A COVID-19 checklist for DC Schemes
02 Apr 2020
In unprecedented times like these, the role of a DC trustee or governance committee member is vital in protecting the interests of their DC members. Along with their advisers, providers and administrators there are a whole range of things that need to be considered. I’ve outlined just some of the questions that should be considered in each of the main areas of effective scheme management, namely scheme governance, administration, investment and member communications. Every DC scheme is different so treat this like a checklist to identify where you may need some extra attention or support.
Scheme Governance
These are extraordinary and challenging times and understanding how you can continue operating and making decisions throughout is essential. For example, do you have a Deputy Chair if the Chair is sick? What are your quorum rules, and should you be considering creating a Covid-19 quick response sub-committee?
Does everyone know what jobs others normally do and is there an up to date contact list for all the relevant parties, including the administrator and adviser?
How robust is the Board in making decisions in these difficult times and how will you hold online meetings (particularly for retired trustees who might not have the same technology available as those still working).
If the company is in a weak financial position, should the Trustees be asking for money at this stage to be paid, for example, into an escrow account which could fund the cost of the wind-up of the scheme in the event of the insolvency of the employer (as otherwise, the costs would come out of member pots)?
Administration
It’s essential that smooth pension scheme administration continues to happen throughout the crisis. By ensuring you have a detailed understanding of how each process is undertaken by your administrators, you’ll be well placed to understand where any pinch points might come and how you can keep your members updated on this.
Who at the company pays the monthly contributions across to the administrator? Is there cover in the case of illness, particularly if there are multiple payrolls?
Is the process for paying UFPLS out of the scheme (if relevant) robust in a more challenged administration environment?
Is your administrator still answering member queries by phone or have they switched to email only? If so, what implications does this have for your internal pensions team given the probability of increased member queries?
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