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My PFS - Technical news - 10/05/16

Personal Finance Society news update from 27 April to 10 May 2016 on taxation, retirement planning and investments.

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Taxation and Trusts

Investment planning

Pensions

TAXATION AND TRUSTS

CGT Deferral Relief
(AF1, AF2, RO3, JO3)

The change in CGT rates for 2016/17 has created an anomaly for EIS investors.

One of the features of the Enterprise Investment Scheme (EIS) which is not mirrored by Venture Capital Trusts (VCTs) is CGT deferral relief. This relief allows an EIS investor to defer the CGT liability on gains realised up to three years before the EIS investment is made or one year afterwards. Thus, in 2016/17, it is possible to make a claim in respect of gains realised as far back as 2013/14, provided there is no more than a 36-month gap between realisation and the EIS investment.

The relief is a deferral, not outright, so when the EIS investment is itself realised the amount of the deferred gain becomes liable to tax (gains under the EIS are otherwise CGT-free after three years of ownership). The tax payable on the formerly deferred gain is at the rate applying when the EIS investment is realised.

With the 8% cut in CGT rates, the result is that gains deferred from an earlier tax year are likely to suffer less tax when finally realised - typically 20% rather than 28%. 

This type of anomaly has arisen before and, in isolation, is no reason for EIS investment. However, for someone choosing between EIS and VCT, it is a point to be borne in mind. 

DOTAS - Revised draft IHT hallmark published for further consultation
(AF1, RO3)

HMRC is seeking views on a revised draft of the IHT hallmark regulations having considered responses to an earlier consultation voicing concerns that the original proposals were too widely drafted. The new proposal focuses on arrangements that are contrived or abnormal, or that contain contrived or abnormal steps.

The IHT hallmark was introduced with effect from 6 April 2011 and has historically applied only to arrangements that seek to avoid IHT charges during a person's lifetime. In July 2015 draft regulations expanding the existing hallmark to ensure that all types of IHT avoidance would have to be disclosed, and removing the existing "grandfathering" provisions, were published for consultation. While the revised draft regulations specifically exempted certain insurance-based schemes, many who responded to the consultation expressed concerns that the hallmark was so widely drafted it could be construed to catch a wide range of non-abusive arrangements, including loan trust arrangements where there was no initial gift, as well as bare trust versions of loan trusts and discounted gift trusts on the basis that there was no 'settlement'.

In the response document to the technical consultation published in July, the Government committed to revising the hallmark to take account of these concerns and has duly published for further consultation revised draft hallmark regulations, which now focus on arrangements that are contrived or abnormal, or that contain contrived or abnormal steps.

The conditions of the revised hallmark, both of which need to be met for an arrangement to be disclosable, are that:

  • The main purposes, or one of the main purposes, of the arrangements is to enable a person to obtain a tax advantage; and
  • The arrangements are contrived or abnormal or involve one or more contrived or abnormal steps without which a tax advantage could not be obtained

The latest consultation document provides examples of ordinary tax planning arrangements which may result in a tax advantage yet are not, in the eyes of the Government, caught by the revised hallmark because they are not contrived or abnormal (and so fail to meet the second condition). These include:

  • Straightforward, outright gifts;
  • Lifetime transfers into flexible or discretionary trusts;
  • Investment into assets that qualify for relief from inheritance tax; and
  • Arrangements that are within a statutory exemption - for example paying full consideration for the continued use of land or chattels that have been given away

Certain other insurance-based arrangements, that could potentially be caught, are specifically excepted under the revised draft regulations. These are:

  • Loan trusts - whether discretionary or bare and whether or not there is an initial gift;
  • Discounted gift schemes - again whether discretionary or bare and whether established in conjunction with a life insurance or a capital redemption policy;
  • Flexible reversionary trusts - including arrangements where the retained rights can be varied or defeated by the trustees; and
  • Split or retained interest trusts

The consultation on the revised draft hallmark runs until 13 July 2016.

The revised draft hallmark regulations address many of the concerns voiced in response to the earlier consultation and will provide reassurance that the use of legitimate, mainstream tax-planning tools, such as loan trusts and discounted gift trusts, should not be caught within DOTAS regardless of how they are structured.

This is a sensible approach from the Government as there is a clear difference between these arrangements and the avoidance schemes which are under threat from HMRC's efforts to strengthen the tax-avoidance disclosure regime.

