HMRC Bulk registration of scheme administrator/practitioner

Further to our direct communication to all our customers, Delta is pleased to advise that it has agreed a facility with HMRC, whereby firms holding data in SSAS~Pro will be able to make a single, electronic submission of all the data required to pre-register their schemes prior to A-Day.

This concession is a considerable one, as HMRCs current requirement is that a separate form is completed, signed, and returned for each scheme a firm wishes to pre-register. The information contained here will help our users to understand what is required from them to take advantage of the concession, and what action needs to be taken by when.

Background

Currently, if a Pensioneer Trustee firm has 500 SSASs and wants to pre-register itself as the first Scheme Administrator for those 500 schemes, this would require completing and signing 500 separate pre-registration forms. The concession that has been negotiated with HMRC for SSAS~Pro users is that the relevant data for these 500 schemes can be submitted as a single, electronic data file, which HMRC can then import directly into their new computer system to record those schemes as registered at A-Day, and allocate a new PSTR (Pension Scheme Tax Reference) number to each scheme.

In addition, HMRC require a simple paper listing of all the schemes containined in the electronic file, detailing the scheme name, the current SF reference number, and the Principal Employer name. It is already possible to produce this listing directly from SSAS~Pro - such a listing is required to be sent to HMRC each November in any case, under current legislation, to advise them of the schemes for which your firm is currently a Pensioneer Trustee.

Finally, HMRC will accept a single, signed declaration confirming that your firm is to be registered as the Scheme Administrator for each of the schemes contained in the list and the electronic file.

How will this work?

Between now and Monday 23rd January, we advise you to go through the scheme records you have in SSAS~Pro and update any relevant data (see below). From Monday 23rd January, you (or your internal IT staff) will supply us with a copy of your dataset, in the same way you normally do for a new version upgrade. Delta will then process this data using an internally created routine to extract the data for the schemes concerned into a single data file, in the format required by HMRC.

Delta will create both the electronic file, and the output paper listing of the schemes contained in that file, as required by HMRC, and will then send you a copy of the electronic file for final approval before submitting the file and the paper output directly to HMRC on your behalf.

You will be required to simply complete and sign a single declaration on behalf of your firm in relation to the schemes contained in the file, and send it directly to HMRC. Details of the declaration form, and where to send it, will be confirmed shortly.

Why is HMRC making this concession for SSAS~Pro users?

This concession is in the interest of all parties concerned. For Pensioneer Trustees to fill in, manually, a separate form for each of their schemes will take considerable time and risk manual transcription errors of data that already exists electronically. There is then a similar risk, of course, of HMRC staff also making manual transcription errors when data is entered into their new system.

In addition, because of the work involved, the number of schemes that are likely to be pre-registered in this way prior to A-Day will be lower than if a firm can make a single electronic submission.

Between them, SSAS~Pro users currently administer more than half of all SSASs in existence in the UK, so by providing this concession, ultimately HMRC is likely to achieve more accurate data, for more schemes, more quickly than if PTs fill in a separate piece of paper for each and every scheme.

Which schemes will be submitted in the file?

This is entirely down to your firm. By default, unless you advise Delta otherwise at the time of supplying the copy of your dataset, we will isolate all scheme records where the Include In All Reports field = 'Yes' (located at the bottom of the Scheme Details I screen).

Most of our users use this field to isolate what they deem to be a 'current' scheme, but if you would like us to use another field in this respect (e.g. Scheme Status = 'Current' etc.) then please advise us at the time.

Can schemes be submitted in batches?

Ordinarily, no.

However, Delta is aware that a number of our users have more than one scheme administrator record entred in the User Details screen of the Manager section. This may be for a variety of reasons, including that your firm may consist of more than one Pensioneer Trustee company, e.g. because you have bought or merged with a separate PT firm previously, or because you are permitted to use SSAS~Pro for the purposes of third-party administration (TPA) on behalf of other PT firms as well as your own.

In these circumstances, Delta recognises that you may need to submit one file per group of such schemes (as defined by SSAS~Pro's SA Reference field), because in normal circumstances the Scheme Administrator details will be different. Again, where this is the situation, please advise us at the time of providing us with your dataset.

Can the other trustees be registered as additional Scheme Administrators?

Yes.

Our internal routine to generate the file HMRC need will also take each trustee record whose status = Current, and record them as the second and subsequent additional Scheme Administrators.

Important - because every Scheme Administrator registered has the same status, it is important that you provide the same level of accurate data for the other trustees as you provide for the first Scheme Administrator, i.e. your firm. This includes both name, address, and telephone number data, all of which are mandatory when registering a Scheme Administrator. (Remember that the data for member trustees comes from the data held for each member (see below)).

What happens if there is not sufficient data for some trustees?

