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Master trust readiness review

We received 33 draft authorisation applications as part of the readiness review process. We are reviewing these and will provide feedback by the end of August to all schemes that applied. Shortly afterwards we will publish details of the lessons learnt from readiness reviews. In the meantime, and to help schemes to continue focusing on their final authorisation application, we have four initial feedback points.

1. Meet the procedural requirements of the legislation and code

Make sure:

  • your application is complete with all compulsory documents included
  • your costs, assets and liquidity plan is included and there is separate ring-fencing for the master trust
  • the continuity strategy contains enough detail explaining how members benefits will be protected in the event of a triggering event and you have included the statement of charges
  • the trustee’s perspective is considered, including reviewing and signing-off the draft application
  • you provide business plans as standalone narrative documents

2. Follow our guidance

Make sure you:

  • provide evidence to support the statements you make
  • provide evidence about the collective competence of the trustee board and how this meets the fit and proper criteria
  • correctly identify all key roles and if there are no parties fulfilling certain roles, eg scheme promoters or marketers, explain why you consider this to be the case
  • provide clearly signposted evidence of how your systems and processes meet the required standards
  • include the required information in your continuity strategy

3. Explain why documents haven’t been included

If you haven’t included documents that we expect to see, as set out in our code and guidance, you should explain why they are not relevant to your scheme as part of your final application.

4. Provide clear signposting

Make sure you:

  • index all documents you submit via the portal (using the new template we will provide)
  • clearly reference relevant documents in your answers
  • don’t include documents without explaining what they’re for

Code of practice

We laid the final code of practice before Parliament in July 2018.

Forms and guides

We have now removed the forms and guides you used to complete your draft application from our website. They will be updated following the responses to our code consultation and we expect to publish the new versions in September. If you would like a copy of the previous forms, contact our customer services team or email us at MasterTrustAuthorisation@tpr.gov.uk.

You’ll need to use the new forms and guides to complete your final application from 1 October 2018.

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 draft code.

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