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Army Preserved Pension Fiasco

Events from Completion of Overseas Payment Mandate

This is the second of two pages that chronicle my attempts to obtain a Preserved Pension. It covers events from my completion of the OPM onwards. This part is directly relevant to my case against Equiniti Paymaster.

Both pages allow you to view all the relevant correspondence that I have received and sent. For letters and emails, this includes the full unedited textual content (but not necessarily details in headers and footers, such as addresses and salutations).

For faster navigation, these documents are presented as popup images. Click on thumbnail image and hold down the button to enlarge. In many cases, there is also a link to a PDF document of the correspondence.

08 October 2015

The form on which details of overseas bank accounts must be supplied (OPM) is available here. After downloading, printing, and completing the OPM for Mexico, I sent it by registered post to the specified address at Veterans UK. Although the OPMs are on a government website and sent to Veterans UK, they are actually created and processed by Equiniti Paymaster's "overseas banking team". It is left as a challenge to the reader to figure out by what means this Fine Load of Bankers determined the requirements in this form.

This part of the OPM appears to be applicable to all countries. But the only field that requires any knowledge of banking is incorrect - the account holder name can be up to 35 (not 18) characters long (although of course, there is no point in specifying this). I was relieved to find that, at 17 characters, mine just fits.

The country-specific part of the OPM looks absurd - and so it is. It bears no relation whatever to what is required by the Mexican Banking System. Since 2004, this is a single unique 18-digit value known as a CLABE allocated to each bank account, which incorporates all the required details plus error checking. There are numerous sources of information on this; for example this article on Xoom, and this site giving examples for various countries.

All references (including the Bank of Mexico) concur that the sole requirement is this 18-digit CLABE. None states that a separate 3-digit Bank Code must be specified (no such value is publicly known§). The Account Number is not used separately outside Mexico (it forms part of the CLABE); and it has a maximum length of 11 digits (not 34!). The Account Type is not only irrelevant, but erroneous (Mexican bank accounts are not classified in this way). So, 0/10 here.

In dealing with this OPM as best I could, I supplied my CLABE in the Account Number field, plus additional details and an explanation below. This should have both enabled payment to be made to my bank account, and made clear that their form was in need of repair. But as you will see, this and several painstaking explanations I made subsequently were not good enough for Equiniti Paymaster, who continued to assert that their bank code was required for Mexico. And months later, not only have I still received no payment, but their OPM remains uncorrected, faithfully preserved for the benefit of others.

§Anyone with a bank account in Mexico will know that the unique CLABE assigned to the account is the only value required to make funds transfers to it. Like a credit card number, to end users the CLABE is a unitary "black box" value. I have had numerous transfers made to my HSBC account in Mexico for over ten years from at least three different sources in the UK, and had never heard of a Bank Code. Neither had bank staff when asked about it. So when completing this form, it seemed that this must be the 9-digit value that identifies the bank branch (i.e. that it was the equivalent of the Sort Code). To be as helpful as possible, I supplied mine underneath, together with my account number (although these are not used externally).

Later investigation showed that the first 3 digits of the CLABE comprise a bank code that identifies the banking institution (in my case, 021 for HSBC); the next 3 digits identify the bank branch. Bearing in mind the total ignorance displayed by this form, and the fact that bank codes crop up all over the place, it is not reasonable to suppose that their 3-digit Bank Code has any basis in knowledge of the Mexican banking system. But even if this were so, they had no business to request it, for at least three reasons:

  • it is for "internal use only"; there is no definitive list of Bank Codes available to the general public
  • it forms part of the CLABE, which Mexican banks require to be specified as a single unit (this also incorporates error checking)
  • the OPM would in any case not yield sufficient information, since this value with the Account Number would lack a bank branch identifier

All this is to underline the fact that their requirement for a 3-digit bank code is invalid, and that this OPM would not enable any funds transfers to be made to Mexico. Equiniti Paymaster can have made no effort whatever to investigate the requirements, or to check this form. And I stand by the efforts I made to deal with it.

