Customer Forum - Minutes of the Seventh Meeting


Contents

1 - Attendees

Jayne Banner

Pension Schemes Deputy Director Audit & Pension Schemes Services (APSS)

Paula Diggle

IR London Head of Savings & Pensions Policy

Derick Kielty

IR APSS Head of Audit Unit

Les Shaw

IR APSS Customer Services & Learning Team Leader

Ann Walker

IR APSS Pension Schemes Services Manager

Martyn Rounding

IR APSS Head of Pension Schemes Technical Advice (PSTA)

Alec Humbles

IR APSS Pension Scheme Services (PSS)

Terry Maddocks

IR APSS Pension Scheme Services

Rob Smith

IR APSS Nottingham Audit

Paul Blackwell

IR SPS Bootle Technical Advice

Ian Long

Norwich Union/ABI

Debora Tullett

Mercer/PRAG

Liz McQuater

KPMG

Liz Hinchliffe

SPC/Scottish Amicable

Ian Neale

Aries

Teresa Preece

Mercers

Pete Cottingham

Prudential

Andrew McCrindle

Prudential

Diane Brown

Shoesmiths/Law Society

Mark Timmins

Shoesmiths/Law Society

David Seaton

James Hay Pension Trustees/APT

Joy Lewis

Clifton Asset Management Ltd

Colin Burgess

Legal & General

Les Shaw welcomed everyone to the Customer Forum. As there were attendees who were not present at the last Customer Forum, all those present gave introductions and a brief outline of roles.

2. Minutes of last meeting

The minutes of the last customer forum held on20 November 2001 were agreed.

3. Re-organisation

Jayne Banner gave a brief explanation of the recent and impending changes within Savings and Pension Scheme Services (SPSS). Roger Hurcombe was shortly moving to a new job and the new Business Director of SPSS would be Caroline Rookes. However, following Barbara Nesbitt's recent move Roger had taken the opportunity to adopt a more co-ordinated and flexible approach by merging PSTA within APSS. This also benefits from economies of scale. Jayne Banner would now be accountable across the whole of APSS for technical and operational work.

Derick Kielty explained the work of the Audit team which consists of some 100 staff based in several locations around the country. They would soon be embarking on a pension scheme audit programme. The first of two new initiatives will cover SIPPs. Rob Smith (0115 974 1495) explained that he and his colleague Eddie Griffin from Bootle (0151 472 6041) would arrange meetings with some of the SIPP providers to develop their audit proposals. The second initiative will cover large self-administered schemes (LSAS). This will be a more complex situation given the huge number of schemes and the requirement to establish the legal administrator. Rob was open to suggestions on the best way to take this forward. The Forum suggested he contact David Astley of NAPF who would be able to provide general information such as scheme numbers and size of membership, possibly trustee and perhaps legal administrator names. Ultimately Rob's intention was, once again, to hold bilateral meetings with LSAS administrators to establish the audit programme. The main aim of each initiative is to try to help schemes "get it right first time".

Ann Walker explained that, following the last Customer Forum and their request for dedicated contacts, she had appointed 2 customer service liaison officers within PSS, Alec Humbles and Terry Maddocks. Their roles will be to act as single points of contact for customers, offering a one-stop service. Part of their job will be to understand the customer needs and identify why there are problems, if any. To deliver the kind of service, how and when they want it, Ann proposed setting up a working group to establish exactly what was required, not what the Revenue think they wanted. She suggested, as a starting point, they offer this service to the top ten correspondents (on volume of correspondence received). (Sub- sequently, in discussion at the end of the meeting, it was felt that the views of a small provider might be useful also: Merchant Investors was suggested.) They will be invited to send representatives to the workshop. The Forum indicated their agreement to what was proposed and suggested possible contacts for each of the following organisations.

Organisation

Contact Point

Scottish Equitable

Stan Cook

Axa Sun Life

Tony Tollerton/Colin Griffin

Norwich Union

Ian Long

Prudential

Pete Cottingham

James Hay

Chris Terrey at Bolton

 

Lucy Matthew at Salisbury

Mercers H R Consulting

Teresa Preece

Legal & General

Colin Burgess

Scottish Widows

Ian Allan

Standard Life

Cathy Robertson

National Mutual

Nick Westgate (established later)

Merchant Investors

Phil Tomlinson

Ann said that once it had been agreed what was required, this would then be piloted and evaluated. After that it would be extended, if appropriate. Alec (0115 974 1637) and Terry (0115 974 1704) would make contact with the named individuals.

