Amendment) Regulations 2017 IFoA response to Department for Work and Pensions 18 May 2017 About the Institute and Faculty of Actuaries The Institute
More informationPublic consultation on the 2014 Review of the OECD Principles of Corporate Governance
2 January 2015 Directorate for Financial and Enterprise Affairs Organisation for Economic Co-operation and Development 2, rue André Pascal 75775 Paris Cedex 16 France Submitted via email to: dafca.contact@oecd.org
More informationRE: Implementation of the Transparency Directive Amending Directive (2013/50/EU) and other Disclosure Rule and Transparency Rule Changes
20 May 2015 Kate Hinchy Markets Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted via email to: cp15-11@fca.org.uk RE: Implementation of the Transparency
More informationProposed Revision to the UK Stewardship Code Annex A - Revised UK Stewardship Code
Consultation Financial Reporting Council January 2019 Proposed Revision to the UK Stewardship Code Annex A - Revised UK Stewardship Code The FRC s mission is to promote transparency and integrity in business
More informationTISA RESPONSE TO DWP s CONSULTATION PAPER BETTER WORKPLACE PENSIONS: PUTTING SAVERS INTERESTS FIRST
TISA RESPONSE TO DWP s CONSULTATION PAPER BETTER WORKPLACE PENSIONS: PUTTING SAVERS INTERESTS FIRST November 2014 version 1.0 Page 1 of 7 INTRODUCTION TISA is a not-for-profit membership association operating
More information15 February 2018 GUY OPPERMAN MP. Mary Creagh MP Chair, Environmental Audit Committee House of Commons
GUY OPPERMAN MP Minister for Pensions Mary Creagh MP Chair, Environmental Audit Committee House of Commons 15 February 2018 Dear Mary, Thank you for inviting me to respond on a number of questions in relation
More informationFinance & investment briefing
Finance & investment briefing September 2017 Sackers finance & investment group takes a look at current issues of interest to pension scheme investors Finance & investment briefing September 2017 Abbreviations
More informationLocal Government Pension Scheme: Revoking and replacing the Local Government Pension Scheme (Management and Investment of Funds) Regulations 2009
19 th February 2016 LGPS Reform Department for Communities and Local Government 2/SE Quarter, Fry Building 2 Marsham Street London SW1P 4DF Submitted via email to: lgpsreform@communities.gsi.gov.uk RE:
More informationCP 13/17 Consultation on the use of dealing commission rules
4th floor, Ropemaker Place 25 Ropemaker Street London EC2Y 9LY United Kingdom +44 20 7260 2000 Phone +44 20 7260 2001 Fax www.markit.com February 25, 2014 Adam Wreglesworth Wholesale Conduct Policy & Client
More informationASSESSING GOOD VALUE FOR MEMBERS
December 2015 ASSESSING GOOD VALUE FOR MEMBERS in association with: in association with: CONTENTS About the authors 4 Introduction 6 1 Setting out your approach 11 2 Identifying costs and charges 12 3
More informationRE: Concept Paper on Review of the Corporate Governance Code and Related Listing Rules
30 Nov 2017 Hong Kong Exchanges and Clearing Limited 12/F, One International Finance Centre 1 Harbour View Street Central Hong Kong Submitted via email to: response@hkex.com.hk RE: Concept Paper on Review
More informationRemedying Poor Value Legacy Workplace Pension Schemes: Findings from the Joint Review of Industry Progress against the Independent Project Board
Remedying Poor Value Legacy Workplace Pension Schemes: Findings from the Joint Review of Industry Progress against the Independent Project Board Recommendations December 2016 1 Summary of Findings from
More informationRE: Investment Consultants Market Investigation Working paper: information on fees and quality
Investment Consultants Market Investigation Competition and Markets Authority Victoria House Southampton Row London WC1B 4AD Date: 27 March 2018 Dear Sir/Madam, RE: Investment Consultants Market Investigation
More informationWe refer to the discussion document on options for extending the Accredited Employers Programme and introducing choice in the Work Account.
