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Last week TPR published draft guidance on calculating cash equivalent transfer values for members of defined benefit schemes, for consultation which aims to help trustees of defined benefit schemes understand and fulfil new responsibilities introduced in regulations by the Department for Work and Pensions.

However, according to Mercer a global provider of consulting services to the financial services industry, the timing of the guidance does not dovetail with the expectations imposed on trustees under the regulations.

Legally the regulations come into effect from 1 October 2008, but in practice, it says trustees will have had to reach decisions on the calculation of cash equivalent transfer values well before then.

Deborah Cooper, head of Mercer’s retirement resource group, said: "Trustees are already thinking about their new responsibilities.

"They will have had to consult with their actuary, complete their decision-making process and notify their administrators of any changes needed to the calculation basis and disclosures to members well in advance of 1 October to comply with the regulations."

Cooper added: "TPR has an obligation to promote good administration of schemes – having a consultation on guidance that won’t be complete until after it is needed does not help.

"It just adds an additional burden on trustees who will have decided on a course of action before the guidance is finalised."