Consultation Responses

Please find below links to Association responses to consultations conducted by Government Departments and other bodies. Providing input and comment on public policy and topical issues is one of the principal roles of the Association. These responses to a wide range of government departments, regulatory and other bodies are archived below in date order:

ACA expresses support in OTS response for ‘sensible’ initiatives to simplify pension tax system

In our response to the Office of Tax Simplification’s call for evidence on its third-party data reporting review, we expressed support for any ‘sensible’ initiatives to simplify the processes of the pensions tax system and make it easier for individuals Read More ... more »»

10th March 2021 David Robertson

ACA response to Taking action on climate risk: improving governance and reporting by occupational pension schemes,

In our response to the DWP consultation we welcomed the DWP’s response to practical issues identified in its previous paper but stress the huge changes for trustees addressing this issue and the risks involved with ‘spurious data gathering and calculations’ Read More ... more »»

27th January 2021 David Robertson

ACA response to General Levy consultation

In our view, there should be an opportunity for industry scrutiny of whether the regulatory activities paid for by the general levy represent adequate value for money. We would argue that levy payers deserve some role in this process, to Read More ... more »»

7th January 2021 David Robertson

ACA responds to APS P1 review

We are in favour of the revised version and welcome the streamlining and clarity. We have a few areas where we think the drafting as stands might result in unintended consequences and these are set out in our response, see more »»

17th December 2020 David Robertson

ACA responds to TPR strategy paper

We broadly agree with the strategic priorities set out in the document. Whilst we agree that TPR should continue to increase its oversight of DC pension savings, we envisage that DB pensions will continue to require significant regulatory oversight for Read More ... more »»

23rd November 2020 David Robertson

ACA responds to 2021-2 PPF Levy Consultation

Find below a copy of the ACA’s response to the Levy consultaton… more »»

Find below a copy of the ACA’s response to the Levy consultaton…

30th October 2020 David Robertson

Improving member outcomes in DC schemes

ACA says the new requirement to assess value relative to larger schemes (where benefits could realistically be transferred) will provide a clear-sighted framework for trustee boards. However, at present, sourcing the information needed for the comparisons in a cost effective Read More ... more »»

29th October 2020 David Robertson

ACA response to Mortality Projections Committee – Working Paper 137

Our main comment on the consultation is that it would be useful if the CMI were to also give some additional functionality or scenario information, alongside the Model so that it covers ‘plausible mortality outcomes’ … more »»

21st October 2020 David Robertson

AE: alternative quality requirements for defined benefit and hybrid schemes

Our thoughts relate to the cost of accruals test only (your “test two”). We support its continuation and have some suggestions for reform. more »»

Our thoughts relate to the cost of accruals test only (your “test two”). We support its continuation and have some suggestions for reform.

13th October 202014th October 2020 David Robertson

Response to pension tax relief administration call for evidence

We think that any approach that is used to resolve the anomalies between net pay and RAS, must be consistent with the government’s anticipated long-term direction of travel on pensions tax. more »»

We think that any approach that is used to resolve the anomalies between net pay and RAS, must be consistent with the government’s anticipated long-term direction of travel on pensions tax.