15 July 2011 Department of Labour Attention ACC discussion P O Box 3075 Wellington 6140 Dear Sir Increasing choice in workplace accident compensation We refer to the discussion document on options for
More informationPension Schemes Bill Impact Assessment. Summary of Impacts
Pension Schemes Bill Impact Assessment Summary of Impacts June 2014 Contents 1 Introduction... 3 Background... 4 Categories of Pension Scheme... 4 General Changes to Pensions Legislation... 4 Collective
More informationPensions Client Directorate. Pensions - Summary of responses to the consultation on the draft scheme order and rules
Pensions Client Directorate Pensions - Summary of responses to the consultation on the draft scheme order and rules 26 October 2009 CONTENTS Introduction 1 Response to the consultation on the draft scheme
More informationHMRC consultation on tax deductibility of corporate interest expense
Submitted via email to: BEPSinterestconsultation@hmtreasury.gsi.gov.uk 4 August 2016 RE: HMRC consultation on tax deductibility of corporate interest expense Dear Sirs, BlackRock [1] is pleased to have
More informationCOMMISSON ON DORMAN ASSETS: CALL FOR EVIDENCE
8 June 2016 Commission on Dormant Assets 4 th Floor 1 Horse Guards Road London, SW1A 2HQ Submitted via email to: consultations@dormant-assets.com RE: COMMISSON ON DORMAN ASSETS: CALL FOR EVIDENCE Dear
More informationPMI Qualifications Guide 2018
PMI Qualifications Guide 2018 Contents About us................................ 3 Why choose PMI?.......................... 4 Member benefits.......................... 5 Qualifications............................
More informationBRITISH BANKERS ASSOCIATION
BRITISH BANKERS ASSOCIATION Pinners Hall 105-108 Old Broad Street London EC2N 1EX Tel: +44 (0) 20 7216 8800 Fax: +44 (0) 20 7216 8811 BBA RESPONSE TO CESR ADVICE ON POSSIBLE IMPLEMENTING MEASURES OF THE
More informationThe Search for Quality: Group Personal Pension Plans or Master Trust?
Aon Defined Contribution The Search for Quality: Group Personal Pension Plans or Master Trust? Risk. Reinsurance. Human Resources. The Search for Quality: Group Personal Pension Plans or Master Trust?
More information9 May
9 May 2013 Email: s.leonard@frc.org.uk Steven Leonard Project Director, Audit & Assurance Codes & Standards Division The Financial Reporting Council 5th Floor, Aldwych House 71-91 Aldwych LONDON WC2B 4HN
More informationConsultation on the review of the Prospectus Directive. Submission from the Association of Investment Companies
Consultation on the review of the Prospectus Directive Submission from the Association of Investment Companies The Association of Investment Companies (AIC) welcomes the opportunity to respond to the European
More informationCESR Consultation Paper Inducements: Good and Poor Practices
22 December 2009 CESR 11-13 avenue de Friedland Paris 75008 France Dear Sirs, CESR Consultation Paper Inducements: Good and Poor Practices The IMA represents the UK-based investment management industry.
More informationConsultation Paper - Draft technical standards under the Benchmarks Regulation
4th floor, Ropemaker Place 25 Ropemaker Street London EC2Y 9LY United Kingdom +44 20 7260 2000 Phone +44 20 7260 2001 Fax ihsmarkit.com ESMA 103 rue de Grenelle 75007 Paris, France Submitted online www.esma.europa.eu
More informationProspectus Directive Review An Investor Perspective
15 May 2015 European Commission Directorate General for Financial Stability, Financial Services and Capital Markets Union Submitted electronically RE: Prospectus Directive Review An Investor Perspective
More informationAsset Management Market Study Interim Report: Annex 5 Institutional Demand Side
MS15/2.2: Annex 5 Market Study Interim Report: Annex 5 November 2016 Annex 5: Institutional demand side In order for competition to work effectively in the institutional asset management sector, institutional
More informationKey Principles of Good Governance for Workplace Defined Contribution Pension Plans throughout Europe
Key Principles of Good Governance for Workplace Defined Contribution Pension Plans throughout Europe Core features Value for money Investments Fit and proper persons Accountability Administration Communication
More informationAlternative Investment Management Association
Alternative Investment Management Association European Banking Authority 18th Floor Tower 42 25 Old Broad Street London EC2N 1HQ Submitted via email to: EBA-CP-2013-11@eba.europa.eu 21 August 2013 Dear
More informationDeutsche Bank welcomes the opportunity to provide comments on the above consultation.