4. SPSS Business Plan for 2002/03

In introducing the SPSS business plan, Jayne Banner focused briefly on the main priorities. SPSS aim to develop a strong customer focus based on customer needs. New policy development and deliverables included simplification, annuity changes and extension of the Single Gateway. In addition, SPSS would continue to improve our core business approvals, technical advice and pro-active education in the industry. The new Audit programme of proposals should encourage and lead to better customer compliance. Finally, participation in the Better Quality Service Review should determine whether we are carrying out our business in the best possible way.

5. Progress on Simplification

Paula Diggle gave a brief progress report on the three strands of simplification. The independent Sandler Report on the market for savings products and the Pickering Report covering DWP regulation of pensions were expected to be published before the summer recess. It was difficult to forecast when the Revenue's internal review of taxation of pensions would be published but it would probably be later. Alongside simplification, the emerging conclusions would stress the value of financial education, and of saving to provide pensions, as soon as possible and at as early an age as is feasible or practical. It was emphasised that all 3 reviews were sharing information to ensure a joined up approach will be taken.

6. Block Transfers

Ann Walker reported that she had reviewed the APSS block transfer processes and the automatic issue of a request for a completed scheme wind up notification (form PS199) when it was not always appropriate. This had been rectified and should not happen again.

7. AVR Changes

Ann Walker asked if there had been any problems to report with the new process, even though it was still early days following the AVR reminder changes. Everybody confirmed there were no problems.

8. Clarity of Writing

Les Shaw explained this was a Revenue wide initiative to improve the quality of our customer service. The aim is to at ensure our written replies are sensible, well produced and answered all of the issues. Paul Blackwell did a pilot sample in Bootle and found there was a training need there. "Nottingham" had not yet embarked on this, but the Forum should let Ann Walker or Les Shaw know about any problems or concerns in this field.

9.Tax Return SA 970

Tax Returns, SA 970 for self-administered schemes were issued by the Tax Offices each year. Les Shaw acknowledged that these Returns are not being issued for all appropriate schemes. He is liaising, as necessary, to rectify the position and provide a better joined-up service. He also acknowledged that on occasions incorrect "Trust" versions of the SA forms are issued. He would welcome any feedback or suggestions on this.

10.Re-write of Booklets PS01 and PS02

Les Shaw said APSS realise that the published booklets PSO1, Occupational Pension Schemes - a guide for members of tax approved schemes - and PS02 - the equivalent for personal pension and stakeholder pensions - need to be revised and brought up to date in areas such as limits etc. Once again, any feedback or suggestions on this would be most welcome. When the job has been completed, the booklets will be re-numbered in the "IR Leaflets" series. This also applies to the PSO3, Occupational Pension Schemes - a guide for trustees of Small Self-administered Schemes, - though this is only available on the Internet.

11. Model Limits Rule PS 123

Martyn Rounding announced that the Model Limits Rule PS 123 would be put on the Internet shortly. It will include two changes. The definition of Final Remuneration would take account of changes announced in Update 110 regarding paid Maternity Leave and Share Incentive Plans. And, secondly, in relation to our transfer certification requirements we no longer require lump sum certificates for transfers to a personal pension for anyone over age 45. We do, however, still need a certificate for controlling directors, irrespective of age. There is a relaxation for people with earnings in excess of the CAP, as we only go back into their earnings history 6 years, instead of 10, and we are now concerned only if they are aged 45 or more. Martyn would establish the date of installation of the Model Limits Rule on the Internet.

Given that people in PSTA are not lawyers, Martyn said it would be helpful to receive, and he and his team would be happy to look at, any suggestions covering the wording for the Model Limits Rule or any other future changes.

The Forum wondered if there were any plans to provide Model Rules for Chapter I to Chapter IV conversions as there had been differing views on the matter emanating from the Revenue. Martyn said he would need to take the point back to consider the matter.

