Industry bodies warn of 'consultation fatigue'

The Society of Pension Professionals, the Pensions Management Institute and the Pension Administration Standards Association were all of a view that, although the consultations represent work being done on a large number of important issues, overloading the industry with material and short deadlines hampers its ability to respond as comprehensively as it otherwise might.

SPP president James Riley told Pensions Expert his organisation has composed nine consultation responses in the past two months, with the regulator’s new combined code of practice being “an absolute monster in terms of the volume of material”.

SPP has another 13 responses due by the end of July, amounting to an “enormous amount” of consultations issued by bodies such as the Pensions Regulator, the Department for Work and Pensions, the Financial Conduct Authority and the work and pensions committee.

Too many consultation responses add little value because they make fairly obvious points or duplicate what everyone else is saying. Respondents should reasonably focus on where they have most specialist value to add, and should be more relaxed about ignoring questions where they have no particular insight

Steve Webb, LCP

This would be difficult enough on top of all the other ongoing work, like guaranteed minimum pensions equalisation and dashboards, he said, but it has been made harder since issuing bodies are increasingly “compressing the timescales” for response.

The PMI’s director of policy and external affairs, Tim Middleton, sounded a similar note, telling Pensions Expert the “bottleneck” that seems to have emerged makes things “awkward” from an administration and resourcing perspective. 

The PMI recently had to file three separate responses in the space of two days, one on defined contribution charges for the DWP, another on contribution notices for TPR and the third being a call for evidence on the staged introduction of pensions dashboards.

He likewise noted the “worrying trend” of compressed timeframes for responses.

“It’s putting an awful burden on the individuals during the consultation, but I think more than that, you’re at risk of simply answering the questions you’re put rather giving them a thoughtful response about the policy the government’s actually trying to achieve,” Riley said.

Riley, Middleton, and PASA board executive Lucy Collett each welcomed the fact that work is being done on such a large number of vital areas.

“Some of the open consultations/call for input on pension scams, benefit statements and pensions dashboards in particular, are crucial to pensions administration and the industry we strive to represent. We are delighted these issues are being addressed and administration issues are becoming front and centre of policymakers’ minds,” Collett said. 

Response period should last for ‘at least’ eight weeks

PASA, the SPP and the PMI all called for longer response times and a more ‘joined up’ approach by government departments and regulators.

This was in part to allow the industry to devote enough time to consider each issue in full, but also to ease the administrative burden of composing responses, which will often involve surveys and working groups that take time to report back.

“The way we deal with things at PMI is that we have a committee whose responsibility is to coordinate a response to each of these exercises. So we have to decide how we’re going to go about doing this; and, on occasions, what we’d like to do is prepare a member survey,” Middleton said.

This would involve “having sufficient time to prepare a survey, to issue it to members, to collate the results, and then write up a response on the basis of that”, he said. 

He added: “So time is another major factor. And it’s also worth bearing in mind that we have volunteers who have day jobs as well. We can’t rely on people dropping everything at a moment’s notice to prepare a consultation response.

“When you get the situation that we have now, in which we have a lot of material in a very short space of time, it’s all too easy for us to find ourselves stretched to the limit.”

Collett said that PASA welcomed the “focus on improving standards and administration issues and we are at a very exciting point in time where focus is squarely on small pots, benefit statements, dashboards, GMP equalisation, pension scams and improving member outcomes”.

“This is everything PASA strives for, but in order to provide well-considered and fully rounded responses to all consultations on behalf of our members and the administration industry, we would welcome response windows of a minimum of eight weeks and a little more joined up spacing of requests from the issuing bodies,” she said.

No ‘badge of honour’ for responding to every question

LCP partner Steve Webb told Pensions Expert: “It does sometimes feel as though there is a new government consultation every day with not enough time to digest them all and give a measured response.”

The industry requires time to consider each consultation in detail, and the government could better coordinate with regulators to ensure they do not end up issuing consultations on “broadly similar issues”, he said.

However, he argued that the industry itself needs to recognise that a lot of the workload is cyclical. The passage of the Pension Schemes Act necessitated a raft of new regulations, and these in turn required a larger number of consultations.

Though acknowledging there are merits to informal consultations, not least because they can be more efficient and less time-consuming, Webb cautioned that relying too much on informal consultations “is not transparent and risks the same voices having too much influence”.

The industry could help itself by recognising that there is no “badge of honour” awarded for answering every question in every consultation, he continued.

“Too many consultation responses add little value because they make fairly obvious points or duplicate what everyone else is saying. Respondents should reasonably focus on where they have most specialist value to add and should be more relaxed about ignoring questions where they have no particular insight,” he said.