Report puts the average price of a basic will at £168
(AF1, RO3, JO2)

Research commissioned by the Legal Services Board published recently has revealed the average prices that consumers pay for the most commonly used legal services including Will-writing, probate applications, estate administration and powers of attorney.

The survey, which comprised 1,506 telephone interviews with a range of legal service providers, found the following average prices:

  • Standard Will - £168
  • Complex Will - £206
  • Lasting power of attorney (LPA) - £414
  • Grant of probate - £829
  • Estate administration - £1,926

Unsurprisingly, unregulated Will-writing firms charged significantly less for individual Wills and LPAs than solicitors (average of £136 for a standard individual Will and £263 for a LPA as compared to the higher averages of £176 and £440 respectively charged by solicitors). Further, the majority of Will-writing firms did not offer grant of probate or estate administration services.

It was also apparent that while providers are still more likely to charge either an hourly rate or estimate the total cost for more complex services such as probate and estate administration, fixed fees now predominate for less complex matters such as individual Wills and LPAs.

This research shows that there is often a significant variation in the price that consumers pay for the same service (from £90 to £200 for a standard Will), so it pays to shop around. The research also reveals a lack of price transparency, with the twenty per cent or so of firms who display their prices on their websites generally being cheaper than those who do not. More positively, the research suggests the wide availability of fixed fees, even for some complex services.

The SC Register - The impact on trustees
(AF1, RO3, JO2)

The ownership of private limited companies is now under greater scrutiny and this extends to situations where trustees are the owners. Here we set out an overview of the new PSC rules and how they might affect trustees who have sizeable shareholdings in companies.  PSC stands for People with Significant Control. 

The Small Business, Enterprise and Employment Act 2015 (the Act) introduces Part 21A of the Companies Act 2006.  This means that, from 6 April 2016, limited companies (and limited liability partnerships) must maintain a PSC register.  A PSC register is basically a register of people who have significant control over the company.

This change is designed to reveal the identities of individuals who have control over private UK companies.  It is only concerned with situations where the owner has a certain minimum level of control (see below).  Also, in general, the register will only give details of those people who have immediate control and not ultimate control.

The register must also record details of people who exercise control of a company through a trust.  In this context, if the trustees themselves have significant influence and control in their capacity as trustees, their names will need to be on the register.  And in these cases if an individual, in turn, exercises significant influence and control over the trust and the trustees, their names will also have to be included on the register.

It should also be noted that the register is open to public inspection on the payment of a fee. Failure to maintain the register is a criminal offence which can be punished with a fine or even a prison sentence.

Persons with significant influence and control

The key point underpinning these rules is that to be included on the register a person must exercise significant influence and control over the company (Schedule 1A to the Companies Act 2006).  For this to be the case, the individual must:

  • hold, directly or indirectly, more than 25% of the shares in the company or more than 25% of the voting rights in the company; or
  • hold the right, directly or indirectly, to appoint or remove a majority of the board of directors of the company; or
  • have the right to exercise significant influence or control over the company.

In the case of a trust, the trustees of a trust will be PSCs and will need to be included on the register if the trust meets any of the "individual tests" above.

The term 'a significant influence or control' has been clarified by statutory guidance which was laid before Parliament on 6 April and is due to come into force in May 2016.

  • Relevant legal entity (RLE)

Only individuals can be PSCs.  The rules are extended to other legal vehicles by the introduction of an RLE.

An RLE is a legal entity that:-

  • if it were an individual would be a PSC and
  • is subject to its own disclosure requirements.

An RLE is subject to its own disclosure requirements if it is subject to Part 2A of the Companies Act 2006, it is a traded company or if it is a description specified in the regulations.

The register

The company must maintain a register of PSCs that can be inspected.  It must supply a copy in exchange for a fee.

Obtaining the information

The company is under a duty to take reasonable steps to find out if a person is a registerable person or an RLE in relation to the company.

Reasonable steps are those a reasonable person would take if he or she had the same information as the company - it will include reviewing available existing information and documentation (e.g. articles of association, shareholders' agreements and voting patterns). If there are gaps in the information, the company must send a notice to any person it has reasonable cause to believe should be recorded on its PSC register. It is a criminal offence not to comply with this requirement. The company can also serve a notice on anyone it knows, or has reasonable cause to believe, can identify a registerable PSC or RLE, or who knows the identity of someone else likely to have that information, requiring them to respond within a month.

