In June 2014, the Regulator published the findings from its record keeping survey 2014, upon which the Regulator's executive director for DC governance and administration Andrew Warwick-Thompson commented 'It is highly disappointing to see that a proportion of schemes still do not see record-keeping as a priority.'

We have mentioned in detail in previous articles in Pensions Pieces the importance of good record keeping in the pension scheme context and also the Regulator's initiatives in this regard.  It now seems that the Regulator is willing to take further steps where failings have been identified.  We understand that the Regulator opened investigations into seven schemes as a result of last year's review and has now opened a further four.  Mr Thompson has also said that 'we (the Regulator) will be working with schemes to improve standards but we will take action where problems become apparent to us and report publicly on the outcomes, as appropriate.'

Notwithstanding the fact that good record keeping is an essential part of the proper running of a pension scheme (and note the legal implications of not having this in our previous articles) attracting the scrutiny of the Regulator is also likely to be a time consuming process. Indeed, if findings are ultimately published then there could also be questions of reputational damage to the companies in question. This is all in the context of legal reforms for defined contribution schemes where small pension pots will automatically transfer with employees (and so correct data in relation to the benefits involved is crucial) and possibly more stringent legal requirements in relation to the administration of DC schemes (ensuring transactions are processed promptly and accurately) which reinforce the need for sound record keeping processes.  It is worth reminding all parties involved of the importance of this issue especially because errors (and resolving them) can be costly.