Member

I turn to the proposed matters to which regulators must have regard in considering an exemption. These are wide-ranging and do not seem to be relevant to why a scheme should be exempted from being at scale. They also seem to suggest that a scheme could be exempt if it uses the scale of another scheme. Why would an employer choose this smaller scheme if the benefits of scale all derive from a different scheme? What is the smaller scheme adding in member outcomes? It will have no real control over the investment strategy of the pooled vehicle; it will not benefit from the economies of scale that come from having a large asset base. Critically, members will not benefit from their scheme paying for the privilege of being a passenger in another larger scheme’s strategy.