Vestigium Services Limited

A Message from Lord Pickles and Lord Blunkett, followed by Vestigium Services Limited's best practice article

The ability to listen and learn from one another has always been vital in parliament, in business and in most aspects of daily life. But at this particular moment in time, as national and global events continue to reiterate, it is uncommonly crucial that we forge new channels of communication and reinforce existing ones. The following article from Vestigium Services Limited is an attempt to do just that. We would welcome your thoughts on this or any other Parliamentary Review article.

Blunkett signature Rt Hon The Lord David Blunkett
Pickles signature Rt Hon The Lord Eric Pickles

Highlighting best practice
Founder and Owner
new firm, Vestigium Services, works with a growing
list of caring financial services organisations, including
JPMorgan, Invesco Perpetual and Aberdeen Standard,
who all want to do more to find their “gone away” customers
and return their billions of assets. With his anchor clients,
Vestigium’s founder, Paul Aggett, believes greater customer
care will lead to more opportunities for financial services
companies. This also means that they can market to their
existing customer base, inspire loyalty and observe the
regulatory principle of maintaining accurate data. Paul explains
that this re-engagement with “gone away” constituents is
entirely consistent with the FCA principle of treating customers
fairly (TCF).
Our principle area of operation
Vestigium Services is a new provider operating from a secure data centre based
in the UK. For consumers, it is a free service. For financial services organisations,
Vestigium treats the root causes of “gone away” customers (GAs), while providing
a cost-effective tracing service with a high discovery rate.
Quality data-matching and prioritisation have been historic stumbling blocks for the
industry, so Vestigium provides a repository where GAs can be continually matched
against self-populated consumer data. This is accessed by the public through
Vestigium’s consumer website and through working with publicly and privately
available records which are always being refreshed and updated (albeit not typically
cross-referenced effectively).
The regulators are as sensitive as Westminster is. GAs were defined in the FCA’s
thematic review (called the Fair Treatment of Long-Standing Customers), issued
in March 2016, as “all customers firms have lost contact with or are unable to
contact”. Historically, tracing has been limited to a digital postcode-matching
process, which is both quick and inexpensive but often ineffective. Under this
process, customers who move overseas have been inaccessible to financial firms.
For in-house resources, these have been big operational challenges.
Financial firms have relied upon internal consumer enquiry processes to re-engage
with their customers. However, the consumer may well not even know about, or
be able to provide, the information required to claim for their asset. Following a
death, lawyers sign off probate and make limited enquiries about assets held by the
deceased person beyond asking their nearest relatives. Those involved simply may
not know, and discovery has therefore been difficult.
»Founder and owner:
»Established in 2013
»Based in Norwich, Norfolk
»Services: Caring financial
service organisation
»No. of employees: 8
Vestigium Services
Billions of pounds lost
The FCA attempted to determine
the scale of the issue for the Life
and Pensions (L&P) sector. Eleven
L&P companies the FCA cited for in
its 2016 report said they had a wide
range of GAs, with results ranging
from three per cent to 22 per cent
of their total customer book. Taking
a simple average of ten per cent
and applying it to the £2 trillion L&P
industry would give an estimated value
of assets belonging to GAs of roughly
£200 billion. Even a very conservative
estimate of £20 billion to £50 billion
due to GAs or their beneficiaries is a
startling volume of “lost” assets. Recall
can be weak, relatives may be unaware
and paperwork lost, especially after the
distress of family loss. As a result, there
are multitudes of smaller amounts
owed to many ordinary people.
Adding in banks, building societies,
asset managers and securities
industries to the L&P numbers might
double the estimates to a level of
£40 billion to £100 billion. While the
numbers are admittedly estimates,
they are substantive. Vestigium’s work
bridges the gaps, uniquely combining
digital discovery, a safe pooling
mechanism and traditional analogue
mining skills to resolve the issue.
Understanding definitions and
the legal framework
Dormant accounts these days are
defined by the Dormant Bank and
Building Societies Act 2008 (the “Bank
Act”) as 15 years without contact. The
Bank Act enables the distribution of so-
called dormant assets to charity. There
is a stipulation for banks and building
societies to screen before handing these
monies over to Reclaimed Funds Limited
(RFL) for release to charity. It appears
little tracing is done prior to release
of funds to RFL, as RFL holds back
significant assets on its balance sheet
in the knowledge that the consumer
has a perpetual right to reclaim.
The Dormant Assets Commission (DAC)
released its report in March 2017 on
extending the act to cover other asset
classes, notably L&P, asset management
and securities. It is important to note that
the DAC was endeavouring to determine
what might eventually become available
to charities, and, after increased effort
in tracing, to lost customers. We have
no reason to dispute the DAC finding
that eventually a further £2 billion
might become available to charities.
We distinguish this amount from the
far larger amounts which would be
released to consumers if a concerted
effort was made to trace GAs.
Consumer benefits
How our clients can benefit is outlined
as follows:
»As of December 2017, £1.1 billion
has been deposited in the Reclaimed
Funds bucket following the Bank
Act. A total of £362 million has
subsequently been released to
charities, and £66 million (less than
seven per cent) has been claimed
by its rightful owners. Counter-
intuitively, money could be released
to charity more quickly if it came
after an increased effort to trace
people. An insurance policy would
be possible after certain agreed
efforts in tracing had been delivered.
»Returning any amount of the £100
billion GAs into the economy would
quickly be a significant boost to the
UK economy.
»Those who were bequeathed
“everything” in wills may not
have received “everything”, and
a concerted push to resolve GAs
would enable speedier, more
accurate closure of probate.
»A fiscal dividend: where inheritance
tax thresholds are breached, these
assets are now taxable, and where
the asset is a pension, tax will also
be due.
Those who were
‘everything’ in
wills may not
have received
»The industry is aware that
consumer trust needs to be
rebuilt following the financial
services crisis of 2008. Doing
one’s utmost for the customer
would pay dividends here.
»Cybercrime concerns will require
investment in legacy systems
and consequently legacy data.
»A significant re-engagement
selling opportunity.
»For the pension annuity industry,
reserves held can be released,
reducing capital requirements.
»Compliance with GDPR and
the FCA’s principles of TCF.
»Significantly reducing customer
enquiry workloads, saving in
considerable overhead expense.
»Providing a “notify once”
solution for change of
circumstance presents a tangible
customer service benefit.
»A cost-effective way of
maintaining up-to-date personal
details for child trust accounts.
»Supports the pension dashboard
initiative by linking consumers
with historic multiaddresses to
their pensions.