11 December 2015

Again being concerned about having heard nothing for over two months, I sent a fax to Veterans UK, imploring response by email. To underline the impracticality of normal post, I mentioned the extreme delay in receiving AFPS Form 8. I also repeated my banking details, commenting on the issues with the OPM on which I was required to supply them. At this time, I did not realise that the OPM was the domain of Equiniti Paymaster, not Veterans UK.

13 December 2015

Received general information from Equiniti Paymaster; it was now clear that this company would be handling payment of my pension. This is the covering letter, stating how and when the pension will be paid. I never requested that the lump sum be sent under separate cover.

The remaining two sheets deal with their purported Standards of Service. Bearing in mind my subsequent experiences of these, it makes rich reading. Of particular note are the risible statements under the heading Complaints Procedure.

Although the Pensions Ombudsman is mentioned, their Complaints Procedure does not mention that a formal Internal Dispute Resolution Procedure must be completed before the Pensions Ombudsman will accept the case. Their two-stage Complaints Procedure is similar in nature to an IDRP; however, it would not serve this purpose:

  • Firstly, all correspondence under the IDRP must be clearly tagged as such for it to be counted as being part of the procedure, but no IDRP is mentioned
  • Secondly, their Complaints Procedure gives no timeframes within which resolutions will be made, and which must elapse before one can proceed to the next stage (the only commitment made is to simply acknowledge a written complaint within 10 working days)

Subsequent investigation showed that Equiniti Paymaster requires their Complaints Procedure to be completed before one can even start the IDRP. This appears to preclude any intervention by the Pensions Ombudsman Service, for the following reasons:

  • As indicated, there is no timeframe given under which their Complaints Procedure could be deemed to have been exhausted, and thus when their IDRP could be invoked
  • (better yet) Although one is required to conduct the IDRP with the party against which the complaint is to be raised (in my case Equiniti Paymaster, not Veterans UK), there does not appear to be an IDRP for Equiniti Paymaster. This Armed Forces Newsletter dated 2015 from Equiniti Paymaster that I found later (see last page) refers one to the Armed Forces IDRP; but this gives only the procedure for Veterans UK - it does not even mention Equiniti Paymaster.

So Equiniti Paymaster clearly holds all the cards, and is effectively immune to any action by the Pensions Ombudsman.

14 December 2015

I was astounded to receive a UK cheque from Equiniti Paymaster through the post. Apart from the fact that I chose to have payments made to my bank account, they should surely have known that I would not be able to present this here in Mexico. It was in the amount of £192.46 (payment for a month), even though it was stated to include arrears of £217.29. It later transpired that it is the policy of Equiniti Paymaster to send cheques regardless, until an OPM has been processed.

Email and attached copy of Award Letter (dated 26th October) gratefully received from Veterans UK. The OPM mentioned is what I completed and sent on the 8th October, and which should have been received and processed long ago by Equiniti Paymaster.

15 December 2015

Sent reply to email received from Veterans UK yesterday, mentioning the cheque I had received. This was forwarded by Veterans UK to Equiniti Paymaster.

22 December 2015

Received email from Equiniti Paymaster in response to the above email, stating that the OPM I sent on 8th October had not been received, but giving me the option to send a scanned OPM as an email attachment.

The AFPS Form 8 I sent on the 5th October was clearly received by Veterans UK well before the 26th October (the date of the Award Letter); both this and the OPM were sent by registered post, only three days apart. It therefore seemed surprising that Equiniti Paymaster had still not received the OPM.

23 December 2015

Replied to above email, attaching a scan of the OPM I sent by post on the 8th October. I also repeated the relevant information on the form and provided further explanation regarding the spurious 3-digit bank code required by the OPM.

07 January 2016

Received this letter entitled "Changes to how you get your Armed Forces Pension Payments".

It concerns mainly getting payments made directly to one's bank account (in my case, the only option).

