Record-keeping: a consultation document - The Pensions Regulator

Chapter 3: Evaluating the evidence of poor recordkeeping
Summary
• There is evidence of problems with record-keeping.
• It comes from a number of sources including:
o what administrators and others have told us;
o experience during wind-up of independent trustees, the Pension
Protection Fund and the Financial Assistance Scheme;
o from the Pensions Advisory Service and similar bodies
• Legacy data is a particular problem, although problems with current
data are also seen.
Is there a problem?
3.1 The regulator acknowledges that there are schemes and providers which
achieve high standards.
3.2 Unfortunately this is not universal. Information provided to us by
administrators, buy-out providers, independent trustees, the Pensions
Advisory Service, the Pension Protection Fund and others confirms that
there is a problem, and that it extends to all sorts of scheme, irrespective
of size and type.
3.3 The effect is that membership, liabilities, entitlements and payment of
pensions all contain errors. A brief summary of some of the most
common data problems is given below.
3.4 For active members:
• missing contracted out earnings information;
• inadequate records relating to transfers in;
• incomplete records of part-time service;
• inadequate records of pension sharing and earmarking orders.
3.5 For deferred pensioners in DB schemes:
• no split of deferred pension between elements that have different
attaching benefits (for example contingent pensions on death,
escalation in retirement);
• post April 1997 part of deferred pension not recorded;
• incorrect or incomplete GMP details;
• no record of maximum cash entitlement under the scheme rules;
• no record of pre A-Day HMRC maximum cash entitlement.
3.6 For pensioners:
The Pensions Regulator: Record-keeping consultation document
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