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Continuity strategy: overview


CDC code in force: 1 August 2022

We must be satisfied that the scheme has an adequate continuity strategyCT1. A continuity strategy is a document that must be prepared by the trusteesCT2, setting out how members' interests will be protected after a triggering event. Trustees must send us the continuity strategy as part of the application for authorisation, within three months after it is revised, and whenever we ask for itCT3. It must give details about all matters set out in regulationsCT4 and include a statement of all levels of administration chargesCT5, which may be presented as a separate document.

We do not expect the continuity strategy to be exhaustively detailed. Using the headings below as a guide, it should provide the principles and framework for identifying key actions, their owners and the timings of decisions required to deal with a triggering event. It should be sufficiently comprehensive for trustees to be able to quickly resolve which continuity option to select and be in a position to provide a template for working up the detail of an implementation strategy within 28 days of the triggering event occurring or becoming final.

Trustees should think of the continuity strategy as setting out a business case to explain what needs to be done and how, and the likely cost of dealing with a triggering event, while the implementation strategy is a fully costed operational business plan to manage a triggering event once it has occurred.

The continuity strategy should be flexible enough to allow the trustees to tailor their approach in response to a specific triggering event. It should be periodically reviewed and if appropriate revised to adjust to changing circumstances. It should also give sufficient detail to allow calculation of the costs identified for the costs, assets and liquidity plan (CALP).

In addition to meeting the requirements set out in the Regulations, trustees should be clear about how they will:

Legal references

CT1 Section 9(3)(f) of the Act

CT2 Section 17(2) of the Act

CT3 Section 17(7) of the Act

CT4 Section 17(5) of the Act and Regulation 15(1) of the Regulations

CT5 Section 17(3) of the Act