The particulars that a company must keep of a registerable PSC include name, address, date of birth and period and nature of control.  In certain circumstances an exemption may be given which avoids the need to include the information on the register (for example, a person can demonstrate that disclosure would put them at serious risk of violence or intimidation due to the activities of the company). 

Trusts

Where a trust meets one of the conditions outlined above (or would do so if it were an individual), the rules need to be considered at two levels:

(i) The trustees themselves will need to be included on the register if the trust would have needed to have been, had it been an individual.  So, if the trust holds more than 25% of the shares in the company, the trustees need to register as PSCs.

(ii) Where the trust controls more than 25% of the shares in a company and there is somebody who has significant influence and control over the trust, that person or persons will need to be included on the register.  This may include the settlor or beneficiaries. 

With regard to (i), the trustees may need to register because the trust meets one or more of the control rules - see above or, if the trust is a trust corporation, it may be an RLE.

As regards (ii) the trustees may need to maintain accurate records where an individual has significant influence or control over the trust so that they can inform that person's details to the company in which they hold more than 25% of the shares.

Significant influence or control

Draft statutory guidance exists on the meaning of 'significant influence or control', published by the Department for Business Innovation & Skills (BIS) in January 2016.  The guidance gives examples of rights or behaviour that would be regarded as giving rise to influence or control.

In relation to trusts, these rights or behaviours include:-

  • the right, in general, to appoint or remove any of the trustees
  • the right to direct the distribution of trust assets
  • the right to direct investment decisions of the trustees
  • the right to amend or revoke the trust

The guidance also suggests that persons who are regularly involved in the running of the trust are likely to exercise significant influence or control over a trust.  For example, a person issues instructions as to the activities of the trust which are generally followed. Typically, a settlor or protector who retains common administrative powers (eg. to appoint and remove trustees) will be regarded as having influence or control.  A settlor with these powers, who wishes to stay off the register, may wish to give up these powers.

Registration not required

Registration is not required if an individual holds an interest in the company keeping the register because of share ownership in one or more RLEs.  In that case, the RLE will be registered and the PSC will not (unless the RLE also keeps a register). Also, interests held as a nominee are not registerable. Shares or rights held by a nominee are treated as if they are held by the person for whom the nominee is acting.

Issuing notices

A company that is required to keep a PSC register must take reasonable steps to find out whether there are any PSCs or RLEs in relation to the company and, if there are, obtain the details for the PSC register.  The company can serve a notice to obtain this information.

A trustee who is served with a notice requiring them to identify PSCs and RLEs will need to think carefully about how to respond. The starting point is to have in mind the fact that failure to respond, or failure to respond accurately, is a criminal offence. In the case of a corporate trustee, the trustee and its officers commit the offence.

Trustees will need to consider carefully whether there are any PSCs or RLEs of whom they are aware. They will need to be particularly careful in assessing whether there are any individuals who have significant influence or control over the affairs of the trust. It may be that with sufficiently robust trust administration, trustees will be able to put hand on heart and say that there are no PSCs or RLES. However, the guidance has been widely drawn and so trustees will need to act cautiously.

Where complicated beneficial interests exist (ie. there are a series of trusts) legal advice should be taken.

Where a person has failed to comply with a PSC notice, the company can serve that person with a warning notice followed by a restriction notice.  The effect of the restriction notice is to freeze that person's interest. This means that any transfer of the shares will be void, it will not be possible to vote and no payment can be made in respect of the interaction including a dividend.

Responding to notices

The failure to respond to a notice on PSCs and RLEs is a criminal offence.  Trustees will therefore need to be careful - particularly in determining whether an individual has significant influence or control over the affairs of the trust.

The introduction of the PSC register is a fundamental change in the disclosure of control of companies. Where trustees hold shares in companies that are affected, they will need to be properly prepared to deal with the new complex regulatory framework.  Trustees will need to carefully balance the need for confidentiality and the obligation to disclose information either under the Act or in response to a notice.

In this respect, trustees may face a dilemma. On the one hand, they owe fiduciary obligations to keep the trust confidential and, yet, the PSC Register will be available for public inspection. On the other hand, failure to provide information on receipt of a notice from the company is a criminal offence which, at worst, carries a two year prison sentence or a fine.

