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The clock is ticking:Meeting PPF Deadlines

It’s that time of year again: the weather is wintry, despite it being nearly Spring; the New Year TV dramas have finished with nothing to replace them; and we are into the final few days of implementing Pension Protection Fund (PPF) levy saving measures. Are you on track to meet the PPF’s deadlines?

Trustees that have the benefit of a contingent asset guarantee should check with their actuarial advisers whether the levy saving could generate £100,000 or more. If so, the trustees will need to obtain a guarantor strength report, which must be submitted in hard copy to the PPF by 5pm on 29 March 2018. The trustees must obtain this report before certifying or re-certifying a contingent asset guarantee. Don’t leave it too late. The report is a new document, which will require some thought. Some trustees may wish to obtain a guarantor strength report whether or not the amount of levy saving requires it. This is because it is likely to provide more certainty as to whether or not the PPF will accept a guarantee as a contingent asset.

Likewise, if you are about to put in place a new contingent asset agreement then it must be in the new form published by the PPF on 18 January 2018. It is worth noting that all contingent asset agreements with fixed cap liability will need to be in the new format in time for the 2019/20 levy year.

Finally, employers that fall within the new definition of “Special Category Employer” (broadly those employers who have some connection with government, and so carry a low risk of insolvency) should complete the self-certification form on the PPF’s website. This will result in a more preferential levy banding. Again, this should be done in plenty of time in order to allow the PPF to raise any questions.

For further information, please see our February communication.

© Copyright 2018 Squire Patton Boggs (US) LLP

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About this Author

Philip Sutton, Estate Attorney, Squire Patton Boggs
Partner

Philip has over 20 years’ experience advising corporate sponsors, trustees and others on a wide range of issues relating to UK pension plans. He regularly helps clients to establish, change or close their pension plans as well as assisting on a wide range of compliance and day-to-day advisory issues.

+ 44 121 222 3541