Secretariat of the Financial Stability Board, c/o Bank for International Settlements CH-4002, Basel, Switzerland 28 November 2013 Deutsche Bank AG Winchester House 1 Great Winchester Street London EC2N
More informationICSA response to the Department for Business, Energy and Industrial Strategy (BEIS) consultation on Insolvency and Corporate Governance
Insolvency and Corporate Governance Business Frameworks Directorate Department for Business, Energy and Industrial Strategy 1st Floor 1 Victoria Street London SW1P 0ET By email: insolvencyandcorporategovernance@beis.gov.uk
More informationMeaningful Disclosure of Costs and Charges Summary Paper
February 2015 Meaningful Disclosure of Costs and Charges Summary Paper Page 0 of 13 OVERVIEW This technical position paper builds on The Investment Association s work over the past three years, which has
More informationNORTHERN TRUST A YEAR IN REVIEW: 2008 CROSS-BORDER PENSION/ASSET POOLING
S E R V I C E l E X P E R T I S E l I N T E G R I T Y NORTHERN TRUST A YEAR IN REVIEW: 2008 CROSS-BORDER PENSION/ASSET POOLING Service Expertise Integrity P R I N C I P L E S T H A T E N D U R E Over the
More informationTransaction Costs Disclosure: Improving Transparency in Workplace Pensions - Call for Evidence
1 May 2015 Transparency Team Department for Work and Pensions 3rd Floor West, Zone G Quarry House Leeds, LS2 7UA reinvigorating.pensions@dwp.gsi.gov.uk Copied to Carol McGinley Strategy & Competition Financial
More informationTechnical Guide: Operation For people, not profit
The People s Pension Technical Guide: Operation For people, not profit Title 2 The People s Pension Technical Guide: Operation CONTENTS Summary 4 The People s Pension 5 A multi-employer scheme 6 One pot,
More informationRegulating the pensions and retirement income sector: Our strategic approach. Joint call for input
Regulating the pensions and retirement income sector: Our strategic approach Joint call for input March 2018 You can download this document from the FCA s website: www.fca.org.uk and TPR s website: www.tpr.gov.uk.
More informationShadow Banking. June Avocats à la Cour
Shadow Banking June 2013 Avocats à la Cour Index 1. Introduction 3 2. Definition of Shadow Banking 3 2.1 Entities 3 2.2 Activities 4 3. Benefits and risks 4 3.1 Benefits 4 3.2 Risks 4 4. Challenge for
More informationBY AND BY POST 2 June Bank Indonesia Regulation Number 7/31/PBI/2005 (the Derivatives Regulations )
ISDA International Swaps and Derivatives Association, Inc. 24 Raffles Place #24-02A Clifford Centre Singapore 048621 Telephone: (65) 6538 3879 Facsimile: (65) 6538 6942 email: isdaap@isda.org website:
More informationRE: Consultation Paper on Recommendations of the Corporate Governance Council
14 March 2018 The Secretariat, Corporate Governance Council c/o Markets Policy & Infrastructure Department Monetary Authority of Singapore 10 Shenton Way, MAS Building Singapore 079117 Submitted via email
More informationPPI PPI Briefing Note Number 108
This is the first of two Briefing Notes looking at default strategies. This Note looks at how well the objectives of pension schemes default investment strategies meet the needs of their memberships. Objectives
More informationALFI response to ESMA s Discussion Paper on UCITS share classes
Luxembourg, 27 March 2015 ALFI response to ESMA s Discussion Paper on UCITS share classes General Remarks The Association of the Luxembourg Fund Industry (ALFI) is the representative body of the Luxembourg
More informationICAEW REPRESENTATION 57/17
ICAEW REPRESENTATION 57/17 Security and Sustainability in Defined Benefit Pension Schemes ICAEW welcomes the opportunity to comment on the Security and Sustainability in Defined Benefit Pension Schemes
More informationThis final response is in addition to our first stage response submitted to CESR on 10 September and covers the following sections:
