Customer Forum - Minutes of the Eighth Meeting

Contents

• Attendees
• Minutes of last meeting
• Introduction of the new Director of SPSS
• SIPP Audits etc
• Single Gateway & Elections Transfer
• Reclaim of Overpaid Rebates
• The Year so far . . .
• Miscellaneous News
• Integrated Stakeholder/Personal Pension Model Rules, Updates, Customer Service etc
• Any other business

1 - Attendees

2. Minutes of last meeting

The minutes of the last Customer Forum held on 21 May 2002 were agreed.

3. Introduction of the new Director of SPSS

Caroline Rookes briefly explained that in her role as the new director of SPSS she had responsibility for Pensions and Savings Policy, Share Schemes, Savings and Pension Schemes Technical Advice and Services and Audit and Pension Schemes Services. She was responsible for the effective management of the business, delivering results and setting the strategic direction. She was aware that the Department needed to be more customer focussed and this Forum provided an opportunity to encourage dialogue and take this forward. In particular it was important to ascertain what the customer wanted from us.

In response to a question about the position on Simplification, Caroline said she was not able to say anything about the content of the proposed paper at the present time nor could she indicate the timetable for publication of the consultative document.

4. SIPP Audits etc

Rob Smith gave a progress report on the proposed audit of SIPPs. Letters had been issued to 84 providers and 20 had responded to date. He had been to see 4 of them to carry out a help visit. The purpose of the audits was to look at investments and the use of scheme funds to ensure there was no leakage for unauthorised purposes. A number of pilot audits would take place commencing in January 2003 to determine the terms of the full audits. Those selected for a pilot audit would not also have a full audit during the first cycle of audits. The cycle would probably take 3/4 years to complete.

Other matters:-

• The Large Self-administered Scheme audits are running behind those for SIPPs. Objectives are now in draft and it was proposed to run them past a sample of providers shortly.
• There was no change in PP and FSAVC audits. However, an IR 76 update due in March/April 2003 will incorporate the new simplified recovery procedure and post 2001 audit objectives.
• Checks were being made of the end of year tape for PPs to validate data against providers records.

5. Single Gateway & Election Transfer

Jim Kitson advised the Forum that the operational work involved in electing to contract out currently dealt with by NISPI in Newcastle will be transferred to Nottingham from May 2003. This work includes maintenance of contracting out scheme information but all other contracting out work done in Newcastle remains unaffected and there is no change to policy and technical advice arrangements. The aim in the first instance will be to ensure continuity of service but the change provides a platform for future improvements in service. One of these is developing a 'single gateway' process to give a joined up scheme registration system between APSS, Opra and NISPI (formerly COEG) based in Nottingham. This has been successfully piloted. One of the lessons from the pilot was the need to allow adequate time to consult and design forms and systems. With this in mind the lead in time for changes will be April 2004.

The pilot exercise is ongoing and has shown a number of benefits:-

• A streamlined process for scheme registrations.
• One port of call for customers to provide information.
• A reduction in the amount of duplicate information needed to be provided by customers.
• Better information being held by Government, reducing unnecessary contact with customers.

6. Reclaim of overpaid Rebates

Ann Storey explained that NISPI were dealing with the problem of overpaid rebates in relation to both personal and occupational pension schemes. All the companies concerned had been contacted and matters were being discussed with the ABI to agree an acceptable way forward.

7. The Year so far . . .

Ann Walker explained that since she took over in April 2001 she had been reviewing everything in her area with the aim of identifying

• Is it still relevant?
• Is it still the best/most efficient/cost effective way of doing it for the customer and IR?

She then gave an overview of what had been done so far in the current year.

