Agenda item

Report of the Chamberlain

The Chairman introduced the report relating to a range of topics in the Police Pension Scheme that included the suite of documents requested at the last meeting.

The report outlined the following items for the consideration of the Police Pensions Board:

Annual Schedule of Events for the Pension Scheme

The Board considered the annual schedule of events relevant to the Police Pension Scheme and noted that all deadlines are currently being met. The Chairman suggested that the Board should provide an annual report to the Police Committee and it was agreed to add this to the Annual Schedule of Events. (1)

Annemarie Allen suggested that the requirement to issue Pension Savings Statements by 6 October be added to the Annual Schedule and it was agreed to do so. (2)

Information on Scheme Record Keeping

The Chamberlain explained to the Board the extent of member data maintained with reference to Appendix 2.  The information outlines the comprehensive range of member data held for members of the Police Pension Scheme, including personal details, contribution records, nomination details, pay and information on leavers/deferred and pensioners.

The Board was advised that the Pensions Team carry out regular data accuracy checks as part of the annual updates procedure. They also use a mortality screen service, issue annual life certificates to those living abroad and participate in the National Anti-Fraud Network (NAFN).  This ensures compliance with regards to deaths, re-employment with another police authority and injury pensions where an injury benefit is being paid by the State.

The Board requested that a table showing membership numbers by category of membership be provided. (3)

The City of London Police Pension Scheme Risk Register

The Board considered the Risk Register, and a Member suggested that for Risk 3 (Pension Scheme Administration), the Causes should be separated into two separate Risks – one for succession planning/ training and one for IT. It was agreed to update the Risk Register. (4)

Documentation and communications that are circulated to Scheme Members

The Board considered the documentation circulated to scheme members for the current Pension Scheme introduced on 1 April 2015, as well as its preceding Schemes introduced in 2006 and 1987 (Appendix 4a, 4b, 4c). 

Communication Working Practices

A Member requested reassurance that data held on scheme members with deferred pensions is being monitored accurately.  The Pensions Administration Manager advised that the Police Human Resources Department notify the Pensions Office of any officer leaving the Force and they in turn calculate the benefits at leaving and send a statement to the ex-officer. 

A Member re-emphasised their concern regarding the maintenance of personal data for ex-officers and queried if ex-officers would know that it is their responsibility to inform the Pensions Office of any changes.  It was agreed that the letter sent to officers would be reviewed at the next meeting.

A Member questioned whether there were any plans to move towards email rather than relying on post to distribution communications.  The Chamberlain explained that this infrastructure is in place for overseas members.  However, it was highlighted to the Board that whilst e-mail was a quick and efficient form of communication, individuals do change their e-mail addresses and unless they advised the Pensions Office of such changes, it could become difficult to remain in contact with scheme members.

A Member asked for the number of deferred scheme members currently held by the City of London Police.  Officers noted the number was approximately 700.

The Board considered if there was a risk relating to the gap between those members paying in to the scheme and those being paid out.  The Chamberlain advised that any shortfall is effectively funded by the Government and there is limited risk to the City..

The Board considered Appendix 6, which provided examples of the various letters and statements sent to officers throughout their membership to the Pension Scheme.  It was noted that no example of an early leaver deferred benefit statement was included and it was requested that such a letter be provided to the Board at the next meeting. .

Under the terms of the 1987 Scheme, widow(er)s pensions cease if the recipient re-marries or co-habits with a new partner .  A concern was raised as to whether or not there are any ethical implications in seeking evidence of “lack of entitlement” from such scheme members. However, it was noted that there is a legal obligation to uphold the Regulations.

The Board agreed that correspondence sent to scheme members must be clear that the Pension Scheme Administration can only  provide facts, and is not able to provide advice as this would breach legislation. 

RESOLVED – That amendments should be made to include a standardised text disclaimer within all the relevant literature to clarify the position that the Pension Scheme Administration can only provide facts and is not permitted to provide advice, but rather to recommend scheme members seek it elsewhere. The wording to be used should be considered by the Comptroller & City Solicitor.

The Board considered Appendix 6i – “Opting out of the POLICE PENSION SCHEME 1987 (PPS 1987)/ POLICE PENSION SCHEME 2006 (PPS 2006) / POLICE PENSION SCHEME 2015 (PPS 2015)” with regard to point 9 - “Enjoy a better quality of retirement” being  a reason for remaining a member of the Police Pension Scheme.  The Board agreed that this comment would qualify as subjective advice and is a value judgment and should be removed.

The Board agreed that point 9 in Appendix 6i – “Opting out of the POLICE PENSION SCHEME 1987 (PPS 1987)/ POLICE PENSION SCHEME 2006 (PPS 2006) / POLICE PENSION SCHEME 2015 (PPS 2015)” should be removed.

The Board considered Appendix 8 (Audit Reports) and it was noted that in the final paragraph the text should read “2018” rather than “2108”.