Agenda item

This paper details why there is a requirement for a pension administration strategy for the Hammersmith & Fulham Pension Fund and Appendix 1 details the revised strategy.

Eleanor Dennis (Head of Pensions) introduced the revised 2022 Pension Administration Strategy (PAS) for the LBHF Pension Fund. 

Noting that some employers not providing the required information were schools, Iain Cassidy was keen to ensure the liaison with schools would not cause any reputational risks to the Council. Eleanor Dennis noted that her team mainly liaised with the payroll providers for the required information while reminding the headteachers about their obligation and the possible financial penalty for non-compliance.  Sometimes, it involved retrieving legacy data stored elsewhere which might incur a fee to the scheme employers.  

Iain Cassidy referred to the good practices identified by the Council’s internal audit for its schools in respect of governance, budget management, reporting and payroll processing.  He said that schools fined might face questioning by members of the Audit Committee. Councillor Adam Peter Lang noted that finance managers at the schools concerned should receive relevant training on the schools’ statutory duty as a scheme employer to comply with the requirement of providing the information. Eleanor Dennis assured members that her team liaised with schools extensively to help them understand their responsibilities. In this regard, the Chair requested the Pension Administration team to provide more granular data on those who were late in data submission, and suggested schools potentially been invited to relevant meeting to discuss outstanding data to support them. 

ACTION: Eleanor Dennis 

Councillor Florian Chevoppe-Verdier asked about the Pension Regulators’ Codes of Practice which sought to ensure all parties were compliant, Marian George (Independent Advisor) noted that they were combined codes currently under consultation and therefore were not available in the public domain yet. Replying his further question, Eleanor Dennis noted that scheme year referred to the period between 1^st April and 31^st March the following year.  

Eleanor Dennis explained that the Local Government Pension Scheme (LGPS) regulations 2013 required fund authorities to have in place a PAS that set out the standards and responsibilities of performance and best practice that Fund and scheme employers who participated in the LGPS should follow. While the LBHF Pension Fund had not imposed any fines in the past two years, actions resulting in fine being levied could be taken if a scheme employer failed to comply with the LGPS regulations including not submitting the data to the Fund.  

In reply to Councillor Florian Chevoppe-Verdier’s question, Eleanor Dennis said she believed that those successful commercial organisations could afford the fines which however might bring a deterrent effect on the smaller organisations.  Nevertheless, schools would be fined as a last resort if they had already been briefed and understood the responsibilities of being a scheme employer and after her team had attempted several chases for data without success.   

Referring to paragraph 7.2 of the revised PSA which read:  

“An employer who reaches three charges in a scheme year, or where the Fund deems one action is of significant material interest, will be reported to The Pension Regulator, who has the powers to take employers to court and impose fines.” 

Councillor Laura Janes considered it necessary to change the wording to “may” rather than “will”.   The Chair said that apart from changing the wording, he requested the Pension Administration team to keep the lagged cases under close review.  

RESOLVED 

The Committee approved the revised 2022 PSA for the LBHF Pension Fund subject to revising the wordings in paragraph 7.2 to tally with current practice.