During  the early part of 2013, the UK Government consulted over whether  smoothing of assets and liabilities should be disallowed (as has been  the case for several years), permitted, or made mandatory. The response  was, to my mind, amazingly, adverse and, in some cases, misinformed. Two particular canards were that those promoting smoothing were promising  lower costs and evading bad news. In fact, smoothing can increase costs  in the short term and the argument was really about what is appropriate  for the long-term. In the end, smoothing continued to be banned, which  is a real shame.

In 2017, DWP launched a green paper entitled “Security and  Sustainability in Defined Benefit Pension Schemes”, with responses due  in by 14 May 2017. Presented entirely personally, I submitted my views  on the last day.

Then, in 2020, TPR held a consultation about funding DB pension schemes. In my view, their approach was horrific, essentially designed to bankrupt plan sponsors and enrich insurance companies, which I accept may not have been intentional. My submission is here.

More recently, in 2023 and 2025, we have had two Mansion House pension reform speeches but there seems to be little relevance to DB schemes. Sorry, there are the surplus refunds but I wonder how they’ll really work out. Without illustrative outcomes, basing them on capital values doesn’t fill me with any confidence. Relying upon the funding basis being so strong that there should be no problem  suggests that one should be asking whether the funding basis is actually too strong. If I were still a pension scheme trustee being asked for a  surplus refund, I hope that my co-trustees would agree that we need the sponsor to provide robust stochastic evidence at their expense.