17 th September 2004 London Office 114 Middlesex Street London E1 7JH Tel: +44 (0) 20 7247 7080 Fax: +44 (0) 20 7377 0939 Email: info@apcims.co.uk By email to CESR at www.cesr-eu.org Dear Sirs Final Response
More informationIMPROVING THE QUALITY OF PENSION TRANSFER ADVICE
IMPROVING THE QUALITY OF PENSION TRANSFER ADVICE 25 MAY 2018 A RESPONSE TO FCA CONSULTATION PAPER CP18/7 ABOUT THE PLSA The Pensions and Lifetime Savings Association is the national association with a
More informationPOSITION PAPER NO On the Review of Financial Advice
POSITION PAPER NO. 1 2011 On the Review of Financial Advice ISSUED AUGUST 2011 POSITION PAPER If you require any assistance or clarification, wish to discuss any aspect of this paper or have any observations
More informationDC Explained: 101 Buzz Words
DC Explained: 101 Buzz Words By Melissa Haggith, Manager 1. AAF AAF stands for Audit and Assurance Faculty. It is part of the Institute of Chartered Accountants England and Wales (ICAEW). They have developed
More informationCapital Requirements Directive 4: consultation on country-by-country reporting
CBCR consultation Financial Services Group Floor 1, Red HM Treasury 1 Horse Guards Road London, SW1A 2HQ Email: CBCRconsultation@hmtreasury.gsi.gov.uk 18 October 2013 Dear Ali, Capital Requirements Directive
More informationThe evolving retirement landscape
The evolving retirement landscape This report has been sponsored by A Research Report by Lauren Wilkinson and Tim Pike Published by the Pensions Policy Institute May 2018 978-1-906284-52-23 www.pensionspolicyinstitute.org.uk
More informationDiscussion Paper - The Use of Credit Ratings by Financial Intermediaries, Article 5(a) of the CRA Regulation
February 27, 2015 Joint Committee of the European Supervisory Authorities European Banking Authority One Canada Square (Floor 46) Canary Wharf London E14 5AA, UK European Securities and Markets Authority
More informationFSA Consultation Paper 176. Bundling and Softing. Response from The UK Society of Investment Professionals
UKSIP is a member society of FSA Consultation Paper 176 Bundling and Softing Response from The UK Society of Investment Professionals About UKSIP The UK Society of Investment Professionals ( UKSIP ) is
More informationAsset Management Market Study Interim Report: Annex 2 Recent regulatory developments
MS15/2.2: Annex 2 Market Study Interim Report: Annex 2 November 2016 Annex 2: Introduction 1. There has been a range of relevant in the asset management sector over the past year. This annex, while not
More informationAsset Management in the UK A Summary of the IMA Annual Survey
Asset Management in the UK 2013 2014 A Summary of the IMA Annual Survey Investment Management Association 65 Kingsway London WC2B 6TD United Kingdom www.investmentuk.org September 2014 Investment Management
More informationIASB Supplement to Exposure Draft of Financial Instruments: Impairment (File Reference No )
Our Ref.: C/FRSC Sent electronically through email (director@fasb.org) 1 April 2011 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Financial Accounting Standards
More informationMerchant Navy Officers Pension Fund (MNOPF) Statement of Investment Principles
Merchant Navy Officers Pension Fund (MNOPF) Statement of Investment Principles Introduction The main purpose of the MNOPF is to provide pensions on retirement at normal pension age for Officers in the
More informationRE: Consultation on integrating sustainability risks and factors in MiFID II
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
More informationSubmitted online and by to
13 th May 2015 The European Commission, Brussels Submitted online and by email to fisma-securitisation-consultation@ec.europa.eu Dear Sirs, Executive Summary of AFME response to the Consultation Document
More informationPara 10 - The principles set out in this Part are intended to assist relevant companies by providing an overview of relevant good practices.
