Q: Should all types of pension transfer into a SIPP be reported as a separate transaction in PSD (product code 20)?
A: The reporting of Individual Pension Transfers as a separate Product under Code 20 only applies in respect of those that are a 'pension transfer' as defined in the SUP16.11. This is essentially those that involve the transfer of benefits from an occupational pension scheme to a private pension arrangement (eg a personal pension, SIPP or stakeholder pension), which would normally involve the advice of a pension transfer specialist. The definition can be found in the Handbook Glossary[1].
Q: How should income drawdown be reported where a member chooses to withdraw on a phased basis?
A: Income drawdown is reportable under product code 24 when a member exercises the option to take income withdrawals. It is the initial decision to enter into a drawdown arrangement that is of interest to us. The value to be reported should be the amount of the funds the member has elected to put into the drawdown arrangement. If the drawdown is on a phased basis, each individual transaction will not be reportable separately.
If, however, the member elects to enter into a subsequent new drawdown arrangement, then this would be reportable separately.
The definition can be found in the Handbook Glossary[2].
Q: We will always be reporting in respect of SIPPs, which do not have a premium at outset - they are wrappers only. We do not ask clients to commit to making a contribution when they apply - they tend to make them as they go. In that case, will our premium records always be nil?
A: As the PSD Data Reference Guide shows, you will not be able to enter a nil value as the value range is from 1 to 999999999. If for some reason the first premium is zero, please enter a value of 1.
Q: The SIPP transaction details require a premium amount greater than zero. Should each SIPP therefore only be reported when the first contribution or transfer value is received, rather than when the wrapper is established? If so, should the date in force be the date funds are received or the date the wrapper was set up?
A: The date in force should be the date the wrapper was set up. If the first premium is 0 (in such cases where there is no premium at outset), please enter a value of 1.
Q: We understood that pension transfers into a SIPP should be reported as product code 30 as you are interested in the 'new joiners' to the SIPP itself. If this is not the case, do you need us to report under product codes 20 and 30 as it will be a pension transfer into the SIPP?
A: If a pension transfer coincides with joining the SIPP, we would expect it to be reported under both product codes 20 and 30 even if that means some double counting. We are interested in how many people join SIPPs and separately how many pension transfers happen. Pension transfers into existing SIPPs should be reported under product code 20 only.
Q: We have not reported on Income Drawdown previously within a SIPP - this is not a new joiner to the SIPP just a date that the client decides to take an income. Also do we enter this as product code 24? This is with regard to the SIPP and taking income drawdown within the SIPP wrapper.
A: A similar answer applies for income withdrawals (product code 24) as for pension transfers (product code 20). We want to know whenever these happen. It could be under an existing SIPP (just product code 24), or it might happen on joining a SIPP (product codes 24 and 30).
Q: As a SIPP provider do we need to report on underlying investments?
A: The focus for PSD reporting is on the product provider not the asset manager nor any other ancillary or intermediary. If you are the provider of the underlying investment, you will need to include it in your PSD report under the relevant product type.
Q: Where a member is paying irregular contributions should each contribution be reported even though this does not involve the sale of a new SIPP?
A: PSD only includes initial data - with regard to SIPPs reporting we will require you to report data when new members join the scheme. PSD does not include increases in regular premiums, nor does it collect single premiums to existing contracts. Also, it does not include the start of regular premiums under existing single premium contracts.
Q: What do we put in the total premium box for SIPP sales?
A: You should try to estimate the total value of all contributions and all assets transferred into the SIPP, including those investments that would not be classed as 'designated investments' such as property and cash.
Q: We are planning to extend our group personal pension with an insured SIPP option (deferred SIPP). The 'deferred SIPP' can be activated by the member either at outset or at a later date and the member can subsequently switch into or out of the 'deferred SIPP' at any time. How do we report cases where this 'deferred SIPP' option is activated at some point after day 1 in PSD?
- A: Report all new business sales where the 'deferred SIPP' is chosen at outset as SIPPs sales.
- Report sales of personal pensions (where the 'deferred SIPP' is not chosen at outset) as standard personal pension sales.
- No additional reporting will be required if there are switches from the personal pension product to the 'deferred SIPP', or if monies are switched into or out of the 'deferred SIPP' at any point during the life of the plan.