The SPP response supports the overall direction of the proposed changes and emphasises the importance of maintaining proportionate, principles-based standards that provide clarity while preserving professional judgement and avoiding unnecessary procedural burdens for actuaries and schemes.
The SPP broadly supports the proposals relating to actuarial equivalence, the communication of method choice and cross-subsidies, and the consideration of relevant periods when assessing outcomes in collective schemes.
However, the organisation notes that in practice the scope for method choice may often be constrained by scheme design and regulatory requirements.
The response also highlights the importance of balancing responsiveness and stability when determining relevant periods for actuarial equivalence, particularly in the context of structural membership changes or economic shocks such as inflation volatility or sudden market disruption.
The SPP response also sets out support for greater transparency where assumptions used for actuarial equivalence differ from those used for actuarial valuations, noting that such differences may be legitimate but should be clearly explained where they could affect scheme sustainability or intergenerational fairness.
Keith McInally, Chair of the SPP CDC Committee, said: “CDC is becoming an increasingly important and evolving part of the UK pensions landscape. The proposed updates to TAS 310 represent a positive step in strengthening transparency and confidence in the actuarial work that underpins these schemes. As the SPP’s response makes clear, it’s important that the standards remain principles-based and proportionate, allowing actuaries to exercise professional judgement while ensuring that key issues such as cross-subsidies, assumptions and scheme sustainability are clearly communicated.”
|
