I am seeking clarification from the actual programming team at Companies House.
I have been associated with Cosec software for some years now in programming.
Recently as a programmer orders have been coming in from various non-programmers that we must change PSC wording in our registers to eliminate the concept of PSC’s by virtue of being trustees of trusts and controllers of ‘firms’.
The first request introduced what I consider to be a fictional non-statutory term that has recently been invented called ‘non-RLE’s’ . The statutory guidance seems to make it clear to me that any ‘non-legal-personality’ entity is called a ‘firm’ by PSC statutory guidance. And as such PSC’s that are controllers of a ‘firm’ should appear on the PSC register as such and they must be reported in PSC01 and PSC04 as such.
However my management have been telephone or email discussing with people at Companies House and coming back with demands for changes to our wording that introduces the non-statutory term ‘non-RLE’, whereby the PSC will no longer show up in the register or on the forms as controlling members of a firm, but simply as PSC’s in their own right with no indication they are PSC’s by virtue of being controllers of a ‘non-legal-personality’ entity. It does my head in.
This madness has now spread to ‘trustees’. I am now being ordered to change the wording of the PSC register so that trustees now simply appear as ‘PSC with direct or indirect control’.
The statutory guidance hasn’t changed. The PSC01 has not changed. The XML schemas have not changed. As far as I am concerned there is no such legal thing as a ‘non-RLE’. The technical and legal term as far as PSC statutes is concerned is ‘firm’ and all wording and forms should reflect as such.
If I am correct then can the programming team at Companies House please make clear to the phone answering team that there is no such thing as a non-RLE and that all non-legal-personality entities that are not trusts are ‘firms’ and all wording and reporting should reflect this, as per statutes.
If not, I will put the option into our software and forms will be coming through to Companies House whereby trustees of trusts and controlling members of ‘firms’ will simply be reported as direct PSC’s.
Thanks very much for any help you can offer in this direction.
Best regards
Andrew
Hello Andrew, I will pass this to relevant colleagues for information and comment.
SDN
Thank you very much, Simon. I must apologise for my strong wording. I wrote it in the steam of the moment and without a cool-off period hit the send button.
Thanks again for the assistance.
Regards
Andrew