5 September 2019
GMP reconciliation has been a long and winding journey – with LCP’s specialist GMP team having reconciled over 140 schemes since it was set up – but we are nearly at the finish line with final HMRC listings due in November 2019. As we take our final steps, the team have been asking ourselves: what have we learnt along the way?
- The size of the scheme does not matter. Some of the smallest schemes had some of the most problematic data – one of the most difficult schemes to reconcile had less than 100 members.
- It is important to keep a thorough record of not just the current members in the scheme, but members who have exited as well, bearing in mind GDPR and all that goes with that.
- Having the right tools can really help, processing became more streamlined over time, with HMRC’s GMP Checker proving particularly helpful.
Most strikingly though, the team has seen the immediate impact that the quality of scheme data makes not only in the ease - and therefore cost - of reconciliation and rectification, but also how data errors or missing data can impact schemes in lots of other areas.
As well as bad data making reconciling and equalising GMP’s more difficult, it can also heavily influence buy-out pricing, other de-risking projects and changes in administrators. Performing some data work before undertaking such projects can significantly reduce costs, and save you time and hassle in the future.
The future pensions dashboard will also require schemes to submit accurate data, so any issues will have to be resolved before any data can be submitted.
We’ve also been reminded by the Pensions Regulator that just because data is there, doesn’t mean that it’s accurate: “Even where trustees are taking action to address the quality of record-keeping it is often limited to assessing the presence of data, rather than quality and timeliness.” This can often be the case with transferred in data, or data from previous administrators, who may have used ‘dummy’ start dates for example.
It’s therefore important to bear in mind:
- The data the scheme has inherited. Don’t assume it’s all correct.
- Data issues can be found in schemes of all sizes so put in place a plan to review your data regularly.
- The role data plays in current and planned projects. Consider the data items needed not just now, but potentially in the future – a bit more work to make sure data is correct now may pay dividends further down the line.
- The increased focus on data quality. The introduction of General Data Protection Regulation requirements and The Pensions Regulator’s guidance on record-keeping have made this a hot topic.
In a nutshell: get into the habit of considering the quality of data. Then the scheme will end up with data that is both present, and correct!