Trustees who qualify as PSCs are also under a proactive obligation to provide updated PSC information to the company as and when necessary.

Affected trustees should start thinking about how they will respond to PSC notices now, as once a notice is received trustees must respond within a month.

Intestacy following the death of a minor child
(AF1, RO3, JO2)

The current rules, under which both natural parents benefit following the death of a minor child, seem unfair to single parents and there have been calls for new rules to be introduced

To be able to make a Will in England and Wales and in Northern Ireland (*) a person must be over 18 years old (with the exception of members of HM Forces in active service where the age limit is 16) and have the capacity to do so. If the individual is over 18 but lacks capacity it is possible to apply to the Court of Protection for a statutory Will. However, when a person is under age 18, that option is not available.

When a child dies before reaching age 18 their estate falls to be distributed under the rules of intestacy. In England and Wales this means that both the natural parents are equally entitled. In most cases the estate of the child is not likely to be considerable but a recently highlighted problem is illustrated by the case of a disabled child who has become entitled to compensation, which is frequently substantial. In a single parent  family the chances are  that the single mother (or, less likely, the single father) would have looked after  her disabled child for many years, successfully pursuing a claim for compensation and dedicating her life to that child's welfare, frequently without any help from the child's other parent. 

In the event of the child's death each parent is entitled under the law to 50% of the child's estate after inheritance tax and liabilities have been paid.  This could represent a very significant sum and it is this result that is being called into question as unfair and unreasonable. Under the current rules there is no solution to this problem. It has been suggested that the problem could be avoided if the powers of the Court of Protection were extended to allow the making of statutory Wills for a child under age 18.  The Court is probably ideally placed to consider what should be the best outcome in these circumstances. 

The Law Commission is considering changes in this area of the law so hopefully they will address this issue as well. Some of the difficulties outlined above may also be possible to avoid by using an appropriate trust to hold any compensation funds. Specialist advice should always be sought in such circumstances.

(*) In Scotland the age limit is 12.

Tax revenue: An increasing reliance on the wealthy
(AF1, AF2, RO3, JO3)

The Institute for Fiscal Studies (IFS) has been drilling into the Office for Budget Responsibility (OBR) projections to see how the pattern of tax is changing. It has just published a briefing note which makes some interesting - and perhaps surprising - points on the actual and projected shifts in the tax landscape between 2007/08 (when the financial crisis first hit) and 2020/21 (the end of the current parliament):

  • By 2020/21, total tax receipts will be 37.2% of GDP, just 0.3% lower than in 2007/08. That is quite a recovery, given that real government receipts fell by 4.4% in 2008/09 and another 5.5% in the following year, ending up at 35.8% of GDP.
  • The recovery in revenues is not across the board: there has been a change in composition from the pre-crisis era.
  • Proportionately more VAT will be raised - in part due to the rise in the rate to 20% in 2012 - but other indirect taxes will be less significant. This is mainly down to the freeze on fuel duties since 2011.
  • Between 2007/08 and 2015/16, the proportion of the adult population who pay income tax dropped from 65.7% to 56.2%, driven both by the doubling of the personal allowance over that period and by poor earnings growth.  At the same time the share of total income tax paid by the top 1% of taxpayers has risen from 24.4% to 27.5%. This reflects the introduction of the additional rate and other measures such as the phasing out of the personal allowance, pension tax reforms and non-indexation of the higher rate threshold.
  • To put that 27.5% in perspective, the corresponding figure in 1978/79 was 11%. The change has been a two stage affair: up to 2007 it was driven by rising income inequality, while since then it has been due to government tax policy.
  • The share of total revenue represented by corporation tax and associated taxes, such as the bank levy, will have fallen by about a third between 2007/08 and 2020/21, whereas the share of most other taxes will have remained little changed. Corporate taxes are currently about 7% of total revenues, against 45% for income tax and NICs and 28% for VAT. The major reason for the decline is the drop in corporation tax rates from 28% in 2008 to 15% in 2020, but falling profits from the finance sector, notably banks, are also to blame.

The IFS's conclusion states that 'A source of concern is the extent to which policy changes are being made in an ad hoc fashion with insufficient attention paid to tax design. Such 'ad hocery' ranges from continued unfulfilled promises to raise fuel duty in line with inflation, to the introduction of the diverted profits tax, ever-shifting taxes on banks and constant fiddling with more and more smaller taxes. This lack of apparent and communicated strategy matters and is reflected in an increasingly complex tax system.' It is hard to disagree.

