Where a member of an occupational DC pension scheme designates their pension fund into flexi-access drawdown at age 60, ie prior to their normal retirement age (age 65), at what time are the information requirements of reg 19 of the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013 (giving first information on accessing benefits) triggered?

Regulation 19 of the Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013, SI 2013/2734, applies in respect of Members who have a right or entitlement to flexible benefits and requires the scheme to provide them with retirement information ‘at least four months before:

1. •

   where there is a retirement date, that date, or

2. •

   where there is no retirement date, the date the member attains normal pension age’ [reg 19(3)]

Moreover:

1. •

   ‘retirement date’ means ‘the date specified by:

   1. ◦

      the member to the trustees or managers of the scheme that is acceptable under the rules of the scheme, or

   2. ◦

      the trustees or