With the first cohort of pension schemes and providers due to connect to the dashboards ecosystem in less than a week, dashboard preparations are in full flow.*  Trustees are ultimately responsible for ensuring all scheme benefits, including AVCs, are connected, so you will need to work closely with your AVC providers as part of your preparations.

Understand how the AVC provider is going to connect

There are two main options, with different AVC providers taking different approaches:

• single connection point – an AVC provider can send data over to the main administrator / ISP, who will then use their connection point to the ecosystem for all scheme data, ie including AVCs
• multiple connect points – the AVC provider can connect directly to the ecosystem, creating multiple connection points for the scheme. If you want the benefits to be displayed together, the main administrator will need to generate a “pension link identifier” and share this with the AVC provider, to include it in the data that they send to the dashboard.

What matching criteria are being used?

Where the AVC provider sends data over to the main administrator, the same matching criteria will be used as for main scheme benefits (as it is the main administrator processing “find requests”).  You will need to be comfortable that the data is of appropriate quality and accuracy for the agreed matching criteria.

Where the AVC provider is connecting directly, it will be processing “find requests”.  In these cases, we are finding that providers often have their own matching criteria, which may be different from the main scheme matching criteria.  As it is trustees’ responsibility to set matching criteria, you should understand the rationale behind their matching criteria, given the data held by the AVC provider, and if and how they differ from the main criteria.

In some cases, particularly where there is legacy data, you may wish to take steps to check the quality of the AVC data, and see whether an improvement plan should be put in place.

Update contractual terms

Contracts and policies should be updated to cover dashboard-related activities and to address associated risks.  In the case of legacy AVCs in particular, you will need to check that you can find the underlying documentation, as that is not always easy in our experience.  Given the amount of personal data being transferred, you should also check that the data protection terms are sufficient.

Co-ordinating illustration dates

All of a member’s scheme benefits must be shown using the same illustration date.  This is likely to be difficult in practice, as AVC providers may have values stored using a different “as at” date, or, alternatively, may share the “live” value of a DC pot, with the main scheme benefit having an older illustration date.  This is a recognised issue in the industry, with TPR acknowledging that it may not be possible to align illustration dates immediately.  In these cases, TPR expects schemes to have a “working plan” with their AVC providers to align the dates in a reasonable timescale.  In practice, documenting any illustration date mismatches and what is (or is not) operationally possible in terms of alignment will be important.

What if your AVC provider isn’t engaging?

While we have found that many AVC providers are engaged with dashboards, this is not always the case.  TPR and PDP are aware of this.  The key is to do what you can to try and work with your AVC providers and, where you are making little progress, keep a clear audit trail of the steps that you have taken, and will continue to take.

As connection approaches…

As your scheme’s “connect by” date approaches, you’ll need to work with your administrator, AVC providers and PDP to make sure that all parties are in a position to enable your scheme to successfully connect to the ecosystem.  As with most things in life, communication will be key!

*For smaller schemes, Leanne’s blog provides useful action points to get your preparations started.