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 responds to TPR consultation on CMA’s recommendation to produce guidance to trustees on engaging with investment consultants and fiduciary managers

ACA expresses unease in consultation response to TPR on CMA’s recommendation to produce guidance to trustees on engaging with investment consultants and fiduciary managers more »»

ACA expresses unease in consultation response to TPR on CMA’s recommendation to produce guidance to trustees on engaging with investment consultants and fiduciary managers

29th August 2019 David Robertson

Trustee oversight of investment consultants and fiduciary managers regs

The ACA has responded to the Department for Work and Pensions consultation seeking views on the draft Occupational Pension Schemes (Governance and Registration) (Amendment) Regulations 2019. more »»

The ACA has responded to the Department for Work and Pensions consultation seeking views on the draft Occupational Pension Schemes (Governance and Registration) (Amendment) Regulations 2019.

30th July 2019 David Robertson

ACA response to FCA discussion paper on Intergenerational Differences

We believe that addressing the intergenerational challenges will require significant additional flexibility in the savings products that are available. more »»

We believe that addressing the intergenerational challenges will require significant additional flexibility in the savings products that are available.

11th June 201912th June 2019 David Robertson

ACA letter to Business Department concerning future of actuarial regulation

ACA letter on proportionate actuarial regulation post-FRC more »»

ACA letter on proportionate actuarial regulation post-FRC

30th April 201916th May 2019 David Robertson

Response to FCA paper on effective stewardship

Response notes any additional governance requirements are clearly linked to positive outcomes compared there is academic research that appears to show the benefits of good Stewardship and it needs to be clear how this can be assessed by asset owners more »»

3rd April 2019 David Robertson

ACA responds to Local Government Pension Scheme: Fair Deal – Strengthening pension protection

ACA welcomes the Government’s proposals to simplify the regime for providing continuity of pension rights when a service or function is outsourced from an LGPS employer, but with provisos more »»

ACA welcomes the Government’s proposals to simplify the regime for providing continuity of pension rights when a service or function is outsourced from an LGPS employer, but with provisos

1st April 20192nd April 2019 David Robertson

ACA responds to DC Investment Innovation and Consolidation consultation

We welcome the drive towards consolidating smaller occupational DC schemes and note schemes can already invest in illiquid assets and may not invest more in these assets more »»

We welcome the drive towards consolidating smaller occupational DC schemes and note schemes can already invest in illiquid assets and may not invest more in these assets

29th March 20191st April 2019 David Robertson

ACA response to FRS 102 amendment

Responding to the FRC’s consultation, the ACA gives a general welcome to the amendment whilst questioning the proposal in para 28.11C on disproportionate cost grounds more »»

Responding to the FRC’s consultation, the ACA gives a general welcome to the amendment whilst questioning the proposal in para 28.11C on disproportionate cost grounds

28th February 20191st March 2019 David Robertson

Patient capital and authorised funds

Response to FCA consultation notes that although we have not carried out any market research we believe there is anecdotal evidence of a demand for funds which can invest in patient capital. In particular this would make sense for younger Read More ... more »»

1st February 20191st February 2019 David Robertson

ACA responds to DB consolidation consultation

We welcome the Government’s proposals to support the development of the superfund sector, but we believe that a stepping stone to achieving successful consolidation is through simplifying the manifestly complex DB environment, with significantly lower ongoing costs supporting improved benefit security Read More ... more »»