There are more external testing and evidence requirements than you may think to meet the authorisation submission requirements for the Pension Regulator by 31 March 2019. This is because the Systems and processes questionnaire has 5 items (4d, 4e, 7a,7b,7c) that were not originally marked ‘IXA’ in the one released in September 2018 or the one used earlier in the Readiness Review.
The Systems and processes: guide to completing your questionnaire has not amended as such. The updated questionnaire reflects more clearly the narrative given in the guide. It is advised that Trustees liaise with their external reporter as to how these will be covered.
“For certain requirements, we would like to see evidence that an independent external assessment has been carried out. Where we expect to see this, we have marked it in the questionnaire as ‘IXA’, against the requirement. For each of these, we have provided a table against each requirement in which you can set out the specific control objective you are submitting as evidence and a text box where you can explain in a narrative how that objective supports your scheme’s compliance with the specific requirement.” Introduction extract from Master trust authorisation Systems and processes questionnaire page 2, The Pension Regulator dated October 2018.
The originally marked IXA items remain being 1a, 1c, 2a, 2b, 3a, 3b, 3c, 4b,4c,5e,6a, 6b. However, there may be less than you may think because 3d is not an IXA item as there is a typo on 3d with a redundant IXA table that does not apply because 3d is not marked IXA (see the extract of questionnaire below).
Also, there may be less to describe for some items in relation to evidence for part c Explain how it is reviewed and monitored to ensure it is effective over time.
4d and 4e are stated by TPR as ‘our preference’ and join 4b and 4c that have always been noted for IXA testing.
Items 7a,7b, and 7c are stated as ‘We expect’ rather more strongly than ‘Our preference’.
There is also a typo on 3d with a redundant IXA table that does not apply because 3d is not marked IXA.
The Systems and process questionnaire and guide are available here.
Testing and evidence collection will be well in progress for master trust authorisation submissions – if you wish to discuss any matters, please email Assure UK’s Director of Assurance Andrew Riley on email email@example.com alternatively, you can call on 020 7112 8300.