11 January 2016

Received email from SPVA Pensions (presumably some group within Equiniti Paymaster), stating that my OPM had been rejected on the grounds that the 3-digit Bank Code that they purport is required for Mexico had not been supplied; and that I should check with my bank and would have to complete another OPM. Considering their blatant errors and the trouble that I had gone to in dealing with them, it should not be surprising that I did not receive this in a spirit of unqualified rapture. And it is extraordinary that this shabby outfit could be the recipient of any awards, as indicated in their email (view PDF document).

15 January 2016

Received two more useless UK cheques, both dated 2nd November 2015, but under separate cover. One was for the amount of the arrears, the other for the amount of the Terminal Grant.

17 January 2016

Sent reply to email dated 11 January, having checked further with my bank and online to clarify my position on their rejection of my OPM. This email included information on what is required to transfer funds to Mexico (an 18-digit CLABE), together with a clickable link to a Wikipedia article in English on CLABE. I further invited them to do an internet search on this, so they could check for themselves the veracity of my statements.

I also included information showing that their OPM would not enable bank transfers to be made to Mexico, and was otherwise completely inappropriate.

A few minutes later I received this abomination, entitled "Automated Response".

This is a disgraceful way to respond to my email. I had chosen to communicate by email, had already been communicating by email, and had made abundantly clear the folly of communication by post. Far from this response, they should encourage the use of email, since it is generally much cheaper and faster, never mind in my particular case.

But apart from this it was difficult to decipher just what was meant. It mentioned that those with a Preserved Pension not yet in payment are required to write to Kentigern House, ..., G2 8EX (although since they have already sent me cheques, I am not sure whether this applies in my case).

I decided not to send a letter by post and wait several months for a reply; instead I hoped that they would act upon the email that they had received (payment is what I was looking for, rather than a reply).

03 February 2016

After waiting a further two weeks for payment and/or response, and having received neither, I reverted to my initial Equiniti Paymaster contact. To this email, I appended the emails dated 11th and 18th of January, and attached the OPM that I had sent previously.

04 February 2016

Received a reply the next day, but only to say that it had been passed back to the same people who had done nothing previously, and that I would receive a reply "in due course" (by what means was not specified). Bearing in mind my experiences to date, I was less than ecstatic to learn this. And this was unacceptable even under their own terms of service, since Equiniti Paymaster undertakes to reply within 10 working days.

But notwithstanding this unpromising reply, and not knowing what else I could do for the moment, I felt I must wait some more.

10 February 2016

Received postal information entitled "Payment of your Pension Abroad". This appears to have been sent in response to the loss of the original OPM I sent on 8th October 2015.

This is the replacement OPM in its full glory, proudly displaying the "Equiniti Paymaster" logo. I wonder what country in the world has bank account numbers up to 34 digits long? Here in Mexico, with a population of 120 million, 11 digits suffices.

22 February 2016

Having waited another two and a half weeks and again received neither payment nor response, it became clear that dealing with Equiniti Paymaster was a waste of time. The only other contacts I had for them were the two postal ones given in their Complaints Procedure (see here). I think my experiences with both the post and Equiniti Paymaster's responsiveness to date should explain why I did not consider sending them a complaint to be a reasonable course of action: this would mean writing a letter to their "Pensions Customer Services Team Leader", which (if their statements are to be taken at face value), they would simply acknowledge within 10 working days.

I therefore reverted to Veterans UK, as they contract Equiniti Paymaster and should be in a position to put pressure on them. And I thought they should be made aware of the quality of service that this company renders on their behalf. The email I sent included a link to this webpage.

23 February 2016

Received this prompt response from Veterans UK, saying he will get Equiniti Paymaster to contact me, and contact me himself once he gets some information (hopefully later the same day).

27 February 2016

Received another useless UK cheque from Equiniti Paymaster, dated 16th December 2015, in the amount of one month's pension.

I checked the online OPM for Mexico, to see if Equiniti Paymaster had updated it. The same OPM that I had downloaded was preserved for the benefit of others. But to correct this form would be to acknowledge their failings, which is obviously something they are not prepared to do.

