FAS Validation Template FAQs 


 

What should we put for “Date pension commenced” (Individual results column I) for a Beneficiary where part of their entitlement has arisen prior to the crystallisation date and some has not? (Please note that this type of beneficiary is known as a “Dubery” member.)
Dubery members will have one asset share calculated and therefore have one row on the Individual Results tab, however the liabilities should be split and allocated to the appropriate categories on the Category 1-3 tabs. Such members could therefore have two different dates that their different tranches of benefits commenced.

Please enter the first date on which the member was in receipt of his/her pension.

 

What should we put for “Beneficiary receiving present payments when regulations came into force” (Individual results column L) for a Beneficiary where part of their entitlement has arisen prior to the crystallisation date and some has not? (Please note that this type of beneficiary is known as a “Dubery” member.)
Dubery members will have one asset share calculated and therefore have one row on the Individual Results tab, however the liabilities should be split and allocated to the appropriate categories on the Category 1-3 tabs. Such members may therefore be receiving payments for one tranche and not for the other.

Please always enter “Y” for Dubery members.

 

What should we put for “Pension entitlement at start of wind up/date pension commenced if later” (Individual results column AK) for a Beneficiary where part of their entitlement has arisen prior to the crystallisation date and some has not? (Please note that this type of beneficiary is known as a “Dubery” member.)
Dubery members will have one asset share calculated, and therefore have one row on the Individual Results tab. However, the liabilities should be split and allocated to the appropriate categories on the Category 1-3 tabs. Such members will therefore appear in more than one category.

If a member was receiving payments in respect of the pensioner element at windup, but not the deferred element, complete as follows:

The pensioner element is the amount that the member was entitled to on the windup date (not date pension commenced).

The deferred element should be the deferred element revalued up to the windup date, i.e. the two figures should be aligned to the same date.

Then add them together to give the total pension entitlement.

Any lump sum commuted should be allowed for in the total pension entitlement.

If a member was not receiving any payments at the windup date, the amount entered should be as at the date pension commenced. This should be the amount put into payment at that date, including any scheme early or later retirement factors used to align benefits to a single retirement age. Any lump sum commuted should be allowed for in the total pension entitlement.

 

How should a person who has received a lump sum only be represented on the Individual results tab?
A member that has received a lump sum only from their scheme prior to the regulations coming into force (i.e. before 2nd April 2010) does not meet the definition of receiving a present payment (so column L should show “N”) and the member will therefore have a FAS-shaped notional pension. Columns AI and AJ should then be completed and columns AK to AT should be left blank. 

 

If a scheme provides for increases above the statutory level, what priority class should the increases be in?
The “increases to pensions” referred to by the statutory priority orders refer to those required under the scheme rules, rather than statutory minima.  Therefore, all increases (including those in excess of the statutory minima) should be allocated to the appropriate priority class depending on the order applicable at the wind-up date.


 

What category should a spouse/civil partner/other partner be allocated to?
A beneficiary with Spouse/Partner or Other Dependent status should be allocated to the category that the original member would have been allocated to.

E.g. If the member was entitled to a pension at the crystallisation date they would be a Category 1 beneficiary and their spouse/partner would become a Category 1 beneficiary on their death.

When should the Beneficiary receiving present payments when regulations came into force (Individual Results column L) be set to “Y”?

We expect this to be “Y” if the date pension commenced is before the regulations came into force (i.e. before 2nd April 2010). We would also expect this to be “Y” for members with a status of Spouse/Partner, Child or Other dependent where the date of death of the original member is before the regulations came into force.

Additionally, a member should also be treated as receiving a present payment where, prior to the regulations coming into force:

(a) the member was entitled to a payment under the scheme rules;
(b) the trustees of the scheme had received confirmation from the member that the payment should commence; and
(c) the member’s entitlement became payable as a result of (a) and (b).

Otherwise, it should be set to “N”.

 

How do you determine whether a beneficiary has FAS or Scheme shaped benefits?
A beneficiary’s benefits are Scheme shaped if they were receiving a present payment when the regulations came into force (i.e. before 2nd April 2010). A member should be treated as receiving a present payment where, prior to the regulations coming into force:

(a) the member was entitled to a payment under the scheme rules;
(b) the trustees of the scheme had received confirmation from the member that the payment should commence; and
(c) the member’s entitlement became payable as a result of (a) and (b).

Otherwise, their benefits are FAS-shaped.

For each member we would expect either the FAS-shaped benefits or Scheme-shaped benefits section of the individual results to be completed (but not both). However, both the FAS- & Scheme-shaped benefits can be left blank for annuitants where their entry is “NK” for the Assets transferring to HMT column in the Individual results tab.

