The Regulator has published its final guidance on record keeping - it is a good practice guide to reviewing record keeping and the quality of scheme data aimed at trustees, administrators and providers.

Key points include:

  • The measures suggested are intended to identify areas of risk (for internal control purposes)
  • Scheme data is divided into three groups: common data (basic member information which all schemes should have), conditional data (this will depend on the type of scheme and may include employer information and investment details), numerical data (this is basic information, for example, number of benefit categories, which can be used to test the basic membership information).
  • The guidance sets out tables of examples of the various data, a brief description of the appropriate test and the reasons for reporting.
  • If a problem is identified and further investigation or data improvement is required then an action plan should be put in place.
  • Schemes demonstrating no problems should undertake the testing exercise annually.
  • Record keeping should be reviewed urgently on the happening of certain scheme events including winding up, PPF entry, change of administrator or buy-out.