Agenda item

This report provides an update on previous report to the Pensions Board on the requirements of The Pensions Regulator in relation to the scheme’s record keeping plan and the current status of annual benefit statements.  This is in view of previously reported breaches of statutory regulations and the significant data issues that have been identified as a result.

I have attached appendices A to D to the main report.

Members considered a report that provided an update to previous report to the Pensions Board on the requirements of The Pensions Regulator in relation to the scheme’s record keeping plan and the current status of annual benefit statements.  This was in view of previously reported breaches of statutory regulations and the significant data issues that had been identified as a result.

Mr Ravinder Jassar (Head of Finance) informed the Board that following the submission of the Record Keeping Plan presented to the Pensions Board on 21 November 2017, The Pensions Regulator wrote to Brent on 29 November stating that the plan did not meet the standards expected as set out in their guidance and therefore adherence to the regulations (Public Service Pensions (Record Keeping and Miscellaneous Amendments) Regulations 2014). The Regulator recommended that their letter be shared with the Board to ensure they were fully aware of the Regulator’s expectations in regards to the scheme’s record keeping and the steps the scheme manager was required to take to address the problem

Mr Jassar clarified the areas in which The Pensions Regulator highlighted that the Record Keeping Plan did not meet the standards expected as set out in their guidance.  The Pensions Regulator expressed the following elements to be incorporated in the improvement plan:

·         Clear objectives, in order of priority, on how Brent intended to achieve improvements in data,

·         Clear outcomes that would be achieved based on the objectives set, including how they would be measured and how long it would take to achieve them

·         Clearly set out the scope of improvement work

·         A breakdown of activities the scheme administrator would undertake on behalf of the scheme manager, including methodology used, resource allocation, timescales and success criteria.

·         A timeline that sets out key milestones, reporting and decision points.

Mr Jassar updated members that the revised record keeping plan was submitted to the Regulator, as set out in appendices attached to the report.  Officers then  met with the Regulator on 22 January 2018 to discuss the record keeping plan and actions being taken to address the data issues.  Initial feedback was positive and further checkpoint meetings were planned over the next six months to monitor progress against the plan.  He added that Capita had made significant progress in issuing the remaining annual benefit statements and additionally, Brent had commissioned a specialist tracing company to locate and contact the deferred members who had changed addresses but had not informed Brent for their records to be updated.

Mr Jassar continued that the Council had also improved the layout of the external website, linking the Pension’s webpage to the Pension Board’s democratic services webpage to ensure all relevant information could be easily identified by members and interested parties.  Other useful information had also been added including the Pensions Administration Strategy, the Funding Strategy Statement, the Investment Strategy Statement and actuarial reports.

Members enquired as to the reasons why Brent failed to meet the requirements of the Pensions Regulator as outlined in their report and did not get it right the first time.  They also expressed a view for sanctions to be applied to those employers who failed to comply with the requirements.  In response Mr Jassar stated that the reason for not getting it right the first time was that the Regulator’s guidance was not adequately followed, which clearly required more specific information in terms of timelines, milestones, dependencies and success criteria.  The various issues are now well understood and have been clearly documented in the revised Record Keeping Plan.  Officers will also explore the use of sanctions for non-compliant employers as part of a wider review of the Pensions Administration Strategy to be undertaken in 2018/19. 

RESOLVED:

(i)         That the updated report on the Pensions Regulator’s Record Keeping Plan be noted;

(ii)       that officers be requested to investigate possible sanctions that could be applied to participating employers that failed to comply with the statutory regulations;

(iii)      that a progress report be submitted to a future meeting of the Board.