Sackers responds to the Pension Regulator’s consultation on revised internal controls guidance

On 1 December 2009, the Pensions Regulator (TPR) published a consultation on revised guidance on internal controls as part of its current campaign to improve standards in scheme governance and administration.  The revised guidance will replace the original version which was published in February 2007 and is designed to complement TPR’s code of practice on internal controls.  The consultation closed today.

Comments from Sacker & Partners LLP:

Robin Simmons, partner and governance expert at specialist pensions law firm Sackers, commented: "Robust internal controls are a critical pillar of a good governance framework for pension schemes.  Our experience is that many smaller schemes do need further encouragement to get their house in order, so we welcome the Regulator's updating of the guidance.  However, we are concerned that it is a wolf dressed in sheep's clothing - although it is called guidance, the current draft reads much more like a code of practice in its "comply or explain" standard of conduct in several key areas.  We are also concerned at its length - at over 50 pages, it seems destined to be left in the “too difficult” pile of the very users that the Pension Regulator is trying to engage.".

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