Thank you for your request for information about the following:

“1) How many pension scheme members had benefits where their capital value, for lifetime allowance purposes, was greater than £1,000,000, as at 5th April 2016, where lifetime allowance value is calculated by analysing the adjusted closing balance from the members annual allowance records? On the assumption: a. 95 scheme members, Capital Value = (Adjusted Closing Balance / 19) * 23 b. 08 & 2015 members, Capital Value = (Adjusted Closing Balance / 16 ) * 20

2) Could you repeat this and provide the number of members where the value was greater than £1,073,100? Since 5th April 2016,

3) How many members have retired and triggered a lifetime allowance charge, as per the reportable event log provided to HMRC?

4) Of these members, could you break the numbers down into lifetime allowance protection categories; such as None, Enhanced Protection, Individual Protection 14, Individual Protection 16, based on the prefix of the certificate number such as: (this list is not exhaustive, other prefixes may exist that may need to be included)

5) For the members with no protection from Question 4 (i.e. no certificate), would you be able to run the following calculation against this set of data: “MissedProtection” = Max (0, Min (Capital Value1, £1,250,000) – lifetime allowance2 ) 1 - (as calculated from adjusted closing balance using method from Question 1) 2- (Standard lifetime allowance for the year of retiring – 2016/17 - £1,000,000, 2017/18 - £1,000,000, 2018/19 - £1,030,000, 2019/20 - £1,055,000, 2020/21 onwards -£1,073,100)

This effectively tells us the amount of lifetime allowance the members could have protected their lifetime allowance, but didn’t put protection in place. From this could you provide: a) the number of members where “MissedProtection” is greater than £nil b) the sum of “MissedProtection” across all members.”

Your request was received on 24 February 2023, and I am dealing with it under the terms of the Freedom of Information Act 2000.

Response

Question 1 and 2

Q1. 10,094 unique members had a capital value in excess of £1,000,000.

Q2. 7,987 unique members had a capital value in excess of £1,073,100.

Caveats:

• Due to the complexities with the 2015 scheme and how the data has been stored in Compendia (doubling entries for year end 2016), I have taken the ‘Adjusted Opening Balance’ for year-end 2017, rather than determine which ‘Adjusted Closing Balance’ to use from year end 2016.

• The requesters calculation above has been used to find a capital value for each individual scheme (for members who have benefits within multiple schemes). These have then been added together, before assessing if the member’s total capital value exceeds the stated amount.

• The information is taken from the annual allowance tables, rather than the lifetime allowance tables. Given that the data is a live database it is subject to change and is reliant on those records being fully up-to-date and data being entered correctly by employers/pension members, which cannot be guaranteed.

Question 3 and 4

Q3 - 5,823 unique members have retired and had a capital value in excess of £1,000,000 in the year ending 2016.

• 5,168 are recorded on the reportable log – protection type breakdown provided below.

o 152 members initially had no protection on the reportable log but have since had a certificate added. Unfortunately, we cannot tell if these members had no protection when the previous FOI 15909 was responded to.

• 655 are not on the reportable log.

Q4 - A copy of the information is attached

Caveats

• This is not a straightforward answer to obtain. There are many entries on the reportable events log however many members appear multiple times and are being double counted. The log also doesn’t have the capital value information needed for the following questions. Therefore I’ve used the data from questions 1 and 2 to try and identify which ones have been reported and group by protection type. The data for Q1 and Q2 specifically relates to the capital values of Year End 2016.

• For members with multiple entries on the reportable log, we have used the most recent entry.

• The protection type translations provided are based on the previous request FOI 15909.

Question 5

Q5a. Of the 655 members deemed to have no protection, 506 have “MissedProtection” greater than £nil, based on the capital value in 2016 (227 officers, 279 practitioners).

Q5b. The sum of “MissedProtection” for these 506 members is £71,004,783.65.

Data Queries

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