IORP II

If you and your client have decided to transfer to a Synergy Personal Retirement Savings Account (PRSA)

• Complete Transferring your Synergy Executive Pension to Synergy PRSA

This document contains an instruction to trustees to discontinue contributions to the Executive Pension, a transfer instruction and the Synergy PRSA application form in one document. LCP will then wind up the scheme once this has been returned.
Return completed form to Standard Life, 90 St. Stephen’s Green, Dublin 2, D02 F653 or email customerservice@standardlife.ie
Visit the PRSA hub for more information on the Synergy PRSA.

If you and your client have decided to transfer to a Synergy Buy Out Bond (BOB)

• Provide a signed instruction to transfer the Synergy Executive Pension 
• Complete the Synergy BOB application form

Return completed documents to Standard Life, 90 St. Stephen’s Green, Dublin 2, D02 F653 or email customerservice@standardlife.ie
Visit Synergy Buy Out Bond for more information.

If you and your client have decided to transfer to an alternative arrangement with another provider

• Provide a signed transfer instruction to transfer the Synergy Executive Pension
• Complete employer instruction to trustees to discontinue contributions if the transfer is to a PRSA
• You will also have to complete any documents with the alternative provider who will tell us where to send your client’s pension fund.

If you and your client have decided to transfer to a Synergy Personal Retirement Savings Account (PRSA)

• Complete Transferring your Synergy Executive Pension to Synergy PRSA which includes a notice to trustees to discontinue contributions to be signed by the employer and a wind up declaration to be signed by the trustees. 

Return both the completed wind up pack and form to Standard Life, 90 St. Stephen’s Green, Dublin 2, D02 F653 or email customerservice@standardlife.ie
Visit PRSAs – Keeping the ‘Personal’ in Retirement Savings for more information on the Synergy PRSA.

If you and your client have decided to transfer to a Synergy Buy Out Bond (BOB)

• Provide a signed instruction to transfer to a Synergy Buy Out Bond.
• Complete the Synergy BOB application form

Return transfer instruction and completed form documents to Standard Life, 90 St. Stephen’s Green, Dublin 2, D02 F653 or email customerservice@standardlife.ie
Visit Synergy Buy Out Bond for more information.

If you and your client have decided to transfer to an alternative arrangement with another provider

• Provide a signed instruction to transfer to another provider.
• If the transfer is to a PRSA, complete the scheme wind up pack. This contains a notice to trustees to discontinue contributions to be signed by the employer and a wind up resolution to be signed by the trustees.
• You will also have to complete any documents with the alternative provider who will tell us where to send your client’s pension fund.

One member arrangements

• Synergy Executive Pension (EP1…) with a start date on or after 22 April 2021 had to comply immediately. 
• Synergy Executive Pension (EP1…) with a start date before 22 April 2021 have until 22 April 2026 to comply with the regulations.

Multi-member group schemes, including those with only one member, had to comply by 1 July 2022.That affected:

• Executive Pension Plus with scheme numbers beginning with 7 and member policy numbers beginning with 503
• Corporate Pension Series with scheme numbers beginning with 7, member policy numbers beginning with 501 or 502
• Tower Pension Series, with scheme numbers beginning with L

IORP II says all pension schemes, regardless of size or number of members, must produce an annual report and audited accounts. This is a significant additional requirement.

However, the Pensions Authority does not expect trustees to prepare a full trustee annual report and audited accounts if:

• They made a formal commitment before 1 January 2023 to wind up the scheme and transfer the assets to a master trust, PRSA, or Buy Out Bond before 31 December 2023 
• The scheme member retires and takes their benefits

A formal commitment to wind-up a scheme would include

• a written instruction from the employer to the trustees to wind-up the scheme, or
• a notification from the trustees to the members informing them of their intention to wind-up the scheme.

Any decision that impacts a member’s options at retirement must be considered carefully. For example, if a trustee is thinking of winding up a scheme, they must also to think about any related costs, in particular the cost of giving up any guarantees associated with the investments in the current scheme.

• The first annual report and audited accounts are due for schemes with a scheme year ending on or after 31 July 2022. The report and accounts will need to be available within eight months of the scheme year end.
• If the scheme year end is prior to 31 July 2022 the requirements will apply from the next scheme year end in 2023

If the trustee wants to continue as trustee for the scheme, they need to appoint an auditor to carry out the new auditing requirement and key function holders for risk management and internal audit. 

They’ll also need to inform Standard Life as registered administrator of the scheme of those appointments, by completing the Key Function Holders and External Auditor (TIORPII) form.

It’s important to note that these appointments, and producing the annual report and audited accounts, will mean an additional cost for the scheme.

Trustees must carry out all the actions necessary to ensure the scheme is compliant with the legislation.

