The STAR Steering Group, Implementation Group and wider membership have been determined to progress with the initiative, despite Covid-19. Core Management Information (MI) has been agreed to measure transfer performance. The objective of Core MI Reporting is to allow for the accreditation of STAR members to reflect their performance within the transfer journey. Each service level (SLA) product group has been given individual consideration by the STAR Implementation Group. The STAR SLA Groups are:
- ISA & GIA
- Personal Pensions, SIPP and SSAS
- Occupational / DC Pensions
- Fund Managers / Transfer Agents
Core MI for the Occupational Pensions and Personal Pensions, SIPP and SSAS MI Submissions will initially focus its requirements on the reporting of electronic transfers. The reporting of re-registrations and manual transfers will be included when the Group feel that there is sufficient data available to report on them. For ISA&GIA it has been agreed that the data to be submitted may not be readily available electronically, therefore the focus is on the reporting of the overall end to end journey data, and the ceding party journey. Monthly MI submissions will be uploaded securely to the STAR website by authorised users to an agreed CSV format.
This is a key milestone for STAR, enabling the initiative to become the single, authoritative source of transfer data on how firms are performing - the output of which will be a quarterly industry index and an annual accreditation scheme for participants. STAR Accreditations of bronze, silver and gold will be awarded so that performance can be evidenced, rewarded and improvements encouraged across the industry.
STAR is also working towards full MI reporting. This more detailed MI will provide an indication of how an organisation is performing in the specific processes that it is responsible for in a transfer / re-registration journey. Each step in the process has been given an agreed target SLA, set in business days. Reporting will be against a target SLA rather than a specific Process Step. This allows reporting to match the process followed, e.g where an organisation processes two steps at the same time, they can report against the combined SLA for those steps. Regular implementation meetings are being held to enable the industry to continue to collaborate to deliver the STAR objectives. In addition, an Accreditation Roadmap has been agreed, seeking to accredit organisations in Q1 2022 (for their 2021 data). The annual accreditation scheme will start in January 2022 based on agreed MI consisting of at least 3 consecutive month’s submission of 2021 data.
The FCA, The Pensions Regulator and the Department of Work and Pensions (and ABI, IA) continue to support STAR’s aims and objectives and participate as observers at the STAR Steering Group. Since the FCA’s initial approach to STAR, it has carried out its Investment Platforms Market Study. A key focus of this work has been to improve outcomes for customers through the portability of investments to drive competition and increase choice. The FCA has been clear throughout this process that Pension Providers, Platforms and Fund Managers must deliver efficient, timely transfers to support this, and that it is looking to STAR to be part of the industry solution.
Andrew Marker, Chair STAR Steering Group commenting said:
“STAR is a voluntary framework and due to the significant organisations participating, represents a significant cross section of the financial services industry. We continue to make strong progress despite the challenges of dealing with Covid-19. I am delighted that the initiative has reached a significant milestone for us, which is central to our objectives. The last year has been an intense period of work with the industry galvanised to drive forward this solution. Not only will this initiative improve outcomes for customers, but for participating organisations, it will drive efficiencies and save money in the process. The accreditation roadmap is synchronised with the timings of the FCA who have said they would review progress in 2022 and take further regulatory action if necessary. We are delighted that the FCA encourage firms in the retail investment and pension sectors not already involved in STAR to take part. It is aligned with shared desired outcomes to improve the customer experience, reduce how long it takes to complete transfers and ensure consumers can move to a provider that better meets their needs more easily.”
The STAR initiative, backed by the regulators and the government, is the only cross industry solution bringing together platforms, providers, life companies, service providers and transfer / asset managers. The initiative has galvanised the industry to create long-term solutions to improving customer experience of transferring pensions, savings and investments between companies, by setting and measuring against a good practice framework.
The FCA’s Executive Director for Consumers and Competition, Sheldon Mills, said;
The FCA’s Investment Platforms Market Study highlighted that improving transfer times is critical in improving consumers’ ability to shop around and switch to a platform that better meets their needs. The FCA is supportive of the progress STAR has made to date and the production of Core MI is an important interim step towards achieving its objectives, which aim to bring down transfer times. Full MI reporting, as proposed, seeks to provide equal accountability for firms across the transfer process, as originally envisaged by TRIG. Reducing transfer times remains a priority for the FCA and Full MI will play an important role in ensuring this. Therefore, we are strongly supportive of STAR continuing to pursue the Full MI and its publication. We have committed to a review of progress against our desired outcomes in relation to transfers in 2022, and we will actively be following STAR’s progress towards its objectives over the next 12 months.
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STAR was created as a collaboration between Criterion and TeX, combining the industry-reach, unique strengths, experience and shared ambition of the two not-for-profit organisations.
Criterion was formed for the industry in July 2017, as an independent, not-for-profit industry body providing Standards and Governance services. It was originally part of Origo Services Ltd and has been publishing process and integration standards for over 25 years. Criterion is uniquely positioned to facilitate and drive cross-industry engagement, helping organisations achieve higher levels of collaboration, reduce costs and achieve better outcomes for their consumers.
TeX is a not-for-profit organisation which works with the industry to ensure that the maximum benefit is provided to all members. This new company is financially independent from TISA but benefits from being linked to the TISA brand through name, the expertise provided by the two corporate entity directorships and the administrative support provided by TISA.