Welcome to our latest edition of our SIPP and SSAS update!


Have you ever been faced with a data subject access request from a disgruntled individual seeking to use data protection legislation as a way of pursuing a dispute about something else?  In this update, we look at the judgment in Lees v Lloyds Bank PLC which considers how the courts should approach this type of situation.  Other cases which we look at include: FCA v Avacade in which the court had to consider the boundaries of regulated activity in the context of unregulated introducers; the High Court ruling sanctioning the transfer of Legal & General's SIPP business to Reassure; and the Supreme Court's ruling in the long running HMRC v Parry litigation.  To read more about these cases and others, click here.


This update looks at the Pension Schemes Bill, the Finance Act and how money laundering legislation which imposes registration requirements on trusts deals with the issue of pension schemes.  Click here for more detail.


There have been lots of FCA-related developments in the past three months.  The FCA section of our update includes developments in relation to FCA fees and levies, the FCA's proposed new requirements for independent governance committees of workplace pension schemes, extension of the implementation period for some aspects of the Senior Managers and Certification Regime, and the FCA's plans for climate risk reporting requirements.  Click here for more detail.

Pensions Ombudsman

Do SSAS trustees have a legal duty to keep minutes of their decisions? How should trustees deal with the situation where death benefits are due, but the scheme is predominantly invested in a single illiquid asset?  Will the Ombudsman make an award for distress and inconvenience against trustees who are entitled to an indemnity under the scheme rules?  These were some of the questions addressed by the Ombudsman in a recent determination.  We also look at two other determinations which illustrate the Ombudsman's approach when a delayed transfer value results in a loss, and another which considers the standards to be expected of a transferring scheme in the period immediately after the Pensions Regulator published its pension liberation guidance.   To learn more about these determinations, click here.

Pensions Regulator

On 16 September the Pensions Regulator updated its COVID-19 guidance to say that from 1 January 2021 the Regulator will revert to expecting pension scheme providers and trustees to revert to reporting contribution payment failures that are outstanding for 90 days, bringing to an end the temporary easement which allowed for outstanding payment failures to be reported at 150 days rather than 90 days. Click here for more detail.


The past three months saw the Government consult on a review of the charge cap which applies where individuals are automatically enrolled into a pension scheme, a call for evidence regarding addressing the discrepancy in tax relief treatment for low earners between net pay arrangements and relief at source, and a call for evidence about pension scams from Parliament's Work and Pensions Committee.  For more on these developments, click here.


In the HMRC section of our Update we cover HMRC's extension of various easements related to Covid-19 as well as developments relating to the Managing pension schemes service.  Click here for more detail.

Other developments

Our Update reports on the Government's confirmation that it intends to raise normal minimum pension age to 57 in 2028 and also looks at PASA's "COVID-19 Guidance: The Road Ahead".  Click here for more detail.

Key contact

Jade Murray

Jade Murray

Partner, Pensions
United Kingdom

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