Customer Liaison Managers

The appointment of two Customer Liaison Managers, Alec Humbles and Terry Maddocks, to act as a single point of contact between customers and APSS. On 19 September a meeting was held with representatives from APSS's top ten correspondents (in terms of volume) to establish exactly what they wanted in terms of the single point of contact. Two themes that emerged from the meeting were that the IR did not understand their business and the way the IR communicated with the industry was inconsistent, confusing and did not make good use of electronic communication. She explained what had been agreed:

• Alec Humbles and Terry Maddocks would act as Gateway to the Revenue for those involved in the pilot initially.
• They would not deal with issues that were being dealt with elsewhere unless there was a problem that the customer could not resolve or no progress was being made.
• A list of contact names has been established for Alec and Terry to use when the IR has problems with one of their companies.
• Alec and Terry have already successfully dealt with a number of issues that arose at the meeting and they will deal with the remainder in due course.
• An evaluation of their role will be carried out at the end of January 2003 to determine its success and to consider whether it should be extended.

Subsequent to the meeting the following action has been taken:

• In order that the IR might start to understand its customers Alec and Terry will be visiting two of the organisations represented early in the New Year.
• A communication review is currently being carried out under the direction of Martyn Rounding, APSS (Technical).

Risk Intelligence Analysis Team (RIAT)

A Risk Intelligence Analysis Team has been set up to:

• Make better and more effective use of information received by the Office.
• Improve the identification of risk.
• Provide greater integrity in the selection of cases for enquiry by removing case selection from the enquiry officer.
• Tackle the highest risks both to the Exchequer and IR business.
• The moving more and more to self-certification and process now check later means APSS will be doing sample checks to establish what the risks are and therefore what level of compliance activity is required in particular areas.
• Identify problems and where appropriate identify practitioners who appear to be causing problems for APSS. Depending on the nature of the problem there will be a range of solutions. The starting point will be to pass it to Alec and Terry to find out what the problem is. They will then feed this back to the RIAT to consider whether the problem is caused by
  • IR processes, in which case they will be reviewed, or
  • An education need, in which case it will be referred to Les Shaw's education team, or
  • Is it the legislation/practice that is difficult/impossible to comply with, if so, they will feed this into Martyn Rounding's technical team which in turn will enable them to feed into policy, or
  • Is it systemic and therefore is audit appropriate, or
  • Is it the fact they simply do not want to comply, then the IR will move into regulatory role as a last resort, instead of the first as in the past?
• · Deliver better policy and compliance across the range of pension products.

Review of the approval of Pensioneer Trustees

Ann has instigated a review to:

• Identify the intended purpose of giving approval.
• Establish what APSS and other stakeholders want it to achieve.
• Determine who all the stakeholders in this process are.
• Consider how non-compliance or unsatisfactory behaviour should be handled.
• Look at how the process might be made as efficient and cost effective as possible for all concerned.
• Create a process with integrity and one in which all stakeholders have confidence.

The review commenced in the late summer and consultation with the APT and others has just started. The report is due by the end of December 2002.

Update 69

Work on the non-compliant cases had started but it was discovered some of the lists of compliant Pensioneer Trustees are not up to date or correct. APSS are about to review the whole process to make sure the non-compliant are tackled correctly and effectively in a structured way. All cases prepared for enquiry will be reviewed to ensure they are Update 69 compliant.

Internal Liaison

Steps are being taken to improve communication between the many different areas of the Department involved in pensions work. This will enable APSS to provide a better service to its customers.

External Liaison

This point has been raised at several meetings in recent months. Unfortunately the extension of the IR's current facility for people to have external e-mail is on hold pending a decision by the Board of Inland Revenue. Of particular concern are security and managing customer expectations.

Improving Advice

The IR, of which APSS is a part, is moving towards an improved electronic knowledge management base across the whole area. It is hoped that this will go some way towards improving the quality and the consistency of IR advice.

Helplines - APSS are continuing to try and improve the quality of service provided by its Helplines.

Ann was advised that there were problems with the RIAT in that it appeared to be making up the rules as it went along, eg needing to request accounts to verify whether a company was in fact trading. Ann asked that specific details were sent to her and she would look into it.

