Updates made with regards to compliance of the TPR Code of Practice 14.
Minutes:
The Pension Fund Manager advised that the document had been updated in line with the comments at the previous meeting.
The Board reviewed the following sections and noted the following [numbers
refer to the Compliance indicator]:
Governing your Scheme [38 – 60]
39-41& 48 – the Training Needs Analysis would be sent to all Board members to complete, so that the training needs for individuals and the Board as a whole could be developed for the next 12 months. Training sessions would be built into meetings or extra meetings would be added.
42 – the Pension Fund Manager advised that the Pension Board knowledge /document library would be developed over the next 6 /12 months.
51 - it was noted that TPR considered it was an important role and expectation of Board members to identify and where relevant challenge any failure to comply with regulations and legislation etc.
56 – the Chair confirmed that he had met virtually with the two new Board members soon after their appointments to provide initial training on the role of the Pensions Board and the responsibilities of Board members.
Conflicts of interest and representation [62 – 91]
76 – the Pension Fund Manager advised a review of the conflicts policy and procedures and all other policies was scheduled for early 2022. The revised policy would be brought to the Board for consideration.
80 – the Board was assured that the process for appointing the two new Board members was duly followed.
Administration [124 – 146]
124 – the Pension Fund Manager advised that the annual data quality test had been completed in October 2021. The common data scored 98% and scheme specific data scored 92% against TPR levels. The Board noted that recording of the postcode in the wrong line had brought the scheme specific level down. The Pension Fund Manager advised that as part of the data improvement plan checking data could now be undertaken on a more regular basis. The Board noted that a test would be completed again after the year end and before the next Annual Benefits Statement were distributed.
128 – the Employer representative advised that the annual letter issued to employers regarding submitting the appropriate information was good practice and was a secondary check to the employers monthly checks.
131 – the Pension Fund Manager advised that the procedures to trace the flow of funds into and out of the scheme and reconcile flows were being reviewed.
The Chair provided feedback from a webinar on the issues raised in response to TPR proposal to combine 10 codes of practice into one code. For LGPS the following themes were highlighted in the consultation:
· clarification on the applicability of the code to LGPS
· guidance from TPR especially on proportionality
· the need to retain historic versions
· legislative boundaries and the need for a clearer definition of governing bodies in respect of LGPS due to their complexity
· the main focus will remain on the scheme manager
· looking at whether it is the role of Pension Boards to formally advise the scheme manager
· designed to be a more flexible code
· the TPR toolkit will be updated
· TPR will not do anything until statutory guidance on pooling assets is published
TPR are not expecting the single code to be in place until late summer or autumn 2022.
Supporting documents: