The PMI response to TPR consultation: 'Our approach to the investigation and prosecution of the new criminal offences'

We support the work being done by The Pensions Regulator (TPR) and others in seeking to address serious intentional and reckless behaviour and improving standards of governance and conduct in relation to pension schemes.

We are grateful for TPR’s confirmation that it does not intend for its guidance to change commercial norms or accepted standards of corporate behaviour in the UK (i.e. consistent with the government's policy intent). However, we are concerned that the current drafting of TPR policy does not achieve this aim. In particular, we do not believe it addresses the concerns raised by the industry during the development of the law, in relation to the broad and ill-defined scope of the new powers, and the circumstances when they will apply. We believe that this will have the impact of altering or reducing normal commercial activity.