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Union Capital Investment Bank · Accra
Pensions Briefing

Tier-3 Provident Funds: What Trustees Should Review This Year

By Adjoa Owusu-Takyi · Union Capital Research
In short

Trustees of Tier-3 provident funds should review their investment policy statement, benchmark suitability and fee transparency annually — and confirm their manager reports against NPRA-aligned mandates.

Voluntary Tier-3 contributions have grown as employers use provident funds to attract and retain staff. With that growth comes a sharper duty of care for trustees.

Three questions for your manager

First, does the investment policy statement still match the membership's time horizon and liquidity needs? Second, is the benchmark the right one, or a legacy default? Third, are all fees — management, custody and transaction — disclosed in a single, comparable figure?

Governance cadence

We recommend an annual review of the policy statement and a quarterly performance and compliance report aligned to NPRA guidance.

Questions

Related questions.

How often should a Tier-3 scheme be reviewed?
We recommend a full investment-policy review at least annually, with quarterly performance and compliance reporting in between.
What is the difference between Tier-2 and Tier-3?
Tier-2 is the mandatory occupational scheme; Tier-3 is voluntary. Both can be professionally managed, but Tier-3 offers more flexibility in design and contribution.

Apply this to your portfolio

Speak to a Union Capital advisor about what it means for you.