AMNT welcomes this consultation, which reflects many of the themes set out in its February 2023 report to the regulator, “AMNT proposals on the future of professional trusteeship”, as well as more recent concerns about the inherent risks of conflict and concentration in the PCST market and the lack of member voice as schemes consolidate towards the Minister’s vision of a future with fewer but larger pension schemes.

The Minister’s foreword states that “trusteeship is a vocation”, and this is particularly evident in the role of member-nominated and other lay trustees, who engage in trusteeship because of their direct connection to the scheme and its beneficiaries. For the sake of members, it is essential to find ways to preserve that voice within larger multi-employer and master trust schemes, whether DB, DC, or CDC. The most effective way for that voice to be heard is through representation on the governance board, supported by appropriate training and experience tailored to the scheme.

There is a clear risk that the loss of this voice could increase conflicts of interest and encourage groupthink among a limited pool of professional trustees. The most effective boards bring together individuals with diverse backgrounds and experience, enabling constructive challenge and collaboration in the best interests of members.

This consultation contains a significant level of detail, and we look forward to responding carefully to such an important subject.

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