Is AAF just a tick box exercise for the Pensions Regulator?

The Audit & Assurance Faculty (AAF) first published guidance on internal controls for pension scheme administrators (AAF 01/06). This was followed by AAF 02/07 for pension trustees, which required independent trustee firms to demonstrate they operate sound administrative and accounts procedures (amongst other things).

Why put yourself through it?

Participation in AAF 02/07 is not mandatory, but is necessary for professional pension trustees who want to be on the Pension Regulator’s (tPR) register, like PSIT and HR Trustees Participation in the AAF audit process is also necessary to be considered for the Pension Protection Fund (PPF) trustee panel (HR Trustees is a panel member), as being on the tPR independent trustee register is one of the PPF panel requirements.

We found the process invaluable. As we recorded processes and discussed controls with the auditor we had to refine our approach, sometimes putting in place formal procedures and forms where previously we had an unwritten understanding of what was required. With formal procedures now in place, standardised approaches and documents, we ensure everyone works to a uniform high standard

What does the AAF process demonstrate?

The Pensions Regulator sets a total of 25 objectives for the way pension trustee services are delivered , which include:

• risk management
• IT security
• risk assessment for taking on new business
• knowledge and skills of staff
• appointment of advisers
• monitoring investments

The process for meeting each objective is set out, controls have been applied by an independent auditor and these controls are tested annually. They apply to defined benefit (DB) and defined contribution (DC) pension schemes, sole independent trustee appointments and where we are a member of a board of pension trustees. If all the controls are met, no exceptions are recorded. I’m proud to note that our last AAF audit had no exceptions.

So, whilst in the beginning we were inclined to think AAF was a tick box exercise, having just completed our fifth audit we know, in practice that this is not the case. An AAF audit may be a time consuming process, but it is worth the effort having helped improve our practices and procedures that enabled us to provide a better, more assured service to clients.

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