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Incorrect PSC information

How to go about amending info held at Co House?

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On checking the PSC info for a new client (as part of our AML provedures) we've discovered an error.

Sole Director, 100% shareholder with no changes since incorporation in 2013.

On the first Confirmation Statement filed after 6 April 16, a PSC notification was included.  This notification just listed the director and shareholder as someone having significant influence, and not the 75% or more shares / voting rights / right to appoint directors etc.

So the PSC register currently just shows that info.  Confirmation statements filed since then have all just been 'no updates'. 

What's the best way to correct this?  I'm thinking an RP04 with a revised confirmation statement for the 2017 one, with the correct PSC notification?

Assume subsequent confirmation statements are fine to stay on record as 'no changes' once the 2017 confirmation statement is updated?

Also, any potential penalties that could arise here?  

As ever from the Ac Web community - thoughts greatly appreciated! 

Replies (16)

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By Wanderer
01st Jul 2020 06:40

Not sure I'd worry too much about the past ones. I'd probably just file a new Confirmation Statement showing the correct information.

Edit: Matrix below is correct. You can just update the PSC details. Use a PSC04.
https://assets.publishing.service.gov.uk/government/uploads/system/uploa...

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Replying to Wanderer:
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By SimonStone
01st Jul 2020 06:47

Thanks. So a PSC04, backdated to 6 April 2016, rather than correcting the original notification of the PSC made on the first confirmation statement after that date?

The contact centre at Co House being closed is also unhelpful at the moment!

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Replying to SimonStone:
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By Paul Crowley
01st Jul 2020 06:57

Seriously do not backdate. Just get it right now. Reason, nobody including Co house cares about tiny little owner managed companies.
The point of PSC was to uncover the dubious, not the honest.

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Replying to Paul Crowley:
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By SimonStone
01st Jul 2020 08:03

But the PSC 04 form asks for the date that the change occurred, which was technically 6 April 2016. Indeed, it's not even a change, just incorrectly filed in the first instance!

I'm probably over thinking!

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Replying to SimonStone:
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By Wanderer
01st Jul 2020 09:10

This:

SimonStone wrote:

I'm probably over thinking!

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Replying to Wanderer:
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By SimonStone
01st Jul 2020 09:29

That's lockdown for you! The time I'd spend commuting and unwinding can be spent going round in circles and down rabbit holes!

As ever, thank you all for the input.

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My photo
By Matrix
01st Jul 2020 06:21

I would also just update the PSC details. This is separate to the confirmation statement.

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By Paul Crowley
01st Jul 2020 06:33

Ignore the past just get it right now. If someone wanted to know they would have looked at first filings.

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RLI
By lionofludesch
01st Jul 2020 10:11

Another vote for just getting the next one right.

Having no consequences can by a plus as well as a minus, depending on which side of the fence you're on. If no-one else cares, why should you ?

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By johnt27
01st Jul 2020 16:06

Firstly, unless the client is appointing you to do CoSec work and has agreed to the change then it's not your problem to fix and you do have a responsibility to report the discrepancy.

Secondly, if the details on the PSC register are wrong then they should be retrospectively corrected not put right now. In the same way if a director had been appointed 5 years ago but the form wasn't completed for whatever reason. There are statutory penalties that can be levied but in reality they never are.

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Replying to johnt27:
RLI
By lionofludesch
01st Jul 2020 17:01

The key point being ....

johnt27 wrote:
..... but in reality they never are.

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By GlobalTax
02nd Jul 2020 17:30

Yes I am going through the exact same thing correcting a 2016 PSC submission for a UK company with US parent shareholders. I thinking whats the point as lot of additional work which I can charge for but will add no value. Does anyone give importance to PSC ?

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Replying to GlobalTax:
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By Wanderer
01st Jul 2020 17:28

GlobalTax wrote:

Doesn't anyone give importance to PSC ?

Nope. It was a real missed opportunity. The new system was meant to give more transparency compared to the old Annual Return. In practice it normally gives less information.
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Replying to Wanderer:
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By johnt27
01st Jul 2020 17:39

I think nobody did give a fig about PSCs other than a few tax campaigners etc. Problem is with the new AML rules it's now our problem if they're wrong and that means additional scrutiny from all the wrong places...

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Replying to Wanderer:
RLI
By lionofludesch
01st Jul 2020 17:40

Wanderer wrote:

GlobalTax wrote:

Doesn't anyone give importance to PSC ?

Nope. It was a real missed opportunity. The new system was meant to give more transparency compared to the old Annual Return. In practice it normally gives less information.

Less to check. Less to get wrong. A real win-win for CH.

Of course, it's less use.

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