Source · Select Committees · Work and Pensions Committee
Seventh Report - Defined benefit pensions with Liability Driven Investments
Work and Pensions Committee
HC 826
Published 23 June 2023
Recommendations
10
Accepted
Para 105
Bring forward plans to bring investment consultants within the FCA regulatory perimeter.
Recommendation
We heard, including from the FCA itself, that in some cases investment consultants were giving standardised advice, rather than thinking through what was best for the individual pension fund. Given the complexity of the decisions trustees are required to make, …
Read more
Government Response Summary
The government plans for DWP to lay draft Occupational Pension Scheme Regulations 2023, accompanied by an impact assessment, which will address the matter of investment consultants and be monitored regularly.
Department for Work and Pensions
View Details →
11
Accepted
Work with the FCA to review effective implementation of LDI fund guidance for trustee monitoring.
Recommendation
To play their part in monitoring LDI, trustees need timely and accurate information from LDI funds and advisers. We welcome the fact that the FCA issued guidance on this in April. TPR should work with the FCA to review whether …
Read more
Government Response Summary
TPR is closely collaborating with the FCA and NCAs to review the effective implementation of LDI guidance issued to managers and pooled funds, and will keep guidance under review for amendments if required.
Department for Work and Pensions
View Details →
12
Accepted
Para 124
Report back on LDI resilience monitoring plans and TPR's digital transformation timeline.
Recommendation
TPR is working to become a more digitally enabled and data-led organisation but has a long way to go to achieve this. We support the Financial Policy Committee’s recommendation that TPR should specify minimum levels of resilience for the LDI …
Read more
Government Response Summary
The government states TPR will use various data sources to monitor LDI resilience and will set out a data and digital strategy by the end of the financial year, building on recent developments like establishing the DDaT Directorate and new recruitments.
Department for Work and Pensions
View Details →
14
Accepted
Report back on plans for analysing LDI data implications with other regulators.
Recommendation
Given the extent of leverage and the concentration of DB investments, more should have been done to follow up on the risks identified in 2018 by the Bank of England. Collecting better data on LDI is part of what is …
Read more
Government Response Summary
The government confirms TPR will collect LDI data through a collaborative framework with FCA and BoE by the end of 2023, and states DWP, HMT, TPR, BoE, and FCA are working together to better manage financial systemic risks.
Department for Work and Pensions
View Details →
15
Accepted
Para 140
Report back on giving TPR a financial stability remit and ensuring its capacity.
Recommendation
When the LDI episode arose, the Bank of England had to intervene to prevent financial instability. The regulatory framework was complex and fragmentary, and not fit for purpose when it came to managing systemic risks. The Financial Policy Committee recommended …
Read more
Government Response Summary
The government accepts the FPC's recommendation for TPR to incorporate financial stability, detailing that TPR is setting up protocols with the BoE, reviewing its risk management approach to include systemic financial risk, and exploring required skills and capabilities with DWP.
Department for Work and Pensions
View Details →
Conclusions (5)
1
Conclusion
Accepted
Para 34
Both accounting standards and pension scheme funding requirements contributed to the development of LDI. The requirement to calculate a present value of liabilities using a market-based discount rate resulted in liability levels being very sensitive to changes in interest rates. LDI was an attempt to manage the resulting volatility in …
Government Response Summary
DWP is working with TPR to understand the LDI episode's impact, with TPR conducting further analysis on scheme assets, liabilities, and funding changes, including LDI strategies. TPR, FCA, and BoE will use enhanced data to monitor sector resilience, and TPR is working to produce a report by the end of 2023.
2
Conclusion
Accepted
Para 41
A second motivation for LDI has been The Pensions Regulator’s approach to regulating scheme funding in line with its statutory objectives to protect member benefits and the Pension Protection Fund. We will return to the question of what is needed for open DB schemes to thrive in our inquiry on …
Government Response Summary
The Pensions Regulator (TPR) will monitor LDI adherence, buffer levels, and operational procedures by collecting data from LDI managers, introducing new scheme return questions, and surveying investment consultants and schemes.
5
Conclusion
Accepted
According to TPR the majority of pension schemes emerged from 2022 with improved funding levels. However, external analysis raises questions as to how confident we can be about these improvements. We are concerned that some schemes had their funding levels negatively affected as a result of the events of September
Government Response Summary
TPR is collaborating with the FCA and NCAs to review the effective implementation of LDI guidance, setting clear expectations for trustees, and keeping guidance under review for potential amendments.
6
Conclusion
Accepted
Para 72
The objective of the latest Financial Policy Committee (FPC) guidance, to protect financial stability is welcome. We look forward to seeing the results of the Bank of England’s planned stress tests, made more pressing by recent rises in gilt yields.
Government Response Summary
TPR will monitor LDI resilience using various data sources and is committed to becoming data-led by developing a Data, Digital and Technology Directorate, approving new digital services, and publishing a data and digital strategy by year-end.
8
Conclusion
Accepted
Para 91
TPR encouraged pension scheme trustees to use leveraged LDI, which involves complex financial instruments. It continued to rely on them as the first line of defence to manage the risks, despite its longstanding concerns about governance standards in some schemes, particularly smaller ones which do not benefit from economies of …
Government Response Summary
The government states TPR will be collecting LDI data via a collaborative framework with the FCA and BoE, which will be in place by the end of 2023, and refers to recommendation 9 for further details on systemic risk management.