STAR is a new collaborative way for organisations in the long-term savings and investments industry to define what excellence means in transfers and re-registration processes, and to demonstrate commitment to its implementation to consumer, government and regulatory stakeholders.
STAR is being delivered by a collaboration between Criterion and TeX, combining the industry-reach, unique strengths, experience and shared ambition of the two not-for-profit organisations.
The Transfers and Re-registration Industry Group (TRIG), a landmark collaboration of 10 industry bodies and representatives of individual firms, delivered a cross-industry framework of good practice for improving customer experiences of moving savings and investments from one financial institution to another.
The TRIG has chosen STAR to manage the framework and support the long-term savings and investments industry in its adoption. STAR will work with industry participants to define the processes covered by that framework, specify good practice targets for each of those processes, and measure actual performance against those targets across the industry.
If you are involved in the management and transfer of long-term savings and investment arrangements, including all types of Defined Contribution Pensions, ISAs and General Investment Accounts, STAR is for you.
Participating in STAR will provide
Participating firms will also benefit from greater certainty in dealing with transfer counterparties, leading to fewer queries and lower administration costs. And consumers will benefit from better communication, common standards, continuous improvement and greater transparency on firms' performance.
Adoption of the TRIG's good practice framework is supported by government and regulators, including the Pensions Minister Guy Opperman MP, and The Pensions Regulator.
All the industry associations that comprise the TRIG - The Association of British Insurers, The Association of Member Directed Pension Schemes, The Investment Association, The Pensions Administration Standards Association, The Pensions and Lifetime Savings Association, The Personal Investment Management & Financial Advice Association, The Society of Pension Professionals, TISA, UK Finance, The UK Platform Group - endorse and recommend STAR to manage their good practice framework.
Q1. What is STAR?
STAR is a service that will be delivered to improve end to end elapsed transfer times across the long-term savings and investment industry.
Q2. How is STAR connected to TRIG?
The TRIG was - a collaboration of 10 industry bodies and representatives of individual firms, that defined a framework to deliver a cross-industry best practice framework. The framework sets out to challenge and improve customer experiences of moving savings and investments from one financial institution to another.
TRIG has now been disbanded following the award of the implementation of this framework to a joint venture between Criterion and TeX.
STAR is the brand of a set of services that defines the delivery of this implementation.
Q3. Who is running STAR?
Criterion and TeX have combined and created a joint venture, the framework and methods used to deploy the TRIG framework has been branded STAR.
Q4. Does the industry support STAR?
In July 2018, the FCA highlighted the issue of transfers and re-registration in its market studies into the Asset Management Industry and Investment Platforms. The initiative has support from the Pensions Minister, across the industry and Government. All industry bodies participating in the TRIG endorse and recommend STAR to manage the implementation and ongoing improvements of the originally defined best practice framework.
Q5. Why should we participate in STAR?
For customers, STAR will lead to greater certainty and speed for transfers, improved control over their money and increased competition. Participation in the framework will enable firms to demonstrate to regulators their commitment to implementing best practice; to the continued development of industry standards; to recognise excellent performance and to improving outcomes for consumers.
The ongoing collection and publication of performance in executing transfers, as well as a list of the firms which have chosen to participate, will provide regulators and customers with clear evidence of how firms are performing. As well as having happier clients, participating firms will also benefit from greater certainty in dealing with counterparties, leading to fewer queries and lower administration costs.
Q6. How much does it cost? / Why is it the same price for all organisations whatever their size?
Funding is transparent, sustainable and free from commercial bias. Criterion and TeX are both not-for-profit organisations, so all participants can be confident that improvements in transfer performance that the STAR framework defines, are not delivered at undue expense. Costs will be borne equitably across a broad pool of industry participants. There is a one-off joining fee of £3K + VAT per Company or Group, and then an annual charge of £1700 + VAT charged per SLA Group set used by each reporting organisation within a Group.
Q7. What is an SLA Group?
An SLA Group is a set of Service Level Agreements covering each of the processes required to deliver a transfer or re-registration end-to-end. For example, we expect an SLA Group to be defined to cover ISA transfer and associated asset re-registration, and another to cover off Occupational DC Pension Transfer.
Q8. If my organisation offers multiple products, do I join twice?
No. The one-off joining fee applies at Company or Group level, and will cover all in-scope products.
Q9. Will MI be at product level or organisation level?
We expect MI to be reported by each organisation for each SLA Group used.
Q10. Who is doing what across STAR?
The STAR team will:
STAR participants will:
Q11. How does this overlap with existing Working Groups?
STAR complements existing transfer and re-registration initiatives by driving consistency and comparability between different existing industry approaches, and by extending the reach of existing good practice more widely. STAR also sets out with the intention of publicly recognising excellent transfer performance.
Q12. How will suppliers of the exchange platforms be involved and engaged?
STAR is establishing a Solution Suppliers’ Forum, to give the suppliers of transfer and administration solutions the chance to engage directly with STAR to receive, review and feed back on performance-reporting specifications. Attending this Forum will be free of charge to solution suppliers.
Q13. Is this work mandated by the regulator?
No. But there is keen interest from regulators and Government in STAR’s progress. It was the FCA that initially brought the TRIG together to develop its framework; and it continues to track the work closely (see e.g. Investment Platforms Market Study Interim Report). The DWP has also taken a keen interest, with Pensions Minister, Guy Opperman publicly urging schemes to commit to implementing the TRIG framework in Money Marketing.
Q14. How will the regulators be engaged?
Relevant regulators and interested Government departments will be invited to observe the STAR Steering Group, and to receive MI showing participants’ output.
Q15. How will the Steering Group be formed?
The Steering Group will comprise two individuals for each SLA Group. Participant firms will be able to nominate individuals to represent an SLA Group that they use. Where there are more nominations than spaces, nominees will be selected by election.
Q16. Who will chair the Steering Group?
Tom McPhail, Head of Policy at Hargreaves Lansdown, has been appointed as Founding Chair of the STAR Steering Group.
Q17. How will this work in practice?
There are three stages:
Q18. What are the timescales?
We are recruiting the critical mass now. Once we have that, we expect the initial collaborative process definition work to last around 6 months. MI requirements and timescales will be agreed as part of this work after which firms will report against their performance.
Q19. How will the performance marks work?
The performance marks help participants be recognised for excellent transfer performance. Participants will have the chance to help shape the criteria for award of the performance marks, although the philosophy behind them is like Michelin stars or Olympic medals: getting to even the lowest level is a meaningful achievement. Participants will report their MI, allowing the STAR team to assess performance and award the marks.
Q20. Will the MI come from existing transfer solutions?
It might, although that will depend on how the SLAs are defined. We believe good industry practice should take the lead, rather than existing solution capability.
Q21. Do all aspects of my business have to come on stream at the same time?
No. We appreciate that different units within a group will have different states of readiness, so will be able to start reporting MI at different times.
Q22. What are the criteria for your recognition marks?
The Founders’ mark will be awarded for the period of their membership to the first thirty organisations to commit in principle to support STAR.
The bronze, silver and gold performance marks will be awarded annually to participants depending on their performance against the SLAs that STAR will define. Like the Olympics We expect even bronze to represent a meaningful achievement, not just a reward for turning up.
Our current thinking is that:
This is subject both to consultation with the Steering Group, and definition of those SLAs.
Q23. How do I find out more?
www.joinstar.co.uk or call Matt Dransfield on 0131 357 0100.
STAR is building its coalition of participating organisations now. Visit the STAR website to find out how you can get involved.Visit the STAR website.