8. Miscellaneous News

Les Shaw spoke briefly about a number of issues:-

• Clarity of Writing - The first quarterly sample had been scored and showed a consistent approach in terms of layout, plain English etc.
• The booklets PSO 1, 2 and 3 had been incorporated into the mainstream of IR publications and consequently redesignated as the IR 2, 3 and 7 respectively. There were no material changes to the content of the booklets. The IR 2 and 3 were available on the IR website and in paper format whereas the IR 7 remained available on the 'web' only.
• Interest on loans from pension schemes to companies wef 1.10.2002 - apologies were made for the short lead in time between reminding people of the change effective date and its coming into effect.
• Unintended payments of pension - it was confirmed that it was possible to recover PAYE even if the pension payment was not recovered.
• Customer Survey - this had been started by the consultants BMRB but there were indications from some of those present that the initial contact had not been followed up. Les confirmed that he would chase up the researchers on this point.
• Customer Forum - the Forum had now been going for a number of years and it was time to evaluate how it was doing. Volunteers were sought to suggest better Terms of Reference and how the Forum should go forward.

9. Integrated Stakeholder/Personal Pension Model Rules, Updates, Continuous Service etc

Martyn Rounding gave an update on the following points which were ongoing in the APSS (Technical) area:-

• Integrated SH/PP Model Rules - following consultation the responses had been analysed in conjunction with DWP. It was now intended to put them out again for consultation with a view to getting them published early in the New Year.
• Model rules for conversions - it was confirmed that there was no current intention to provide model rules for conversion cases.
• Publications - it was proposed to carry out a review of how we currently produce Pensions Updates and other information provided to practitioners (eg IR12 and IR76) and in particular whether APSS should move to just an electronic delivery of these items. Martyn invited comments both on whether people would be happy with only an electronic version of these items and on what format would be preferred for electronic delivery. There were no objections to moving to a purely electronic delivery.

In response to a question concerning the delay between finalising Updates and publishing on the 'web' Martyn advised that this was due in part to the terms of the publication contract.

• Continuous service - the form PS 155 was introduced in July 2001 (Update No 101) to clarify this difficult area. The position has been monitored since then and it is appreciated that there may be some areas where the position may be changed. We are therefore reviewing the position to see whether there are any minor changes that can be made. Any changes must be seen in the backdrop of Simplification and therefore it is not proposed to undertake any major reforms at present. The proposed changes have been put to the JWG and the APT for comment and it is hoped to publish an Update early in the New Year.

10. Any Other Business

The following points were raised:-

• Ian Neale raised the question of inconsistent replies to enquiries and suggested that updating the Pension Schemes Instructions (PSI) would assist in clarifying the Revenue's position. In response Martyn Rounding said that integrated instructions may be the answer but there was a significant resource implication and Simplification may affect the position. In the meantime knowledge management as mentioned by Ann Walker may help to reduce such instances.

  Les Shaw commented that knowledge management and internal communication problems commonly arise when someone in SPSS realises that a particular change is going to affect lots of people. The question is how should this be communicated and to whom, internally, in order that everyone who needs to know is informed?

• Mark Howard asked if SPSS would agree a rule amendment to allow early retirement in the wake of Venables, suggesting that such a case had recently been agreed. Martyn Rounding replied "no" and in any event Venables had not yet reached a conclusion.
• Mark Howard asked about the issue of NICs on FURBS. Les Shaw confirmed that NICs are chargeable on employer contributions from 6.4.98 but that following the Tullet & Tokyo Forex case the legal position was unclear and the Revenue was taking counsels opinion. However, he confirmed that some clients had had refunds.*

(*Subsequent to the meeting the Revenue made it clear that their view was that such payments were erroneously made. The Revenue view is that Class 1 NIC liability does arise on payments into FURBs.)

• Mark Howard asked if the current review of the form PS 155 (continuous service) would cover aggregation. Martyn Rounding advised that it probably would not.
• Chris Fox enquired whether the continuous service review would cover situations where directors have a brief overlap of directorship in the old and the new companies. Martyn Rounding confirmed that it would.
• Roger Lewry asked whether the minimum age for taking non-Safeguarded Rights under a Pension Credit was 50 or 60? Martyn Rounding said that SPSS were clarifying the position with DWP. Ian Long representing the ABI confirmed that this issue had been raised via the JWG.

11. Next Meeting

The next meeting was scheduled for Tuesday 20 May 2003 (venue to be confirmed).