Irish Funds 10th Floor, One George s Quay Plaza, George s Quay, Dublin 2, Ireland. t: +353 (0) 1 675 3200 f: +353 (0) 1 675 3210 e: info@irishfunds.ie w: irishfunds.ie Consultation on Delegate Oversight
More informationVIRGIN STAKEHOLDER PENSION INDEPENDENT GOVERNANCE COMMITTEE
VIRGIN STAKEHOLDER PENSION INDEPENDENT GOVERNANCE COMMITTEE Statement for the year ending 5 April 2016 Virgin Stakeholder Pension - IGC Statement for the year ending 5 April 2016 Background With effect
More informationPensionsWatch Analysing the pensions of top company directors. Produced by PIRC for the TUC
PensionsWatch 2008 Analysing the pensions of top company directors Produced by PIRC for the TUC 1. Executive summary PensionsWatch was established by the TUC to give a picture of occupational pension provision
More informationCosmo Gibson Redress Policy, Strategy & Competition Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS. About Which?
Which?, 2 Marylebone Road, London, NW1 4DF Date: 30 March 2017 Response to: Financial Conduct Authority consultation on Reviewing the Funding of the Financial Services Compensation Scheme (FSCS) Cosmo
More informationPooled liability driven investment solutions.
LGIM OUR RANGE OF POOLED DE-RISKING SOLUTIONS Pooled liability driven investment solutions. For defined benefit schemes and their advisors With unrivalled scale and experience in the UK pension market,
More informationFor the attention of: Tax Treaties, Transfer Pricing and Financial Transaction Division, OECD/CTPA. Questions / Paragraph (OECD Discussion Draft)
NERA Economic Consulting Marble Arch House 66 Seymour Street London W1H 5BT, UK Oliver Wyman One University Square Drive, Suite 100 Princeton, NJ 08540-6455 7 September 2018 For the attention of: Tax Treaties,
More informationResponse by TISA to DWP Consultation Meeting future workplace pension changes: improving transfers and dealing with small pots.
Response by TISA to DWP Consultation Meeting future workplace pension changes: improving transfers and dealing with small pots. March 2012 TISA response to DWP Consultation: Meeting future workplace pension
More informationP a g e 1
P a g e 1 P a g e 2 P a g e 3 P a g e 4 P a g e 5 P a g e 6 P a g e 7 P a g e 8 P a g e 9 P a g e 1 P a g e 2 The Professional Footballers Pension Scheme Income Section Statement of Investment Principles
More informationBlackRock Securities Lending Unlocking the potential of portfolios
BlackRock Securities Lending Unlocking the potential of portfolios Introduction Securities lending is a well-established practice whereby mutual s make loans of securities to seek an incremental increase
More informationTurning Off the Liquidity Tap:
LMA contact T: +44 (0)20 7006 6007 F: +44 (0)20 7006 3423 lma@lma.eu.com www.lma.eu.com Turning Off the Liquidity Tap: the consequences of a no deal Brexit on the European loan market 1. INTRODUCTION This
More informationESF/SIFMA RESPONSE TO CESR CONSULTATION PAPER ON THE ROLE OF CREDIT RATING AGENCIES IN STRUCTURED FINANCE
31 March 2008 Carlo Comporti CESR Secretary General The Committee of European Securities Regulators 11-13 avenue de Friedland 75008 Paris ESF/SIFMA RESPONSE TO CESR CONSULTATION PAPER ON THE ROLE OF CREDIT
More informationWholesale Conduct Policy Team Markets Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS
Wholesale Conduct Policy Team Markets Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted to dp14-03@fca.org.uk London, September 16, 2014 Discussion Paper
More informationUK Pensions Regulation Compared
UK Pensions Regulation Compared October 2008 Key findings A study of pensions r egulation in several OECD countries pr epared by John Ashcroft for the National Association of Pension Funds. NAPF Research
More informationSecurity and Sustainability in Defined Benefit Pension Schemes Green Paper Questions and NFOP Responses