Trustees have three choices. They can make their own arrangements to comply with IORP II Regulations, appoint a professional trustee to make sure the scheme is IORP II compliant, or review alternative pension options and wind up the current scheme.

If they choose to wind up the scheme, and the member is active, they can transfer to a master trust arrangement with an alternative approved pension provider or a PRSA. 

If the member is deferred r, they’ll need to transfer to a buy-out bond or PRSA. 

Alternatively, if circumstances allow, all active and deferred members can retire from the scheme and take their benefits.
 
We’ll be writing to trustees in 2023 with more information on the options available. 

Consider guarantees for members transferring to an alternative pension product
There may be guarantees associated with the investments trustees have chosen for their current scheme. For example, if members have any with-profits investments they may be giving up valuable guarantees if they transfer or surrender their policy.
Any decision that impacts a member’s options at retirement needs careful consideration. The regulations require that trustees maintain systems of effective governance and internal controls that always protect the interests of the scheme members.

Synergy Executive Pensions with scheme numbers beginning with EP1 and started before 22 April 2021 have until 22 April 2026 to comply with the regulations.

• The current occupational pension scheme trustee remains in place

The trustee is responsible for appointing key function holders, producing annual reports and audited accounts and complying with IORP II regulations, incurring additional costs to the scheme.

• Appoint and pay a professional trustee

While the responsibility for complying with IORP II regulations sits with the professional trustee, the cost of appointing key function holders and producing annual reports and audited accounts will be incurred by the scheme, in addition to the professional trustee fee.

If your client chooses to appoint a professional trustee, we’ll need to know who the auditor and key function holders are. Trustees should complete the Key Function Holders and External Auditor (TIORPII) form and send it to us at registered_admin@standardlife.ie or post it to:
Registered Admin Team
Standard Life
90 St Stephen’s Green
Dublin D02 F653

• Wind up the scheme

The member transfers their pension to an alternative arrangement and the scheme is wound up. Typically the member can choose from:

• PRSA 
• BOB 
• an occupational pension scheme which they’re already a member of, including a master trust arrangement 
• Retire from the scheme if the circumstances are right, and take their benefits. Members should talk to their financial adviser about their options.

For Synergy Executive Pensions with scheme numbers beginning EP1 and started on or after 22 April 2021, we partner with Lane Clark and Peacock Trustee Services (LCP) to provide independent trustee services. 

Since November 2022, where schemes have LCP as trustee and Standard Life as registered administrator, we have decided that winding up is the best option. That’s because neither the employer nor the member will incur the significant additional costs of producing an annual report and audited accounts.

These schemes will need to be wound up before 30 June 2023 and be transferred to an alternative arrangement to avoid these costs.

If there is a professional trustee other than LCP appointed to the scheme, your clients will need to liaise with them to discuss the preferred course of action.

If your clients choose to wind up their scheme and transfer to a Synergy PRSA or buy-out bond, you can find more information about those here:
Synergy PRSA 
Synergy buy-out bond

Standard Life will be writing to trustees early in 2023 with more information on the options available.

• The current occupational pension scheme trustee remains in place

The trustee is responsible for appointing key function holders, producing annual reports and audited accounts and complying with IORP II regulations, incurring additional costs to the scheme.

• Appoint and pay a professional trustee

While the responsibility for complying with IORP II regulations sits with the professional trustee, the cost of appointing key function holders and producing annual reports and audited accounts will be incurred by the scheme, in addition to the professional trustee fee.

If your client chooses to appoint a professional trustee, we’ll need to know who the auditor and key function holders are. Trustees should complete the Key Function Holders and External Auditor (TIORPII) form and send it to us at registered_admin@standardlife.ie or post it to:
Registered Admin Team
Standard Life
90 St Stephen’s Green
Dublin D02 F653

• Wind up the scheme

The member transfers their pension to an alternative arrangement and the scheme is wound up. Typically, the member can choose from: 

• PRSA 
• BOB 
• an occupational pension scheme which they’re already a member of, including a master trust arrangement 
• Retire from the scheme if the circumstances are right and take their benefits. Members should talk to their financial adviser about their options.

We’re also looking into options for group pension schemes containing with-profit investments that will incur a unit price adjustment (UPA) on scheme wind up. 

With-profits policies are designed for the medium to long term. A UPA is an adjustment factor applied to anyone leaving the with-profits fund at a time other than that specified in the contract – for pension schemes, this is the normal retirement age. 

That’s to make sure that those leaving the fund don’t receive more than their fair share of the underlying investment, and that investment managers treat with-profits customers fairly. For that reason, the UPA can’t be waived. 

We’re working with the Pensions Authority on this issue and these proposed solutions:

• Assignment to the member

Where group schemes have only one member, and that member is no longer and employee and no longer paying contributions, the policy may be assigned, as is, to the member if the trust is wound up. Under this option the member remains invested in their with-profit fund.

