The Croydon Council Pension Board met on 24 July 2025 to discuss updates from the Local Government Pension Scheme Advisory Board, the Pensions Regulator, and the London Collective Investment Vehicle, as well as to review breaches of the law, the risk register, and the administering authority mandatory discretions policy. The board was also scheduled to discuss key performance indicators for the Croydon Pensions Administration Team, and the implementation of the McCloud remedy¹. Finally, the board was expected to review the Pension Board Annual Report.

Government's 'Fit for the Future' consultation

The board was scheduled to note a report on the government's response to the 'Fit for the Future' consultation, which was published on 29 May 2025.

The report included summaries from Hymans Robertson and Mercer, the Fund's Actuarial Consultants and Investment Advisers respectively.

The consultation covered investment pooling and scheme governance. According to the report, the main points covered by the government's response were: Investment pooling

• Funds will continue to set their own investment strategies but delegate implementation to their pool.
• Funds must take their principal investment advice from their pool.
• All fund assets must be transferred to the management of the pool.
• Pools will not be expected to create bespoke investment solutions to suit the specific requirements of each of their funds
• Fiduciary oversight services procured by groups of funds in conjunction with their pool could be used to oversee the pool.
• Each pool must be established as FCA-authorised and regulated investment management companies.
• Arrangements for those funds not needing to change pools must be in place by 31 March 2026.
• For investment purposes local is defined as broadly local or regional to the Administering Authority or pool.
• Each pool will be required to build the capability to enable local investment for their funds.
• Funds will be required to work with other local bodies to ensure collaboration on local growth plans.
• Reporting on the impact of local investments will be done by the pools. Governance
• Requirement for individual committee members (rather than the committee as a body) to have appropriate knowledge and skills aligned to that of Pension Boards – the governance and training strategy will be required to set out how this will be met (this will be achieved by an amendment to the LGPS 2013 Regulations);
• Administering authorities will be required to publish a governance and training strategy and a conflicts of interest policy;
• Administering authorities will be required to publish an administration strategy (this will be achieved by an amendment to the LGPS 2013 Regulations);
• Requirement for Funds to appoint a senior LGPS officer (this will be required by an amendment to the LGPS 2013 Regulations). Part of the remit is to ensure that sufficient resourcing is allocated for Fund operation. The Government's view is that Fund and Administering Authority budgets should be separate, with Fund resources not being restricted (this will be set out in guidance);
• Requirement for Funds to undertake periodic independent reviews and submissions to MHCLG – this will be required once every 3 years (this will be included in the Pension Schemes Bill); and
• Requirement for Funds to appoint an independent pensions advisor to the Committee (non-voting).

London CIV update

The board was scheduled to be updated on the London Collective Investment Vehicle² (London CIV). The report included updates on compliance with pooling requirements, savings in 2024/25, developments arising from the government's 'Fit for the Future' strategic development plan, and London CIV reporting in accordance with FCA requirements.

According to the report, at 31 March 2025, the fund had £424.3 million (21.7% of its investments) invested in sub-funds managed by the London CIV, and a further £837.4 million (42.7%) managed by Legal and General and M&G Investments, which are classified within the pooling umbrella. The report stated that the fund increased its proportion of assets invested through the pool from 52.1% to 64.4% in line with the target of 65%.

The report also noted estimated savings made against assumptions of standard fees and costs incurred from the pool investments during 2024/25 were £778,000.

The report also included the London CIV's Strategic Development Plan, as well as a letter from HM Treasury dated 9 April 2025, and a letter from the Chair of the Scheme Advisory Board to Ministers dated 12 May 2025.

Review of Breaches of the Law

The board was scheduled to review and note the contents of the Pension Fund Breaches of the Law Log Extract. The report presented the current Breaches of the Law log Extract for the Pension Fund and highlights any changes made since the board last reviewed the log extract at their meeting of 10 April 2025.

The report noted that since the board last reviewed the log extract, no new entries had been added, and five entries concerning the 2019/2020, 2020/2021, 2021/2022, 2022/2023 and 2023/2024 accounts, had been updated to include details of the letter to be issued by the Fund to The Pensions Regulator informing them that the Fund has failed to meet the statutory deadlines in respect of publishing annual accounts and annual reports for each of these years.

The board was also scheduled to note the letter sent to The Pensions Regulator.

Implementation of the McCloud Remedy

The board was scheduled to give their views on the intention of officers to exercise discretion on behalf of the Administering Authority to delay, for one further year, the inclusion of remediable service information in the Annual Benefit Statement issued to members for 2024/2025.

The report noted that there would be certain members who do not receive an ABS where the McCloud remedy implementation phase will need to be extended to 31 August 2026.

The report stated that there were some members where the team were currently unable to provide the remedial service information in the 2024/25 ABS, so would apply the discretion to defer until the 2025/26 ABS. These groups of members and reasons are detailed below:

• There are 2 Active and 5 Deferred Members with a pension debit with an effective date after 31 March 2014
• There are 20 Active and 17 Deferred Members with a transfer in pre 65 or Club transfer in
• There are 6 Active and 2 Deferred Members with remediable service that has been transferred from a different public service pension scheme or LGPS administering authority, and the previous administrators have not yet supplied final salary details for the remedy period
• There are 0 Active and 2 Deferred Members who joined the LGPS after age 65 who transferred in remediable service from a different public service pension scheme
• There are 14 Active and 23 Deferred Members where service was concurrent within the remedy period
• Members where officers are querying service and service breaks because they seem inconsistent

Croydon Pensions Administration Team Key Performance Indicators

The board was scheduled to note the Key Performance Indicators and the performance against these indicators set out in the Croydon Pensions Administration Team Performance Report for March to May 2025.

The report noted that the team have generally met targets for most indicators during this period with only a few cases missing legal and team targets for each category, with the exception of deferred benefit calculations which still fall below expected levels.

The report also noted that the team have been cleansing data to ensure member's Annual Benefit Statements will be compliant with added requirements as a result of McCloud remedy.

Review of Risk Register

The board was scheduled to review and note the contents of the Pension Fund Risk Register. The report noted that no new risks have been added, risks 4, 5,6,7, 8, 12, 14 and 15 have all been updated and the previous risk 10 concerning the heightened cyber security risk associated with the Russia / Ukraine conflict has been removed.

Administering Authority Mandatory Discretions Policy Review

The board was scheduled to review and recommend the administering authority mandatory discretions policy statement for adoption by the Pension Committee for a period of 3 years from the date of approval by the Committee.

The report noted that there are no changes to the current policy at this time, but that as a result of the 'Fit for the Future' implications, it is expected that regulatory changes will be implemented which may require further review of the policy at that time.

Pension Board Annual Report 2024/25

The board was scheduled to review and comment on the contents of the draft Pension Board Report for 2024/25, and to agree to publish the report as a final version subject to any changes agreed.

Governance Best Practice Compliance Statement

The board was scheduled to be updated on the updates made to the Governance Best Practice Compliance Statement which were agreed at Pension Committee on 10 June 2025, and to review and note the statement.

Local Government Pension Scheme Advisory Board / The Pensions Regulator Update

The board was scheduled to be advised of the matters currently being considered by the Local Government Pension Scheme Advisory Board and The Pensions Regulator which are relevant to the Fund, and to note the contents of the report.

Cyber Security Update

The agenda included an item to discuss a cyber security update, but the public were excluded from this part of the meeting.