Security and Sustainability in Defined Benefit Pension Schemes Green Paper Questions and NFOP Responses OVERVIEW NFOP represents 65,000 individual pensioners predominantly in three Defined Benefit Pension
More informationSupervising retail investment advice: inducements and conflicts of interest
Guidance consultation Supervising retail investment advice: inducements and conflicts of interest September 2013 Contents 1 Executive summary 3 What does this report cover? 3 What did we find in our thematic
More informationPolicy Statement PS16/16 Implementing audit committee requirements under the revised Statutory Audit Directive. May 2016
Policy Statement PS16/16 Implementing audit committee requirements under the revised Statutory Audit Directive May 2016 Prudential Regulation Authority 20 Moorgate London EC2R 6DA Prudential Regulation
More informationEmployer Debt (Section 75 of the Pensions Act 1995) Consultation on draft regulations draft ICAEW response
19 November 2009 Our ref: ICAEW Rep 118/09 Your ref: Mike Rochford Department for Work and Pensions 7 th Floor Caxton House Tothill Street London SW1H 9NA Dear Mr Rochford Employer Debt (Section 75 of
More informationConsultation Paper Handbook changes to reflect the application of the EU Benchmarks Regulation
4th floor, Ropemaker Place 25 Ropemaker Street London EC2Y 9LY United Kingdom +44 20 7260 2000 Phone +44 20 7260 2001 Fax ihsmarkit.com Financial Conduct Authority 25 The North Colonnade London E14 5HS
More informationFINANCIAL CONDUCT AUTHORITY
FINANCIAL CONDUCT AUTHORITY ASSET MANAGEMENT MARKET STUDY ABOUT THE PRI The United Nations-supported Principles for Responsible Investment (PRI) is the world s leading initiative on responsible investment.
More informationCapital treatment for simple, transparent and comparable securitisations
Chris Dalton, Chief Executive Officer Australian Securitisation Forum 3 Spring Street SYDNEY NSW 2000 (t) + 61 2 8243 3906 5 February 2015 Secretariat of the Basel Committee on Banking Supervision Bank
More informationCP19/15: Contractual stays in financial contracts governed by third-country law
Andrew Hoffman and Leanne Ingledew Prudential Regulation Authority 20 Moorgate London EC2R 6DA Cp19_15@bankofengland.co.uk 14 th August 2015 Dear Leanne and Andrew, CP19/15: Contractual stays in financial
More informationFinancial Reporting Council. Proposed Revisions to the UK Corporate Governance Code
Aberdeen Standard ilivesliiielik- Catherine Horton Financial Reporting Council 8th Floor 125 London Wall London EC2Y 5AS 1 George Street Edinburgh EH2 2LL phone: 0131 245 7956 email: mike.everett@aberdeenstandard.com
More informationCode Committee for Financial Advisers. Draft Code of Professional Conduct for Authorised Financial Advisers
Submission to the Code Committee for Financial Advisers on the Draft Code of Professional Conduct for Authorised Financial Advisers 21 July 2010 Contact: Karen Scott-Howman Senior Adviser: Policy/Legal
More informationThe Aon Ireland MasterTrust
Aon Hewitt The Aon Ireland MasterTrust Expert guidance for the Defined Contribution journey Risk. Reinsurance. Human Resources. About Aon Aon plc (NYSE: AON) is a leading global professional services firm
More informationREVIEW OF DISCLOSURE OF INFORMATION REQUIREMENTS APPLYING TO OCCUPATIONAL, PERSONAL AND STAKEHOLDER PENSION SCHEMES RESPONSE TO CONSULTATION
REVIEW OF DISCLOSURE OF INFORMATION REQUIREMENTS APPLYING TO OCCUPATIONAL, PERSONAL AND STAKEHOLDER PENSION SCHEMES RESPONSE TO CONSULTATION The comments set out below are the formal response ( Response
More informationPublic Consultation on Responsible Lending and Borrowing in the EU
date: 28 August 2009 e-mail: paul.broadhead@bsa.org.uk direct line: 020 7520 5917 direct fax: 020 7240 5290 European Commission DG Internal Market Rue de la Loi 200 1049 Brussels Belgium Dear Sir/Madam
More information