From Government Departments, to regulatory bodies, to industry groups… everybody has been tinkling on the ivories, and creating a cacophony of sound on the subject of Defined Contribution governance in workplace pension plans. This has been lacking in theme and melody, until last month when the DWP stepped forward to air its latest composition – an almost complete, long awaited, yet technically challenging piano concerto: “DC Governance – in B Sharp”.
The waiting audience is divided into two. Those in the trust-based half of the arena listen with a degree of contentment, comfortable in the knowledge that the tones they are hearing are relatively familiar. Yet there is an unexpected interlude in which it becomes apparent that there are new legal duties arising which will add to their governance burdens.
On the contract-based side of the arena there are issues with the acoustics. The audience shuffles uncomfortably. Surely what they are hearing represents wholesale change? This builds to a crescendo – charge capping, independent governance committees, fiduciary duties, new standards… This may have been the conclusion that some were anticipating – but all at once, and largely from 2015?
The final chords sound. The pianist rises and takes a bow. Most of the audience applaud, but some remain in their seats, pondering the challenges ahead.
What do you think?
If you are a trustee, an employer or a pension provider, what is your reaction to the DC Governance proposals? There is undoubtedly a lot to consider in the coming year. We set out our thoughts in our recent communication.