Member

Amendment 32 is really important, and I hope the Government and the Minister might consider its merits. The Bill currently suggests that, if a scheme receives an intermediate rating, its trustees or the provider itself suddenly must do all kinds of things that will be pretty expensive and probably quite scary: notifying members that the scheme is intermediate value—whatever that will be called—and notifying the employer, as if there is something fundamentally wrong with the scheme. However, with any investment product there can be one or two years in which it does not perform terribly well, but that does not mean that anything is wrong. These are long-term investments and the aim is a long-term outcome, and if you are investing with a longer-term strategy then you will have years where perhaps performance is not so good or managers change. Rather than all these draconian requirements set out in the Bill being required immediately, I suggest that the intermediate rating needs to be maintained for at least three consecutive years. At that stage, the big costs of writing, reporting and planning how you will improve would kick in.