The Regulator’s new draft code is much more tightly written and is less prescriptive than the previous editions. We have a few serious comments to make. These pertain to their treatment of value for members and to the speed with which contributions should be invested once received.

The consultation on the code also provides an opportunity to raise related matters. There is a need to address gaps in the regulatory framework for master trusts and to do so promptly. Master trusts are playing an essential role in automatic enrolment. They offer considerable benefits of scale, institutional pricing and high quality governance, which would otherwise be unavailable to a large segment of the working population. However, the regulatory framework developed to regulate occupational DB and DC schemes, set up and supported by a single employer is now in need of review to take account of the new risks posed by master trusts.