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You’ll all have heard about the need for competitive tenders for fiduciary manager appointments, but there’s a less well communicated new requirement coming out of the recent CMA review. This one involves investment consultancy and it will impact all pension schemes.
The CMA found schemes rarely had clear objectives set for their investment consultants, meaning pension trustees have trouble understanding whether they are being served well or not. All trustee boards will need to do something about it – by 10 December 2019 you will need to have set objectives for your existing investment consultant and then incorporate these into any new tenders for investment consultancy services.
What might these new objectives look like?
The Pensions Regulator (tPR) will issue guidance, but we don’t have this yet. We expect objectives will involve an element of measuring an investment consultant’s success in providing the right advice to enable the pension scheme to remain on track with its journey plan. There will almost certainly be some more subjective measures around the quality and clarity of advice too.
Possible foibles include investment consultants who are good at talking about the market and the way various assets are performing but are less able to crystallise knowledge into concrete advice specific to the pension scheme. We’ve also all met a few who drag their feet in dropping poor funds (think guaranteed annuity rate funds in the late 1990s etc).
There are some pension investment consultants who tend to take the latest ideas off the shelf internally then communicate them to pension scheme clients without due regard to the circumstances of each individual scheme… or perform expensive investment reviews when not fully necessary… or provide extra cost reports that aren’t very helpful. As professional trustees we can spot (and stop) this, but it is much harder for those whose pension trustee role isn’t their day job.
Of course, there are excellent investment consultants out there who do none of these things. The question is are pension trustee boards measuring and evaluating them by taking all this fully into account?
In any event, this topic will arise at your next pension trustee meeting (it should, so make sure it does). If tPR’s guidance is out, this can inform the discussion. If not, hopefully my thoughts might help stimulate some debate around the trustee board table.
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