Independent governance committees (IGCs) and pensions

The following Pensions practice note provides comprehensive and up to date legal information covering:

  • Independent governance committees (IGCs) and pensions
  • What is an IGC?
  • The regulatory framework for IGCs
  • Who is required to establish an IGC?
  • Composition of IGCs
  • Terms of reference of IGCs
  • The annual compliance report
  • Contents of annual compliance report
  • When must the annual compliance report be produced by?
  • Transitional provisions for changes effective from 1 and 6 April 2020
  • More...

FORTHCOMING DEVELOPMENT: On 24 June 2020 the Financial Conduct Authority (FCA) published consultation paper CP20/9, which contains proposals that aim to make it easier for independent governance committees (IGCs) and governance advisory arrangements (GAAs) to compare the value for money of pension products and services, enabling them to be more effective in assessing value for pension scheme members. Feedback on the consultation paper is sought by 24 September 2020, and the FCA aims to publish a policy statement by the end of the year.

IGCs currently oversee the value for money of workplace personal pensions provided by firms like life insurers and some self-invested personal pension (SIPP) operators. They provide independent oversight of workplace personal pensions in accumulation (building up pension savings) and of the investment pathway solutions that will have to be offered from 1 February 2021. They act for consumers who are less engaged with their pension savings.

The proposals in the consultation paper stem from commitments in the FCA and TPR joint regulatory strategy from 2018 for regulating pensions and the retirement income sector. One aim of this strategy is to promote a consistent approach to assessing value for money across the pensions industry. The FCA also wants to avoid firms or IGCs undertaking work which adds little consumer value, but which adds to consumers’ costs.

Alongside the

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