Date - 21 March 2022
Request
I would like to know the number of independent trustees appointed by The Pensions Regulator (TPR) in the past five years, and what were the main reasons for these appointments. I'm particularly interested in knowing which of these appointments were related to scam activities.
I would also appreciate if you disclose [sic] the number of appointments by company (ie Dalriada, Pi Partnership Group, 2020 Trustees, etc) per year.
From the number of occasions an independent trustee firm was appointed by TPR due to a pension scam, in how many occasions were the trustee firms able to recoup money and in how many occasions were these funds returned to members of the schemes.
Response
I can confirm that we hold information falling within scope of your request. However, we are unable to supply some of the information requested for the reasons set out below.
Information we are able to supply
- The number of independent trustees appointed by TPR in the past five years, and what were the main reasons for these appointments. I'm particularly interested in knowing which of these appointments were related to scam activities.
TPR have appointed independent trustees 105 times in the last five years, some of which have been bulk appointments to multiple schemes. These are more clearly appointments related to scams activities (suspected fraud) as we carried out full investigations and that was in our reason for appointment. However, there appointments which are possibly scams related, but the appointment was made for other reasons, including s.7(3)(b), concerns around investments, TKU, etc. For these, scams investigations may have been carried out by the appointed IT to deem that they were scams related schemes, but we can’t say they are scams related appointments.
These appointments have covered 573 schemes with approximately 6,337 members in total (over 1,000 of these members are listed against one appointment).
98 of these appointments (93%), covering 560 schemes (98%) with approximately 4,349 members (69%), were appointments made under s.7(3)(b) of the Pensions Act 1995, to secure that the number of trustees is sufficient for the proper administration of the scheme. In practice, this means the majority of appointments made are to schemes where there is no trustee able / willing to act.
Five of these appointments, covering five schemes with approximately 405 members, were related to suspected scam activities.
Membership numbers here are approximate. TPR obtains this data as part of the appointment process and it is often out of date, incomplete, unknown, or estimated. The fact we are appointing an independent trustee means that there have been issues with schemes having no trustees, schemes having governance or record keeping issues etc.
- The number of appointments by company (ie Dalriada, Pi Partnership Group, 2020 Trustees, etc) per year.
Please see the table in Appendix A. There have been no appointments made in March 2022 at the time of supplying this data.
- From the number of occasions an independent trustee firm was appointed by TPR due to a pension scam, in how many occasions were the trustee firms able to recoup money and in how many occasions were these funds returned to members of the schemes.
These are the appointments we are more confident in saying relate to scams (potential fraud).
| Date of appointment | IT appointment name | Appointed IT |
|---|---|---|
| 30 August 2017 | Project Victor |
Independent Trustee Services Ltd |
| 10 January 2018 | Project Victor |
Dalriada Trustees Limited |
| 13 February 2018 | Project Blackbird |
Dalriada Trustees Limited |
| 19 April 2018 |
Embolden Executive Pension Scheme |
PS Governance Services Ltd |
| 4 December 2019 | Special Procedure Request November 2019 |
Dalriada Trustees Limited |
Information we are not able to supply
- From the number of occasions an independent trustee firm was appointed by TPR due to a pension scam, in how many occasions were the trustee firms able to recoup money and in how many occasions were these funds returned to members of the schemes.
We do not hold information about post appointment recoveries.
Appendix A
The number of appointments by company (ie Dalriada, Pi Partnership Group, 2020 Trustees, etc) per year
| Independent trustee | Mar 2017 to Feb 2018 | Mar 2018 to Feb 2019 | Mar 2019 to Feb 2020 | Mar 2020 to Feb 2021 | Mar 2021 to Feb 2022 | Total |
|---|---|---|---|---|---|---|
| 20-20 Trustee Services Limited | 4 | 6 | 2 | 2 | 3 | 17 |
| Capital Cranfield Trustees Ltd | 6 | 10 | 5 | 7 | 28 | |
| Dalriada Trustees Limited | 4 | 3 | 3 | 2 | 12 | |
| Independent Trustee Services Ltd | 1 | 1 | ||||
| Lyons Davidson Trustee Company Ltd | 21 | 7 | 28 | |||
| Open Trustees Limited | 2 | 8 | 1 | 2 | 13 | |
| PAN Trustees Ltd | 1 | 1 | ||||
| Pi Consulting (Trustee Services) Ltd | 3 | 3 | ||||
| Punter Southall Governance Services Limited* | 1 | 1 | ||||
| Ross Trustees Services Limited | 1 | 1 | ||||
| Total | 33 | 23 | 23 | 14 | 12 | 105 |