We are confirming the situation in this respect with HMRC at the moment. We would hope that where a scheme has sufficient data for say, 2 out of 3 current trustees, as well as correct data in relation to your firm then you would be registered as the first Scheme Administrator and the other 2 trustees for whom sufficient data exists would be registered as the second and third Scheme Administrators respectively. Subsequent trustees, for whom not all mandatory data was supplied would not be registered at this point.

HMRC are still to confirm the situation in this respect, as it is possible that, where one or more of the records for trustees to be registered as a Scheme Administrator has incomplete data, it may prohibit that entire scheme from being successfully pre-registered. We will update this page as soon as we receive clarification from HMRC in this respect.

Can this concession be used to register only as the Practitioner?

No. You can register to be both the first Scheme Administrator for each scheme submitted, AND the first Practitioner, but you cannot use this concession to register ONLY as the Practitioner and NOT as the Scheme Administrator. Again, please advise Delta if you also want your firm to be registered as the first Practitioner, as well as being the first Scheme Administrator, for each scheme.

Remember, under the new legistlation, ONLY the Scheme Administrator(s) can add or remove a Practitioner as being associated to a registered pension scheme.

What data needs to be reviewed to make an electronic submission?

As detailed in our initial email in this respect, you are strongly advised to go through the data for the schemes you wish to pre-register, in order to ensure that it is both as up to date as possible, and correct. Detailed below are the elements of scheme and member (and therefore trustee) data that you should examine prior to submitting the data:

1) A key element of data in this process is the CURRENT registration number for each scheme, previously known as either the SF, PSO or SPSS reference number of the scheme.

The most recent versions of SSAS~Pro have this field labelled as the 'SPSS Reference No.' and this field has been in the format of NNN/NNNNNN/NNNNNN/A where the characters 'N' are numbers and the character 'A' is a letter, e.g. 012/012345/000000/D.

This number is important becuase HMRC will use it to check and 'match' the information you submit, with the information they already hold for each scheme. This information has been in this format for some time now, but just in case, users shoudl check the following aspects of this data item:

• the first data block consists of three (3) numbers, but for most schemes, this number is a number from 1 to 26 (as the old reference number was based on the letter of the alphabet that the scheme name started with) and should thus most likely contain data from 001 through to 026. However, 049 is also a permitted value;
• the second block consists of six (6) numbers, but many older schemes would have had only 5 numbers, so the number 12345 should become 012345, i.e. any number of less than 6 digits should be preceded by the relevant number of leading zero's (0);
• the third block consists of six (6) numbers, and is nearly always 6 zero's unless that scheme had participating employers associated with it from the outset;
• the final block is a single alphabetic character. This will vary from scheme to scheme, and if you have really never been notified of any such letter, it can also have the value zero (0), e.g. if you have a new scheme that has been set up today and not yet reported to HMRC. However, this field should NOT contain any of the following letters: I (uppercase letter i), M, O (uppercase letter o), P, R, T, U, W or Y.

N.B. - It has come to our attention recently that a number or firms may have some records with the last letter still being the capital letter I (i), which is not acceptable to HMRC in this exercise. If this is the case, you MUST change this to the relevant letter you were advised when the scheme was first submitted. HMRC would have sent you first a Reference Advice letter, and then subsequently a Scheme Approval letter, each of which contain the full reference number for that scheme, including the correct last character as a letter. If you have a number of schemes in this situation, please make sure that you go through each and every one of them and first input the correct letter into the last field, as otherwise schemes with the capital letter I (i) will be rejected and not registered when wubmitted electronically through this concession.

2) The data you hold for the Organisation Name, which in this context will be the value in the Principal Employer Name field on the Principal Employer data entry screen.

3) The data you hold for each member that is a trustee, in particular their title, full name, address, telephone number* and email address. All of these items, bar the last, are mandatory when the data is to be used to register current trustees as second and subsequent Scheme Administrators.

* We have been advised by HMRC today (11/1/2006) that in fact, if a telephone number is absent for a record in the electronic file, they will not be too worried about this. However, they are keen to avoid having Scheme Administrator records that consist of only a name, with no address.

For this reason, where any additional trustee record does not contain data in at least both Address Line 1 and Postcode fields, we have agreed with HMRC that (trustee) record will be ommitted from the file entirely by our processing routine (and therefore not registered at this time as an additional Scheme Administrator for that scheme).

4) Finally, you may also want to check the status of each member, as number of current (active, deferred and pensioner) members in each scheme also needs to be submitted when pre-registering each scheme.

Timings

Remember that HMRC require the data for all schemes for this exercise, whether submitted electronically or on paper, no later than Tuesday 31st January 2006.

In order for Delta to have sufficient time to turn around the datasets for users, we need to have your datasets with us no later than Monday 23rd January 2006.

Further information

If you require any further information on the above, please contact michael.power@deltafs.co.uk by email.