INVESTMENT PLANNING

UK equity income sector review
(AF4, RO2, CF2, FA7)

In the last bulletin we commented on slowing dividend growth and the difficulties facing investment managers running funds in the UK Equity Income sector. We noted that a quick look at the Trustnet tables revealed that only about 60% of funds in the sector currently met the 110% of FTSE All Share yield target.

It has now emerged that the Investment Association (IA) has just launched a consultation on the sector definition. Currently, the full definition is as follows:

"Funds which invest at least 80% in UK equities and which intend to achieve a historic yield on the distributable income in excess of 110% of the FTSE All Share yield at the fund's year end.

Specific sector notes:

1. To ensure compliance with the sector criteria, funds should supply data for monitoring to enable the calculation of historic yield based on The Investment Association guidelines set out in "Authorised Funds: Yield Calculation and Disclosure Guidelines - 2012".

2. Funds are required to submit yield data at the fund's year end to the sector team at The Investment Association, and at the mid-year when notified by The Investment Association.

3. To ensure compliance with the intended 110% yield, funds in the sector will be tested over 3 year rolling periods by taking a simple average of the yield figure achieved for each fund at its year end. Funds that fail to meet the 110% average yield for each 3 year rolling period will be removed from the sector. (As an illustration, this would require a fund that delivered 90% in the first year and 100% in the second year to deliver a yield of 140% in the third year, if it were to be allowed to remain in the sector.)

4. Annually, at the fund's year-end, each fund in the sector must achieve a yield of not less than 90% of the FTSE All Share yield. Funds that fail to do so will be removed from the sector.

5. The Investment Association will measure yield to one decimal place.

6. The Investment Association will consider adjusting the yield parameters of the sector up or down to account for extraordinary market factors when a request is made by funds in the sector representing either 50% by number or 80% by value.

7. To assist users of the sectors and aid comparison, The Investment Association will publish the annual yield achieved by each fund in the sector."

That IA definition has been forcing funds, such as Invesco Perpetual High Income, Schroder Income and JP Morgan Strategic Equity Income, out of the sector and into the great dumping ground that is UK All Companies. 17 funds have left the sector since 2013 and as a result £19bn that was once in the UK Equity Income sector resides in UK All Companies. More is to follow: the £1.2bn Rathbone Income Fund will depart on 1 May and the £8.9bn Woodford Equity Income Fund is under threat of exit.

The IMA consultation is reported to have three main proposals:

1. Do nothing. This will mean the sector continues to shrink.

2. Change the yield basis to over 100% of FTSE All Share. The 90% annual criterion (see 4 in the sector definition above) would remain. Moving from 110% to 100% means the yield threshold drops by a little under 0.4%, based on the current FTSE All Share yield. At the time of writing 15% of sector members would fail the 100%+ test.

3. Abandon any yield target in return for greater disclosure on income generated. This would help those funds which place a greater emphasis on increasing income each year rather than meeting a specific yield criterion. However, it would pass more of the responsibility for assessing what constituted an income fund onto advisers and investors.

The consultation ends next month. Several commentators have already suggested that none of the options looks like an attractive solution.

PENSIONS

Summary of death benefits from money purchase pension schemes
(AF3, RO4, RO8, JO5, CF4, FA2)

This is a summary of lump sum and drawdown benefits paid on the death of a member and beneficiary.

Benefits Payable on the Death of a Member

The following is a brief summary of the benefits payable from a UK money purchase registered pension scheme on the death of a member to a beneficiary (dependant or nominee of the member).

Death Prior to attaining Age 75 - Uncrystallised Funds

If paid within the relevant two-year period:

  • Tested against the member's remaining LTA,
    • BCE 7 (lump sums);
    • BCE 5C (drawdown); or
    • BCE 5D (lifetime annuity),
  • Remaining lump sum can be paid tax-free or used to provide a tax-free income to a beneficiary.

If paid after the relevant two-year period has elapsed:

  • Income or lump sums subject to PAYE assessed on the recipient.

Death Prior to Attaining Age 75 - Drawdown Fund

  • Not tested against the member's remaining LTA;
  • Remaining lump sum can be paid tax-free or used to provide a tax-free income to a beneficiary.

