In the Ghanaian pension system, trustees are pivotal in ensuring the effective administration and management of pension funds, particularly under the three-tier structure introduced by the National Pensions Act, 2008 (Act 766, as amended). As a senior compliance and treasury expert with over 20 years at institutions like Ecobank Ghana, I’ve overseen pension-related operations, especially in the context of post-2017 banking cleanup and the 2022-2024 Domestic Debt Exchange Programme (DDEP), where trustees played crucial roles in safeguarding member interests amid bond haircuts and liquidity challenges. Trustees, approved by the National Pensions Regulatory Authority (NPRA), act as fiduciaries, balancing regulatory compliance with stakeholder expectations for resilience, ethical practices, and profitability. Below, I discuss their expected roles and functions from the perspectives of regulators (primarily NPRA, with indirect BoG oversight via financial stability directives) and other stakeholders (e.g., scheme members, employers, fund managers, custodians), grounded in NPRA guidelines and Act 766, with practical insights.

Roles and Functions Expected by Regulators (NPRA)

The NPRA, as the primary regulator, mandates trustees to administer schemes in compliance with Act 766 and associated guidelines, emphasizing fiduciary duties, risk management, and transparency. Under BoG’s broader ecosystem (e.g., aligned with Basel III and Corporate Governance Directive 2018), trustees contribute to systemic stability, especially in investment decisions post-DDEP recovery as of 2025. Key expectations include:

• Scheme Registration and Setup: Trustees must secure registration of pension schemes with NPRA, ensuring all documentation complies with regulatory standards. For instance, in practice, this involves submitting trust deeds and investment policies, as seen in the registration of Tier 2 and Tier 3 schemes for corporates like MTN Ghana, preventing delays that could expose members to risks.
• Appointment of Service Providers: Trustees are responsible for appointing licensed pension fund managers, custodians, and other providers (e.g., auditors), ensuring their independence and compliance. This includes due diligence to avoid conflicts, as per NPRA’s guidelines, which I’ve applied in syndicating facilities where pension funds invest in corporate bonds, aligning with BoG’s Liquidity Risk Management Guidelines to mitigate operational risks.
• Investment Policy and Risk Management: Maintain and review investment policy statements, ensuring diversification to minimize risks (e.g., variance and standard deviation in portfolio returns). In Ghana’s volatile market, trustees must hedge against systematic risks like inflation (e.g., using FRAs or swaps under Payment Systems and Services Act, 2019 – Act 987), as evidenced by post-DDEP strategies where trustees shifted to shorter-term T-bills for liquidity.
• Fund Administration and Record-Keeping: Keep accurate accounting records, member registers, and separate accounts for each member, updated monthly. This ensures transparency and facilitates audits, crucial under NPRA’s annual reporting requirements and BoG’s Cyber and Information Security Directive 2020 to protect against data breaches in digital pension platforms.
• Processing Transfers and Payments: Handle member requests for transfers, withdrawals, or benefits efficiently, in line with scheme rules. Practically, this involves coordinating with employers for timely remittances, as delays during the 2017-2019 cleanup led to penalties for non-compliant banks.
• Reporting and Compliance: Prepare and submit annual audited financial statements, scheme reports, and notify NPRA of irregularities (e.g., fraud). Regulators expect proactive governance, including ICT adherence for interoperability, as per NPRA’s ICT Guidelines, integrating with fintech trends in 2025 for ethical digital banking.
• Fiduciary Duties: Exercise prudence, care, and diligence as a “prudent person,” acting solely in members’ interests, avoiding conflicts. This is enforceable under Act 766, with penalties for breaches, as in cases where trustees faced revocation during governance lapses similar to UT Bank’s collapse.

NPRA oversees through licensing (renewable annually), inspections, and potential revocation for non-compliance, ensuring trustees meet capital requirements (e.g., minimum net assets) and have qualified boards with independent directors.

Expectations from Other Stakeholders

Stakeholders expect trustees to bridge regulatory mandates with practical outcomes, fostering trust and sustainability in pension funds, which total over GHS 50 billion as of 2025.

• Scheme Members (Contributors): Expect protection of accrued benefits, timely statements (quarterly), and maximized returns through diversified investments. In practice, trustees provide benefit projections and handle complaints, as in DDEP where members sought assurances on bond restructurings, aligning with ethical practices for long-term retirement security.
• Employers: Rely on trustees for seamless contribution remittances and scheme administration, reducing administrative burdens. For multinationals like AngloGold Ashanti, trustees facilitate compliance with SSNIT and Tier 2 mandates, ensuring BoG-approved forex hedging for USD-denominated pensions.
• Fund Managers and Custodians: Expect clear investment mandates and collaborative risk assessment (e.g., WACC calculations for valuations). Trustees oversee their performance, as in appointing managers post-recapitalization under BoG Notice No. BG/GOV/SEC/2023/05, promoting profitability through efficient asset allocation.
• Government and Broader Society: View trustees as enablers of economic stability, channeling funds into infrastructure (e.g., via bonds). Post-DDEP, expectations include sustainable banking principles, with trustees avoiding high-risk exposures that contributed to past crises like Capital Bank’s liquidity issues.

In conclusion, trustees’ roles integrate compliance with stakeholder value, enhancing modern banking resilience. Effective execution, as in successful schemes managed by entities like United Pension Trustees, underscores their importance in Ghana’s evolving financial landscape.