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Authorisation of existing master trusts

From 1 October 2018, master trust pension schemes will have six months to apply for authorisation from us in order to continue operating.

Preparing your application

If you operate a master trust you will need to demonstrate that the scheme meets the required standards across the following criteria:

  1. Fit and proper: all the people who have a significant role in running the scheme can demonstrate that they meet a standard of honesty, integrity and knowledge appropriate to their role.
  2. Systems and processes: IT systems enable the scheme to run properly and there are robust processes to administer and govern the scheme.
  3. Continuity strategy: there is a plan in place to protect members if something happens that may threaten the existence of the scheme, including how a master trust will be wound up.
  4. Scheme funder: any scheme funder supporting the scheme is a company (or other legal person) and only carries out master trust business.
  5. Financial sustainability, including business plan: the scheme has the financial resources to cover running costs and also the cost of winding up the scheme if it fails, without impacting on members.

Our code of practice and accompanying guidance provide practical guidelines on demonstrating how your scheme meets these criteria.

You will need to submit your application via the master trust portal.

Fee

You must pay the fee of £41,000 before you apply for authorisation of a master trust that operated before 1 October 2018.

You need to make the payment by BACS. You can ask for our bank account details by emailing MasterTrustAuthorisation@tpr.gov.uk.

When you pay, use the reference ‘MTA’ followed by the Pension Scheme Registration (PSR) number for your master trust.

Decision-making procedure

We'll make a decision on your application within six months of receiving it. For further information, read:

Extensions to the application period

If the trustees satisfy us they have a good reason for needing an extension, we may extend the application period by up to six weeks.

We may be prepared to grant an extension for a variety of reasons. However we are unlikely to be satisfied that there is a good reason for an extension where a scheme has simply not been diligent in preparing its application and is unlikely to meet the deadline for that reason.

We will be more likely to grant an extension to the application period because of circumstances beyond the trustees’ reasonable control. Examples might include the sudden illness or incapacity of a trustee, or the resignation of a trustee or strategist. It may also be appropriate where the scheme is undertaking a major event that impacts on its structure (for example changing a key service provider) or the information contained in its application. However we will take into account all relevant circumstances in deciding whether to extend.

Making a request

Requests should be sent to MasterTrustAuthorisation@tpr.gov.uk. They must contain full details of the reasons why an extension is needed together with the length of extension required, up to a maximum of six weeks after 31 March 2019. A TPR supervisor will inform the applicant of the outcome of their request as soon as is reasonably practicable. Where granted, the confirmation will include the date by which an application for authorisation must be received.

Schemes that have still not submitted a complete application for authorisation at the end of the extended application period will be considered not to have made an application and may be fined and required to wind up and leave the market if operating as a master trust without authorisation.

Feedback from the readiness reviews

We received 33 draft applications as part of the readiness review process. We reviewed these and provided feedback to the schemes that applied. To help schemes to continue focusing on their final authorisation application, we have put together details of lessons learned:

Multiple schemes and cluster schemes

The requirement to be authorised is at scheme level rather than provider level. Therefore, each scheme needs to be authorised to operate in the market.

Cluster schemes are an exception to the principle of one application per scheme. When you come to apply for formal authorisation, you should treat these schemes as one master trust and make one application for the group. You can read more about cluster schemes in paragraphs 27 to 32 of the code.

New schemes

If you’re planning to set up a new scheme after 1 October 2018, you will need to apply for authorisation of a new master trust.