St Pauls
Authorisation and Supervision of Master Trusts
Consultation on draft Code of Practice
Andrew Penketh
29/03/2018
St Pauls

Consultation on draft Code of Practice

Following the publication of the government’s response to its consultation on the draft regulations about the new Master Trust Authorisation and Supervision regime, The Pensions Regulator is now consulting on its related draft Code of Practice.

The Pensions Regulator welcomes comments by 8 May 2018.

Use of assurance frameworks in gathering evidence to support Master Trust system and process requirements

In its consultation document and response, The Pensions Regulator says “Master Trusts have to confirm that their systems can provide a minimum functional capability, and we may require them to demonstrate this to us. They will also be expected to demonstrate that they have effective processes for running and governing the scheme and its operations. Where a Master Trust is administered by third parties, evidence will need to be obtained from a third party to show the authorisation criteria can be satisfied. We will not mandate that a Master Trust should obtain an assurance report, although we will be publishing guidance as to how various assurance standards might support an authorisation application.”

Andrew Penketh, Head of Pension Funds at Crowe UK says

“The draft Code of Practice sets out The Pensions Regulator’s interpretation of how Master Trust schemes might satisfy the system and process requirements in Schedule 4 of the draft regulations.

“There is already a reasonable amount of overlap between the control objectives in the ICAEW Master Trust Assurance Framework (MAF) and, the system and process requirements in the draft regulations and draft Code of Practice. The Trustees of Master Trust schemes who have adopted MAF may have already collected a lot of the evidence about systems and processes which will need to be provided to the Regulator.

“The additional guidance due from The Pensions Regulator is expected to set this out in more detail. In the meantime, we can help Master Trust schemes undertake a gap analysis between the evidence gathered for ICAEW Master Trust Assurance and, the matters set out in the draft Code of Practice in preparation for authorisation."

Contact us

Andrew Penketh
Andrew Penketh
Partner, Head of Pension Funds
London