Further DWP proposals for DC schemes to invest in illiquid assets

The Government is consulting on ways to increase DC schemes’ investment in illiquid assets. The proposals would mean additional disclosures for DC schemes.

As well as setting out new proposals about illiquid investments, the consultation by the Department for Work and Pensions (DWP), published on March 30, 2022, responds to a previous consultation on removing performance fees from the charge cap.

It also proposes changes to employer-related investment rules for master trusts (see Changes proposed to employer-related investment rules for master trusts) and gives a response to a 2021 call for evidence on further DC consolidation (see Further DC consolidation paused).

The consultation closes on May 11, 2022.

Illiquids: disclose and explain

To facilitate investment by DC schemes in illiquids, the DWP proposes to:

• Add to the Statement of Investment Principles (SIP) requirements. DC pension schemes would have to disclose and explain their policies on illiquid investment in the SIP.
• Require DC schemes with over £100m in total assets to publicly disclose and explain their default asset class allocation in their annual Chair’s Statement. This would include describing the average percentage holding and type of illiquid assets and the benefits the trustees feel these assets bring to their scheme and members.

The DC section of hybrid schemes would be in scope if the scheme’s total assets (DC and DB together) are above £100m. The new requirements would apply only to the DC section.

These proposals are made in the hope that investment policy and asset allocation transparency would increase, therefore encouraging greater competition and innovation and helping with value for money comparisons.

No timescale is proposed for this and it is uncertain how these proposals will fare when consulted on so DC trustees should for now just monitor how this develops.

Removing performance fees from the charge cap

The Government proposed in November 2021 to remove from the charge cap well-designed performance fees that are paid when an asset manager exceeds pre-determined performance targets.

The DWP confirms that reactions to this proposal have been mixed.

The Government now intends to engage further with the pensions industry on the consultation feedback and explore how it could be addressed in future policy. This is therefore probably not the last word on performance fees and the charge cap.