Ian Neale raised the problem of earnings v receipts basis for the definition of Final Remuneration which he felt had not been finally put to bed. David Seaton was concerned about problems with continuous service. Martyn suggested that in areas such as these, where people perceived that our practice may not seem to follow a reasonable and common sense approach or were technically inaccurate, the Forum should let him know.

Liz Hinchliffe highlighted concern over the need for APSS to be given the value of the fund both before and after the change before considering a request for a change of normal pension age, as very often this was a difficult and time-consuming task. Ann Walker said she would look into the matter.

12. Consultation on Draft Pension Updates

The Forum enquired about the feasibility of extending the scope for more consultation on draft Updates. Ann explained that there was already some consultation, albeit currently on an ad hoc basis but for various reasons such as confidentiality, timing etc, this was not always possible. The Forum accepted this. Nevertheless Martyn and Ann would review the whole question of consultation to try to ensure consistency of approach.

There was also some concern that some decisions were not published widely eg consultations taken up by ABI/APT but not publicised beyond the professional body's membership. Martyn indicated that APSS needed to manage the consultation process to ensure the most practical result. However, when decisions were made public, they should be widely broadcast. The placing of FAQs on the Internet may be a useful tool in certain circumstances.

There was unanimous Forum agreement that Update No 132, Improper Transfers - Trust Busting was a good example of a well-produced Update.

13. Update on the Pilot Study (Gateway)

Historically, the Single Gateway pilot was started to provide customers with a single point in Government for tax approval, Opra Registration and election to Contract Out. It was started as a limited trial, but the initial pilot was extended from 1 March 2002.

The original participants were

  • Legal & General
  • Scottish Amicable
  • James Hay

These were joined in March by

  • William Mercer
  • Prudential
  • Norwich Union
  • HSBC

At present, we have received over 200 applications and several thousand pieces of maintenance through the gateway. Work is now being received from the new providers.

Work is continuing on amalgamating common SPSS and NICO forms to be used only through the pilot gateway address. These are the

  • PS256 - Principal/Participating employer changes - All schemes
  • CA7310 - Change of scheme and/or employer's name/address

  • PS257 - New principal employer
  • CA7311 - Change of principal employer

Other forms have little, if any, communality and therefore will not be amalgamated.

For the future, success criteria has been agreed with the participants.

It is proposed to evaluate the extended pilot in June 2002, providing there has been enough volume - otherwise it will be extended until September 2002. A report will be completed by the Project Contact, Stuart Cockayne (0115 974 1593).

14. Focusing Pension Scheme Experts

Les Shaw acknowledged that the accuracy of advice/guidance on pension scheme matters from the various IR network offices could vary widely. Some "experts" had been trained in this field but the movement of staff had resulted in an uneven coverage of expertise across the country. Les was liaising with the network to rectify the problem. In the meantime he would be happy to receive information and details of specific instances to assist him in this process.

15. Changes of Scheme Year and Policy on Tax Returns

Ann Walker reported that originally Self-Assessment Tax Returns had to be completed on a fiscal year basis. However, following industry representations for a concessionary basis, the Revenue did allow an easement whereby the return could be completed on an accounts basis. This easement was given on the understanding that, if the accounting year changed, then the return must be completed on the fiscal year basis thereafter.

16. Any Other Business

  1. Teresa Preece referred to a problem with overseas transfers and the guidance published in Update No 82. She agreed to speak to Martyn separately about the particular case.

  2. Les Shaw would welcome from the Forum any "whistleblowing" information about parties involved in improper transfers covered in Update No 132. For obvious reasons the Revenue were unable to provide details of what information they currently have on this.

  3. Les Shaw announced an intention to change the content basis of APSS customer satisfaction survey questionnaires so that more meaningful, and statistically valid results, could be achieved.

  4. Due to the high (and rising) costs of provision of information in paper format, Les Shaw would be pleased to receive any comments and views on delivery in other than paper format.

17. Next Meeting

The date has been changed to Thursday 14 November 2002. The venue will be Room 116 New Wing Somerset House.

 

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