Regulatory and Compliance
How does the package meet regulatory requirements?
Every communication in the package has been developed with reference to the applicable regulatory framework, including:
TPR General Code (effective March 2024) Requiring accurate, clear, plain-English communications with vulnerability considerations. FCA Consumer Duty (effective July 2024) Moving the standard from “did you tell them?” to “did they understand?”, requiring evidence of good member outcomes. Disclosure Regulations 2013 (Schedule 8) Mandatory wind-up notices with specific content requirements and timing deadlines. Pensions Act 1995 (Section 74) and Discharge of Liability Regulations 199 Discharge notice requirements at buyout.
UK GDPR (Articles 13/14) Ensuring members receive access to the insurer’s Privacy Notice within four weeks of buy-in. Pensions on Divorce Regulations 2000 Notification requirements for members with Pension Sharing Orders. Transfer Values Regulations 1996 Including the requirement for FCA-regulated financial advice on transfers of £30,000 or more.
Does the package constitute legal advice?
No. The template communications are prepared by the Marsh Impact team’s communications specialists and are designed to meet regulatory requirements based on our understanding of the applicable framework. They do not constitute legal advice. Trustees should ensure that the communications are reviewed by their legal advisers prior to issue, particularly for the required regulatory notices (Schedule 8, Section 74 discharge notices, and Pension Sharing Order notifications).
How does the package handle the insurer’s Privacy Notice requirement?
Under UK GDPR, members must be given access to the insurer’s Privacy Notice within four weeks of the buy-in completing. The package includes a dedicated covering letter (Ref 1.2) that directs members to the insurer’s Privacy Notice, together with a plain English explanation of why they are receiving it. The insurer’s Privacy Notice URL is inserted as a placeholder and confirmed once available.
What about members’ vulnerability and accessibility needs?
All communications in the package are written in plain English and designed to be clear and accessible. We include specific vulnerability considerations and accessible format guidance, in line with the TPR General Code's requirements for trustees to consider the needs of vulnerable members. We can also advise on large-print versions, alternative formats, and multi-channel delivery strategies.
Important: Scheme trust deeds may impose member notification obligations beyond the statutory minimum summarised above. Trustees should take independent legal advice on their specific obligations. Northern Ireland schemes should note the separate General Code effective 5 July 2024.
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