Code of Practice - Reasonable Periods for the Purposes of the Occupational Pension Schemes Regulations 2006
ACCA is pleased to comment on the draft Code of Practice on the above.
Our main reaction to the draft is that the list of reasonable periods as set out in Chapter 3 contains such a diverse collection of deadlines that it would require regular consultation by trustees and managers. This could be said to add to the weight of the regulatory burden on them. A small number of the individual deadlines covered in the draft are not capable of amendment. But we wonder whether it would be more efficient, and helpful to trustees and managers, to identify a standard period, say 2 or 3 months, and for this standard deadline to be applied in the great majority of cases.
On another matter, the passage relating to the status of the Code states that it is not necessary to follow all the provisions of a Code in every circumstance. But some of the time periods provided for in the Regulations are mandatory. Therefore the Code needs to distinguish between those indications of ‘reasonable periods’ which are mandatory and those which convey the Regulator’s idea of what constitutes best practice.