This article was sponsored by Vestigium Services Limited. The Parliamentary Review is wholly funded by the representatives who write for it. The publication in which this article originally appeared contained the following foreword from The Rt Hon Theresa May MP.

The Rt Hon Theresa May MP's Foreword For The Parliamentary Review

By The Rt Hon Theresa May MP

This foreword from the then Prime Minister appeared in the 2018/19 Parliamentary Review.

British politics provides ample material for analysis in the pages of The Parliamentary Review. For Her Majesty’s Government, our task in the year ahead is clear: to achieve the best Brexit deal for Britain and to carry on our work to build a more prosperous and united country – one that truly works for everyone. 

The right Brexit deal will not be sufficient on its own to secure a more prosperous future for Britain. We also need to ensure that our economy is ready for what tomorrow will bring. Our Modern Industrial Strategy is our plan to do that. It means Government stepping up to secure the foundations of our productivity: providing an education system that delivers the skills our economy needs, improving school standards and transforming technical education; delivering infrastructure for growth; ensuring people have the homes they need in the places they want to live. It is all about taking action for the long-term that will pay dividends in the future.

But it also goes beyond that. Government, the private sector and academia working together as strategic partners achieve far more than we could separately. That is why we have set an ambitious goal of lifting UK public and private research and development investment to 2.4 per cent of GDP by 2027. It is why we are developing four Grand Challenges, the big drivers of social and economic change in the world today: harnessing artificial intelligence and the data revolution; leading in changes to the future of mobility; meeting the challenges of our ageing society; and driving ahead the revolution in clean growth. By focusing our efforts on making the most of these areas of enormous potential, we can develop new exports, grow new industries and create more good jobs in every part of our country.

Years of hard work and sacrifice from the British people have got our deficit down by over three quarters. We are building on this success by taking a balanced approach to public spending. We are continuing to deal with our debts, so that our economy can remain strong and we can protect people’s jobs, and at the same time we are investing in vital public services, like our NHS. We have set out plans to increase NHS funding annually by an average by 3.4 percent in real terms: that is £394 million a week more. In return, the NHS will produce a ten-year plan, led by doctors and nurses, to eliminate waste and improve patient care.

I believe that Britain can look to the future with confidence. We are leaving the EU and setting a new course for prosperity as a global trading nation. We have a Modern Industrial Strategy that is strengthening the foundations of our economy and helping us to seize the opportunities of the future. We are investing in the public services we all rely on and helping them to grow and improve. Building on our country’s great strengths – our world-class universities and researchers, our excellent services sector, our cutting edge manufacturers, our vibrant creative industries, our dedicated public servants – we can look towards a new decade that is ripe with possibility. The government I lead is doing all it can to make that brighter future a reality for everyone in our country. 

British politics provides ample material for analysis in the pages of The Parliamentary Review 
The Rt Hon Theresa May MP
Prime Minister