Mr. Jerry Moriarty:

Not particularly. I think the particular issues are for very small, self-directed schemes, which are mostly for company directors. Our members tend to be more on the large employer schemes. While the Government has been clear that the current IORP directive only applies to schemes of more than 100 members, the intention is to apply it to all schemes. We certainly feel that should not happen, at least until there are suitable alternatives for those smaller schemes. The regulator has been very clear that it wants greater consolidation of schemes, because we have too many small schemes. I think this is a trigger to make that happen, if the governance requirements become so difficult that it forces schemes to do something else. At the moment, those other options that are available are planned to be changed. The regulator wants a new regime for regulating and authorising master trusts, which are multi-employer schemes, or one scheme with lots of employers in it, but those provisions are not in place yet. We also know there are plans to introduce auto-enrolment, where all employers are going to have to put their employees into a pension scheme, and our concern is that, without either of those two options being on the table yet, if a lot of additional requirements are forced on smaller schemes, employers are just going to stop doing anything. We feel that would be a mistake. Until that is in place, the derogation should continue to apply to smaller schemes.