(Lab):...The Minister
said that the regulations would be cost neutral and the
Explanatory Memorandum says, as she has just noted, that they,
“make minor and technical changes”,
but that does not appear to be the view of the sector. The
journal Professional Pensions, which did a long
article on these regulations, quoted Faye Jarvis
from Hogan Lovells who said the regulations,
“could result in significant costs being incurred, the magnitude
of which will depend upon the level and type of exposure that
would need to be relocated to comply with the rules in the event
of … no deal”...
...The noble Lord raises an extremely important point about the
need to consult before regulations are published, rather than
after. The Minister said that these were technical and that there
was ongoing engagement. Responses from practitioners in the
sector show that they were concerned about the mistakes made the
first time round. Unlike the noble Lord, , who thought that everything
would be perfect the second time round, the response of Faye
Jarvis, a partner at Hogan Lovells whom I quoted earlier, was
that they were getting very significant impacts from the original
version of these regulations. She warned schemes to pay attention
to any further changes to the regulations in case they brought
such unintended consequences again, saying:
“People will need to be scrutinising and seeing what else is
coming out in terms of draft regulations to make sure there
aren’t any other inadvertent errors but also to check there
aren’t any unexpected impacts”.
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