The details of this option are still being finalised and we will be able to provide you with more information in early 2023.

• Assignment to a master trust

We’re working with a third-party master trust provider to assign schemes to their master trust. This option will be available to group schemes with more than one member, active or otherwise, and to group schemes with only one member who is actively paying contributions. The employer must be active and will need to agree to the assignment. 

When the existing scheme is wound up the policy can be assigned, as is, to a master trust. There would be no change to the underlying contract and the policy would continue to be administered by Standard Life. Under this option the member remains invested in their with-profit fund. 

Assignment of the policy means it will be owned and governed by the trustees of the master trust for the benefit of the members. The trustees will comply with all relevant legislation and requirements, like IORP II requirements, trustee annual reports and audited accounts.

The details of this option are still being finalised and we will be able to provide you with more information in early 2023.

Your clients can get more information about with-profits investment by visiting standardlife.ie/withprofits

May 2023 Mailing  

Synergy Executive Pensions (policy number begins with EP1) set up on or after 22 April 2021 

This mailing highlighted the impact of IORP II legislation, and provided a reminder that once all assets of the scheme are transferred and it’s wound up by 30 June 2023, there would not be requirement to produce annual reports and audited accounts. It also signposted the estimated cost to the scheme of meeting the requirements of IORP II if wind up and transfer is not completed by 30 June 2023.  

Letter to the member of Synergy Executive Pension with Lane Clark & Peacock Trustee Services Ltd (LCP) as trustee 

Letter to the member of Synergy Executive Pension where LCP is not trustee and we received a signed request to wind up the scheme 

Letter to the trustee of Synergy Executive Pension where LCP is not trustee and we did not receive a signed request to wind up the scheme 

March 2023 Mailing
Synergy Executive Pensions (policy number begins with EP1) set up on or after 22 April 2021

This mailing highlighted the impact of IORP II legislation, and provided a reminder that once all assets of the scheme are transferred and it’s wound up by 30 June 2023, there would not be requirement to produce annual reports and audited accounts.

Letter to the member of Synergy Executive Pension with Lane Clark & Peacock Trustee Services Ltd (LCP) as trustee

Letter to the member of Synergy Executive Pension where LCP is not trustee and we received a signed request to wind up the scheme

Letter to the trustee of Synergy Executive Pension where LCP is not trustee and we did not receive a signed request to wind up the scheme

December 2022 Mailing
This mailing reminds trustees of the option to wind up the scheme and that they must provide us with a copy of their formal written instruction or notification to wind up before 31 December 2022.

Synergy Executive Pensions (policy number begins with EP1) set up on or after 22 April 2021

We are working to prepare more information about the options available for members once the scheme is wound up, including details about the Synergy Personal Retirement Savings Account (PRSA) which provides similar investment choices to the Synergy Executive Pension.

Letter to schemes where LCP are trustee (SYEPLCPWU)

Letter to schemes with a corporate trustee or other professional trustee (SYEPTRUSTWU)

Group Schemes (scheme number begins with L or 7)

Standard Life are also looking into options for group pension schemes containing with-profit investments, which includes assigning the policy to the member or assigning the scheme to a master trust with a third party. Read the letter below

Letter for group scheme (GSGOWU)

October 2022 Mailing
We wrote to trustees to tell them about the annual report and audited accounts, and to ask for the details of the key function holders and external auditor. Read the letters below

Group Schemes
One Member Schemes set up on or after 22 April 2021

We’re preparing more information about the options available to members once the scheme is wound up, including details about the Synergy PRSA, which provides similar investment choices to the Synergy Executive Pension.

We’re looking into options for group pension schemes containing with-profit investments, which includes assigning the policy to the member or assigning the scheme to a master trust with a third party. Read the letter for group scheme (GSGOWU).

IORP II legislation meant that from 22 April 2021, no more than 50% of total investments in an executive pension could be invested in unregulated markets like direct property.

As a result, we closed the Standard Life Property Fund and the Standard Life Global Real Estate Fund to new investments through the Synergy Executive Pension and the Executive Pension Plus from 6 September 2021.

These funds are still available on all other Synergy Products.

What this means for customers:
They can no longer make new investments into the Standard Life Property Fund or the Standard Life Global Real Estate Fund. This includes:

• Single contributions, transfer payments, or new regular investments 
• Switching or redirecting regular premiums 
• Increasing premiums

Regular contributions
We have asked for clarification from the Pensions Authority about what this means for customers who already make a regular contribution into either property fund. We'll contact those customers directly if they need to make any changes to their regular premium investments.

We wrote to customers invested in the fund to notify them of the closures to new investments and recommend that they speak to their financial advisers for advice.

If you have any queries on this fund closure to new investments, please speak to your Standard Life Business Manager.