Aries monitors every development in new and proposed legislation and official guidance.   Clients are kept up to date via the website, email alerts and tweets.   Aries serves as a one-stop source of intelligence on everything that is going on and coming up.   Aries doesn't miss anything of significance.

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Via Pension Schemes Newsletter 118, HMRC has acknowledged that the developing situation created by COVID-19 is creating problems for pension scheme administrators. For at least three months, but to be kept under review, HMRC is making temporary changes to pension processes:

  • Rent and loan payment holidays: usually, to make sure there's a commercial basis for payment holiday on loans due from

connected parties and on commercial property rents, HMRC would expect the scheme administrator to obtain an independent valuation. Given the present situation, HMRC are content that any arm's length commercial decisions relating to registered pension schemes, including rent holidays, will not give rise to an unauthorised payment charge and can be agreed without independent valuations taking place.
  • APSS105 relief at source repayment claims: HMRC understands it may be

  • difficult to obtain wet signatures on interim repayment claims from authorised signatories. "For now", HMRC will accept scanned interim repayment claims: emailed by the authorised signatory (can be accepted without a signature); or signed and emailed by someone else, providing there is a separate email directly from the authorised signatory authorising them to submit the claim. On a temporary basis HMRC will accept submissions . . .

    27 Mar 2020  

    The cross-industry GMP Equalisation Working Group (GMPEWG), has issued its latest guidance on "when to rectify" Guaranteed Minimum Pension (GMP) benefits.

    This latest addition to the body of GMP guidance produced by PASA, relates to making corrections as a result of GMP reconciliation, known as GMP rectification and recommends four steps for trustees to undertake to ensure they make the right decision for their scheme:

    1. Understand the data

    Step 1a here is GMP reconciliation: a process that should be fully or largely complete prior to rectification. It ensures that schemes have the right GMP information for progression to the next stage of the exercise.

    Trustees should ask their administrator to: confirm the current status of the GMP reconciliation; discuss the estimated timescales; provide details of the

    members whose GMPs have not yet been reconciled; and detail any decisions which need to be made by the trustees (such as stalemate cases).

    Step 1b requires an understanding of the populations in scope for GMP rectification and equalisation projects. The guidance provides a diagram illustrating the different populations needing to be considered and where these might overlap. . . .

    25 Mar 2020  

    The Pension Protection Fund (PPF) has already begun to implement the Hampshire ruling, making increase payments to pensioners whose benefits fell below 50% of the value of their accrued benefits because of a combination of the compensation cap and other factors.

    Having already made these payments to all pensioners affected by the cap alone and who've sent the necessary information, the PPF is aiming to

    increase payments to the majority of pensioners in this group by the end of September 2020.

    The 'other factors' mentioned might include differences in the benefit structure or significantly higher annual increases under the former scheme, compared to the PPF's.

    The PPF is also continuing to gather data for the members who were not capped, but are affected because of other factors.

    It thinks it has enough information to begin assessing and calculating increases for these members, but it will take some time before it can process all the necessary increases.

    The PPF hopes to increase payments for 90% of everyone entitled to an increase by the end of March 2021. However, it won't yet pay any arrears (including tax free lump sums) because . . .

    25 Mar 2020  

    Having previously stated it was engaging with the pensions industry to understand the pressures faced from COVID-19, the Pensions Regulator (TPR) has already updated its guidance.

    The latest guidance covers:

    1. Expectations of Trustees

    Trustees must be alive to risks that would have significant consequences for the scheme and members. They should assess whether the Business Continuity

    Plan is still adequate. Administrators or service providers should be contacted to discover what contingency is in place to mitigate the impact of increases in work volumes or unavailable staff.

    Trustees should make it clear which activities should be prioritised in the event of under-resourcing, such as pensioner payments, retirement processing and bereavement payments.

    For trustees of defined benefit (DB)

    schemes, TPR has noted that some sponsoring employers have already asked to reduce or suspend deficit repair contributions (DRCs). TPR provides a bespoke page on corporate distress. TPR notes heightened need for trustees to understand the corporate health of DB sponsoring employers and suggests COVID-19 related questions to ask.

    TPR recognises that it may . . .

    23 Mar 2020  

    With precious little disruption being wrought by COVID-19 at Aries Insight, we realise we're some of the lucky ones. With certainty thin on the ground, the Government has announced measures to support the economy and various bodies in the pensions industry have been moved to make statements.

    The Pensions Regulator (TPR) states it is engaging with the pensions industry to understand the pressure it faces from COVID-19 and to help minimise any

    impact on savers.

    Trustees are expected to have in place appropriate monitoring and contingency planning, including a business continuity plan (BCP) setting out what actions would be taken if certain events take place that would impact the running of their scheme. Trustees should also understand their service providers' business continuity arrangements.

    Trustees must understand what

    contingency is in place to mitigate any staffing under-resource and establish which scheme activities would be prioritised. TPR is "engaging with key administrators to understand their current preparedness".

    TPR notes its Integrated Risk Management guidance is designed to assist schemes in these regards.

    The Pensions Protection Fund . . .

    19 Mar 2020