Your Tomorrow Pension Scheme · CAS-37002-T3N7

CAS-37002-T3N7

Ombudsman’s Determination Applicant Mr S

Scheme Your Tomorrow Pension Scheme (the Scheme)

Respondents Lloyds Banking Group Pensions Trustees Limited (the Trustees)

Willis Towers Watson (WTW)

Hargreaves Lansdown Asset Management Limited (HL)

Outcome

Complaint summary

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Background information, including submissions from the parties

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Adjudicator’s Opinion

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• While it may have been possible to resolve the query regarding the illegible DOB in a telephone call to HL, in reality this is not practical and neither is it in line with the service that WTW has undertaken to provide.

• The service level agreement (SLA) that WTW has in place with the Trustees for dealing with transfer quotation requests is 5 working days.

7 CAS-37002-T3N7 • WTW considers it attempted to deal with the DOB issue in a reasonable and timely manner. As a third-party administrator, WTW cannot be held liable for errors in the documentation provided to it.

• WTW did not have a valid LOA and were right to question it. The transfer quotation request was reviewed on 24 October 2018 and the appropriate letter sent to HL. Taking into account the high volumes of requests it receives each day; it is not possible to prioritise any one individual request above another.

• HL has stated it was in possession of a LOA with a legible DOB shown on it. The appropriate response to WTW’s request would have been to send a copy of the legible form.

HL’s comments

• Whilst it is disappointing that WTW did not have a copy of Mr S’ passport on file, HL appreciates this could have been issued to it on 28 November 2018. However, its requirement for the Security ID to be completed remained outstanding. HL therefore does not believe that its not providing a copy of the passport caused a delay to the process.

• HL denies that the delay in allocating the transferred funds to Mr S’ SIPP was caused by an error in its office. It has provided a copy of an email prior to the one from Mr S, dated 23 January 2019, which says the transferred sum was received in HL’s bank account on 31 December 2018, but the reference attached to it was not HL’s. It was therefore unable to apply this amount to Mr S’ account.

• HL telephoned WTW on 4 January 2019 to chase the transfer and was told it had been sent. However, WTW was unable to confirm the amount transferred so it was not possible to credit Mr S’ funds until HL received paper confirmation of the amount transferred.

The complaint has now been passed to me to consider. I have noted the additional points made by WTW and HL, however, I agree with the Adjudicator’s Opinion.

Ombudsman’s decision

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I uphold Mr S’ complaint.

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Anthony Arter

Pensions Ombudsman 27 October 2020

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