29 February 2016

Having waited for a week without hearing from either Veterans UK or Equiniti Paymaster, I sent this follow up to Veterans UK.

01 March 2016

Again, I received a very prompt response from Veterans UK. I was somewhat disappointed that it indicated little progress from the previous email - nonetheless, I should be grateful that they were being helpful and responsive, and not just saying "you're on your own, sunshine".

03 March 2016

Received another email from Veterans UK, stating that Equiniti Paymaster would be contacting me directly as it is their OPM that is causing the problems. I was not sure whether this startling revelation was due to an admission by Equiniti Paymaster, or investigation by Veterans UK - I suspect the latter. Although this was to pass me back to Equiniti Paymaster, he did offer to give further help if I had more problems.

13 March 2016

After waiting another 10 days without either communication or payment from Equiniti Paymaster (no longer to my surprise), I sent this to Veterans UK. In it, I expressed my concern about the conduct of Equiniti Paymaster and opined that legal action was the only way to resolve the matter, hoping that stronger action would result. I additionally suggested that Veterans UK would do much better to make pensions payments themselves rather than contract this function out to Equiniti Paymaster. I also wondered whether Veterans UK could disprove Equiniti Paymaster's claim that they had not received the OPM by 22nd December (this was sent to Veterans UK, presumably for their authorisation before being sent on for processing by Equiniti Paymaster).

16 March 2016

Received yet another useless UK cheque from Equiniti Paymaster, for 16th January 2016. Maybe they think that sending these absolves them of their obligation to make payment to my bank account (the only option in my case) and thus they can avoid having to accept any responsibility for their negligence.

19 March 2016

I now feared that Veterans UK would not do much, despite their apparent willingness to help, so sent this to the Pensions Ombudsman Service (with, of course, a link to this website). They are at least considerate enough to provide an email address (unlike Equiniti Paymaster and various other organisations in the UK, who seem to eschew email in favour of sending paper through the post).

As indicated previously, I did not venture to send anything to Equiniti Paymaster's "Pensions Customer Services Team Leader" for the following reasons:

  • Only a postal address is available and Equiniti Paymaster clearly does not care to use email; so any reply would almost certainly be sent by post taking several months (if it arrived at all - I have still not received the Award Letter from Veterans UK).
  • Bearing in mind the behaviour of Equiniti Paymaster to date, I doubt they would consider themselves under any obligation to respond; Veterans UK is in a much better position than I to get anything out of them, and they have had no success after several efforts.
  • This case is not just a matter of questionable judgment or even plain negligence, but involves serious misconduct; to have Equiniti Paymaster in charge of assessing it would be to appoint a villain as judge and jury at his own trial.

22 March 2016

Received a prompt and detailed reply from the Pensions Ombudsman Service. Unfortunately, this stated that before they can act, I have a legal obligation to pursue this at two levels with Equiniti Paymaster via a formal internal dispute resolution procedure (IDRP). Attached were a Template Document showing how to make clear that the complaint was under the IDRP, and a Complaints Leaflet.

Not having been informed about any such procedure in any of the information I received from Equiniti Paymaster, I queried what was meant. I also expressed the difficulties I would have in following such a procedure, especially since this would apparently mean the use of post.

24 March 2016

Suspecting that the information I had from Equiniti Paymaster did not conform to the IDRP on at least two points, I sent this follow up to the Pensions Ombudsman Service. Attached were scans of the two pages describing Equiniti Paymaster's self-professed Standards of Service, that you may see here.

29 March 2016

Received a reply to the two above emails. Whilst this gave a little more information, it did not address the issues that I raised. They did attach the application form on which I could make a complaint once the IDRP was completed, that you may see here. I was advised to contact the Pensions Advisory Service.

04 April 2016

Contacted the Pensions Advisory Service via an online form. Whilst there was no way I could properly explain the situation within the supplied enquiry box, I gave a link to this website, and hoped that they would contact me by email.