 

Should the Spouse/partner's proportion-death in retirement (Individual results column AL) take commutation into account?
Yes. If the member is in receipt of payments and has commuted a proportion of their original pension, but their spouse’s pension is based on the pre-commutation amount, the proportion should reflect this. For example, scheme rules may grant 50% of pre-commutation pension. 50% of pre-commutation pension may equate to 63% of the post-commutation pension actually in payment, so in this case 63% should be entered.

 

What should we put for Category (Individual results column E) for a Beneficiary where part of their entitlement has arisen prior to the crystallisation date and some has not? (Please note that this type of beneficiary is known as a “Dubery” member.)
If part of a Beneficiary’s entitlement has arisen prior to the crystallisation date and some has not, these members are known as “Dubery” members. Dubery members will have one asset share calculated and therefore have one row on the Individual Results tab, however the liabilities should be split and allocated to the appropriate categories on the Category 1-3 tabs. Such members will therefore appear in more than one category.

Please enter the category where their total liability is highest.

 

What should we put for Status (Individual results column F) for a Beneficiary where part of their entitlement has arisen prior to the crystallisation date and some has not? (Please note that this type of beneficiary is known as a “Dubery” member.)
If part of a Beneficiary’s entitlement has arisen prior to the crystallisation date and some has not, these members are known as “Dubery” members. Dubery members will have one asset share calculated and therefore have one row on the Individual Results tab,  however the liabilities should be split and allocated to the appropriate categories on the Category 1-3 tabs. Such members could therefore have two different statuses.

Please enter status as Pensioner.

 

What should we do if any of our liability amounts fail the validation test?
Any liability amount entered in the Category tabs that fails our validation test will be shown in red on the template. Each of the Category tabs shows the average annuity rates we have used to validate your liabilities. These have been based on the average information you have provided for each tranche along with the relevant assumptions in the Basis tab. 

To help us to validate your liability amounts it would be useful for you to consider how our annuity rates shown on the spreadsheet compare with what you have used for your calculations and to provide any details as to why our global checks may not be relevant. In addition, providing sample annuity rates (level and/or increasing) for any tranches with liabilities that may be deemed as significant in relation to the valuation will also be useful to help us in reconciling any differences.

Any additional information provided may be submitted within the relevant Category text box in the Validation tab.

 

If the assets of the scheme are not expected to cover all the priority classes do I still need to calculate all of the liabilities?
For any priority classes where the assets are not expected to meet any of the liabilities (i.e. where there would be a 0% coverage for that particular priority class), there is no need to calculate the liabilities for that class. Please state you have taken this approach.

 

What should the entry be for the Assets transferring to HMT (Individual Results column K) for annuitants?
For partial annuitants with policies in their own name, please enter “N”.

If the Beneficiary has a policy in the trustees’ name and is being included in an initial valuation to determine if assets are to be transferred or if an annuity should be assigned, please enter “NK” to indicate that this information is not known. In the final valuation, this should then be changed to “Y” if the policy is transferring to government, and “N” if the policy is being assigned to the Beneficary.

 

Should the lump sums paid be included in the scheme interim payments total (Individual results column AE)?
Yes. Any lump sums paid should be included in the scheme interim payment value total (column AE) and should also be allocated according to whether it was paid pre or post eligibility date (column AH).

 

How should we represent members with multiple periods of service in the Beneficiary numbers and Individual results tabs?
Members with multiple periods of service should be represented once on the Beneficiary Numbers tab. These members can be split over multiple rows in the Individual results tab, with a separate row for each period of service. Alternatively, they may be aggregated within a single row. The liabilities for each period of service should be allocated to the appropriate categories on the Category 1-3 tabs. If a single row contains liabilities for more than one category it should be classified as being in the category with the highest liabilities.

 

What assumptions should we use for category 2 members where the MFR basis applies?
Members are classified as non-pensioner for the purposes of MFR if they are classified as non-pensioner in the priority orders. Therefore, Category 2 members should be valued using the non-pensioner MFR basis (rather than the pensioner basis), i.e. a long-term discount rate and appropriate MVAs should be used.

 

How should I represent a GMP step up?
The GMP step-up pension may be valued separately with the liabilities allocated to the appropriate tranches on the Category 1-3 tabs. Alternatively, the GMP step-up pension may be included within the liability for a given tranche of pension. However, it should be made clear that this is the approach used. Please ensure that the pension amount provided is consistent with the liabilities provided for each tranche. We would encourage the provision of additional information within the Validation tab regarding the way in which you have represented a GMP step-up in the template. When representing a GMP step up we are happy to accept the method that is most convenient based on the way in which you have carried out your calculations.