The statement warns that a degree of caution must
be used when liabilities are estimated, which “should not
be compromised to make a recovery plan appear affordable”,
and that schemes must be “treated fairly in relation to other
creditors and equity providers and not disadvantaged”.
Chair of TPR, David Norgrove, said: “Where
sufficient prudence has been built into funding targets, a sensible
consideration about the length of the recovery plan and schedule
of annual payments can occur. That’s the balance we need to
strike to best secure member benefits for the long-term and to enable
employers to play their part in the economic recovery.”
The statement, Scheme funding and employer covenant-prudence,
affordability, applying flexibility through the economic cycle,
says TPR has analysed the current regulatory framework and approach
to scheme funding and has found it to be “adequately flexible”
to manage these conditions. Technical provisions are the scheme-specific
funding standard, which pension schemes must target and the regulator’s
requirement is that they are set prudently.
The statement also addresses FRS17 issues, acknowledging
that as it stands, the accounting rules are unlikely to represent
an adequate level of caution. Risk margins are also looked at in
terms of the assumptions used for setting technical provisions,
which must take note of the extent to which an employer covenant
can support them.
The industry has responded to the statement with
mixed attitudes, with Watson Wyatt’s Rash Bhabra, head of
corporate consulting, questioning why these statements continue
to be issued. “Assessing the employer’s ability to stand
behind the scheme is an increasingly important part of a trustee’s
job, so the Regulator is right to draw attention to that. Besides
that, you have to wonder why similar statements keep being re-issued
every few months. Is it mostly employers or trustees who the Regulator
thinks are not heeding its message?”
Neil Carberry, head of pensions policy at the Confederation
of British Industry (CBI), added: “This emphasises the flexible
approach the Regulator is taking to balancing affordability for
employers with funding for pension schemes. It is vital that this
message reaches trustees – one way to do this would be a temporary
extension of the Regulator’s recovery plan trigger from ten
to 15 years.”