Received an acknowledgement a few minutes later.

08 April 2016

Received a totally unexpected email from the original contact at Equiniti Paymaster, at last acknowledging what I had been telling them for months. I am not sure whether this was a result of goading by Veterans UK (from whom I had heard nothing for over five weeks), or possibly due to the Pensions Advisory Service. The "much going back and forth" that Equiniti Paymaster apparently found necessary to resolve this clear and simple situation is a matter for the reader's imagination.

Regardless of what prompted this out-of-the-blue communication, I have no intention of letting things rest here. I feel that not only am I due a significant sum in compensation, but have a duty to expose this disgraceful conduct to prevent further issues of this kind.

Given Equiniti Paymaster's complete unresponsiveness and the evident difficulties in the complaints procedure, I had long since given up on receiving any Army pension in the medium to long term (or at all). I had therefore been compelled to attempt to take a lump sum out of a small private pension, after having previously liquidated some investments here (my failure to do this is a much bigger story involving not just negligence and cavalier treatment, but criminal misconduct and collusion, that you may see here).

09 April 2016

Replied to simply confirm that I had not presented any of the cheques that they had sent. I refrained from making further comment, as it clearly would not be worthwhile here.

11 April 2016

Received a reply stating that all cheques had been cancelled, and that I would receive another email to notify me of the expected amount in local currency and the credit date. I was not entirely clear why I would be notified of the amount in local currency, since the amount paid is in £ sterling, and the exchange rate fluctuates on at least a daily basis.

15 April 2016

Received details giving the amounts in Mexican Pesos, and an expected credit date of 18th April. I assume then that the transaction has already been finalised, as otherwise there could be no known conversion rate. I got $24.34 MXN / £ sterling, which although better than it has been most of the last 10 years, is significantly lower than it was a few months ago. Also, no interest has been paid, never mind compensation for what I have been through over the last few months, and the financial losses involved in premature liquidation of assets.

20 April 2016

Received a detailed reply from the Pensions Advisory Service. This included three PDF documents, none of which I had seen previously:

  • Armed Forces Pension Schemes - Dispute Resolution Procedures; although this initially appeared useful, it dealt only with the pension administrator (in this case Veterans UK). It did not even mention Equiniti Paymaster; this is probably because it is dated 2009, long before Equiniti Paymaster became the paying agent (apparently about three years ago)
  • A Form used to authorise the Pensions Advisory Service to contact those relevant to the investigation
  • Avoiding and Resolving Disputes; a general guidance leaflet (as they explained, the pages are out of sequence)

Given the timing, I wondered whether the Pensions Advisory Service had made representation to Equiniti Paymaster; yet the form above suggests that they would not have done this before I had completed and returned it.

24 April 2016

Replied to the Pensions Advisory Service. I recently found an Armed Forces Newsletter dated 2015 from Equiniti Paymaster (see last page) that gave the Armed Forces Pension Schemes - Dispute Resolution Procedures as its IDRP (even though the document did not mention Equiniti Paymaster). I gave a link to information on their Complaints Procedure (received 13th December 2015), raising the issue that Equiniti Paymaster did not appear to have an IDRP. I also asked whether they had contacted Equiniti Paymaster to bring about payment.

I received no response to the serious issues I raised about Equiniti Paymaster - it seems I have nowhere to go in achieving justice for myself and other past, present, and future victims of Equiniti Paymaster's negligence, incompetence, and intransigence.

As I write this addendum on 27 December 2018, with the benefit of subsequent experience and hindsight, it has become very clear that both TPAS and TPO are in the business of protecting pension providers (especially those with government connections). Their claims that they are impartial and do not take sides are barefaced lies.

29 April 2016

Another cheque from Equiniti Paymaster, for 16th February 2016 (maybe this is the last..)

07 May 2016

... No it isn't, received a cheque for 16th March 2016.