On attaining age 75, any uncrystallised and/or drawdown funds of the member are subject to a lifetime allowance test. The drawdown funds are assessed under BCE 5A and uncrystallised funds are assessed under BCE 5B.

Death Having Attained Age 75

  • Not tested against the member's remaining LTA;
  • Income or lump sums subject to PAYE assessed on the recipient.

Benefits Payable on the Death of a Beneficiary

The following is a brief summary of the benefits payable from a UK money purchase registered pension scheme on the death of a beneficiary to an individual successor.

Death Prior to attaining Age 75

Remaining lump sum can be paid tax-free or used to provide a tax-free income to a beneficiary.

Death Having Attained Age 75

Income or lump sums subject to PAYE assessed on the recipient.

Note:

  • The "relevant two-year period" does not apply on the death of a beneficiary; and
  • There is no LTA test on the death of a beneficiary.

References:

Finance Act 2004 -s. 167, s. 206, Schedule 28 Part 2 and Schedule 29 Part 2
ITEPA 2003 -s. 579A-579D, s. 636A-636C and s. 646B

High quality master trusts a 'top priority' for pensions regulator
(AF3, RO4, RO8, JO5, CF4, FA2)

The Pensions Regulator (TRP) has issued its Corporate Plan 2016/2019. This sets out TPR's main focus over the next three years.

TPR's top - 10 priorities are:

  • Successfully implement automatic enrolment
  • Protect consumers from poorly governed master trusts
  • Effectively regulate defined benefit schemes
  • Effectively regulate public service pension schemes
  • Maintain confidence in pensions
  • Improve the quality of scheme governance
  • Extend our regulatory influence
  • Increase member engagement with pensions
  • Develop our people
  • Be an effective and efficient regulator

This article focuses on the second of these priorities of; "Protect consumers from poorly governed master trusts."

Addressing the "quality and viability" of these trusts is high among the regulator's top 10 priorities, second only to implementation of AE. So it can therefore be seen that risks associated with poor master trust arrangements is seen by TPR as being a significant threat to the success of AE.  TPR's concerns relate to the view that some of these schemes have been set up "off the radar" so to speak and they may not be sustainable in the long term. TPR is pledging action to address those risks. However, but the big uncertainty is about the work the Department for Work and Pensions is doing on the costs of winding up. Will the DWP force providers to commit to paying these costs?

Master trusts enable pension scheme providers to manage a defined contribution (DC) scheme for several employers under a single trust arrangement, making them particularly attractive to smaller businesses which are now legally required to automatically enrol their workforce into a suitable pension scheme but which do not necessarily have the resources to run a scheme of their own. However, these arrangements can be subject to less regulatory scrutiny than FCA-regulated contract-based schemes, prompting the government to pledge earlier this year that it would introduce new rules as part of "the first appropriate vehicle" that will receive full parliamentary scrutiny.

As part of this work, the plan makes it clear that TPR will promote those schemes run by providers authorised by the Financial Conduct Authority (FCA) as well as those that have obtained independent assurance via the voluntary master trust assurance framework; see here. TPR has stated that it will engage directly with master trusts where it has a concern, but the truth is that it is doing this already. This behind the scenes work will be a key part of the TPR's efforts in the next three years.

Currently, master trusts can obtain independent assurance of their quality, measured against a voluntary assurance framework developed by the Institute of Chartered Accountants of England and Wales (ICAEW). However, there is no legal requirement that master trusts obtain this assurance. Independent assurance allows master trusts to quickly demonstrate their compliance with the regulator's mandatory governance standards for all DC schemes.

TPR said that it planned to work with ICAEW on a revised version of the assurance framework as part of the corporate plan, as well as with the FCA and government to "identify and address unmitigated risks to members of master trusts". According to the corporate plan, TPR's biggest concerns are that if large master trusts fail members could be "forced to meet the administration costs as a result of [their] disorderly exit from the market" without a sponsoring employer, while smaller schemes may not have enough members or assets to deliver sufficient investment returns.

This move by TPR is to be welcomed. However, one glaring omission from TPR's Corporate Plan, is any reference to dealing with pension scams. As fraudsters favouring the use of SSAS arrangements what are of course "regulated" by TPR and not the FCA. Concentrating on educating the public is all well and good, but is it sufficient without a more robust and pro-active approach from TPR?

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