21 January 2019

This is the letter and envelope of a communication from Equiniti Paymaster, requiring a witnessed signature to a declaration that I am who is specified on the letter. The completed form is given in the section for 26 January below.

This letter and form is dated 30 November 2018, and I received it on 21 January 2019 (the envelope is postmarked 18 January). This is actually much faster delivery than I have typically experienced in the past, but would still make it difficult or impossible for me to meet their 12-week deadline. Although this period is rather more generous than the 14 days allowed by Scottish Widows for a response to their forced use of post, post often takes much longer than this to arrive. As the return address is a PO box number, courier is not an option (in any case, it is very expensive). The fastest way I can return this form is by registered post, which is likely to take at least three weeks. And their requirements for witnessing caused me considerable difficulty...

Even if it is reasonable to require me to complete this declaration, their requirements for witnessing it are certainly not. I also had to get the AFPS Form 8 from Veterans UK that I sent on 05 October 2015 witnessed, but this did not present a problem. The only option Equiniti Paymaster allows me for a witness is a notary public (in Mexico, this is an experienced government-appointed lawyer). In the witness declaration, it states that the witness must have known the signer for at least 12 months. This may be reasonable for a character reference from a personal acquaintance, but it is clearly not an appropriate specification for someone acting in a professional capacity.

As a result of this requirement, together with the threat that false statements may result in criminal proceedings, I was at first refused. This was despite my having crossed out and made a note to cover the relevant section (see the completed form in 26 January below). After a great deal of worry, I managed to get this witnessed by the notary who had conducted a land purchase for me around five years ago, who was willing to act as witness on this basis. In all, I had to make three separate journeys to notary publics, and the fee I had to pay was much higher than expected (no doubt due to the difficulties created by Equiniti Paymaster). The financial hit was particularly severe given my very meagre circumstances (due in no small part to the Personal Pension Fiasco thanks to Scottish Widows and its protection by the corrupt Pensions Ombudsman).

All this has caused me a considerable amount of trouble, worry, and expense. I have no doubt that they would not hesitate to stop my pension if I did not respond in time. Or even if I did, they could always claim that they did not receive my form (they claimed on 22 December 2015 that they did not receive the bank details form that I sent also by registered post on 08 October 2015, which I find unlikely). Otherwise, they could always claim that my details were invalid (as they also did with my bank details form on 11 January 2016).

Unfortunately, my experiences with UK pension providers show that they act above the law in an environment without competition, regulation, oversight, or any effective complaints procedures, thus enabling them to abuse the pensioner with total impunity. And each time, they gain in keeping hold of the money - the pensioners lose. This, I have learned, is British justice - the corrupt organisation always prevails over the individual.

26 January 2019

I sent the completed form by registered post first thing 26 January 2019. This is the earliest I could possibly send it, with the difficulties noted above - I gave it top priority. The popup image is the proof of dispatch (one important piece of supporting evidence in my favour - as mentioned, a signed-for service was not possible).

After sending the form, I thought it prudent to send an email with a PDF document attached containing scans of the returned form with covering letter and additional documentation from the notary public. I also made clear the difficulties I had with their requirements, and suggested that it would be expedient to send me any future forms as PDF documents that I could print here (some chance).

Here is the completed form. The popup images cover only my declarations and the page for the witness. The PDF document is the attachment to the above email, as I sent it, containing the entire form plus other material. This was done quite late in the evening after the notary public had arrived back from Morelia (the state capital of Michoacán). I was unable to post it the next day (25 January), but posted it early on the 26 January.

Apart from the stipulations for witnesses being inappropriate, they are also vague. What exactly is meant by whom I have known for at least 12 months? And it also requires that I am not related to the person named on this form. Does this mean a family relation or any other kind of relation? This also may make it difficult or impossible to satisfy the requirement that the witness has known the person named on the form for at least 12 months.

This is another automated email response stating that any reply will be sent by post (see 17 January 2016). I had made clear that I wished to communicate only by email, and that post is completely impractical. Thankfully, I do not need a reply.