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Financial Services - De-bunking the Myths

Tue, 25 Nov 2025 13:30:00 GMT

De-bunking some of the myths around Financial Services (‘FS’) efforts to maintain accurate customer data and de-bunking some of the myths around efforts by FS administration departments to locate the Executors and Next of Kin of dead customers.

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Vestigium Services - Who We Are

Tue, 25 Nov 2025 12:49:00 GMT

Vestigium Services Limited (Vestigium’) provides a comprehensive range of services to provide a full
and holistic solution to locating clients’ customers not residing at the recorded address (‘Gone
Aways’), the Executors and Next of Kin of dead customers and for the ongoing maintenance of good
customer data.

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Why Bad Customer Data Presents a Threat to your Pension Scheme

Tue, 25 Nov 2025 12:06:00 GMT

Because it is Costing The Scheme Money.

What is Bad Data?

Where customer data fields such as Address and Date of Birth (DOB) are incorrect.

Addresses may be historic the customer has moved. DOB could have been transposed erroneously
when transferred from manual records to digital or between spreadsheets or even have been given
incorrectly Customers may have married and/or divorced or changed their name by deed poll.

Why does this Matter Financially?

Because you or your’ outsource supplier are using this data to monitor Death Registers to become
aware when your customers die. Bad Data no death match. How many customers do you have over
90 years of age? Does this seem possible?

If you pay out interest from date of death you have an investment mismatch if you are not invested
in cash exposing you to adverse marketing movements.

You may be under or over reserved where the DOB is incorrect where age is a key variable in
calculation of reserves.

Why Does This Matter, The Customer will get in touch eventually?

Not if they are unaware of the existence of your Product. The ‘loved ones’ of the Life Assured? The
Vulnerable?
And you still have the Financial Exposure.
And there is a Regulatory risk. If you don’t know where your customers live or aren’t sure that they
live at the address you have on file, how can you provide sufficient information so that you can make
informed decisions eg:
• Apply appropriate procedures for Vulnerable customers
• Make policyholders aware of options or guarantees in a timely manner
• Prepare Policyholders for retirement from age 55
• Pay out on a funeral plan policy before the funeral takes place

These could have financial consequences- backdating guarantees, options or payments, dealing with
complaints, meeting the Regulator’s expectations.

The Pension Dashboard will help?

OR It will shine a public light on your bad data inflicting a tsunami of queries and complaints and
reputational damage.

Why Does this Matter for Annuities, the Banks will inform us as to a closed account due to Death?

• The account is not closed where it is joint account.
• They do not tell you if the second life predeceases the first
• They may not tell you if the ain life dies first and the annuity should reduce or cease.

Result:
You are paying out annuities to the dead and holding reserves unnecessarily.

How Vestigium can Help?

Vestigium ‘raises the bar’ on tracing and provides an holistic solution

Visit our website www.vestigium-services.com

Talk to our CEO Paul Aggett 07990 570203

paul.aggett@vestigium-services.com

Vestigium Services - Who We Are

Tue, 31 Jan 2023 16:49:44 GMT

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Are you really tracing lost customers, or just playing customer snap?

Tue, 31 Jan 2023 16:45:31 GMT

Are you really tracing lost customers, or just playing customer snap?
Many financial organisations maintain they are undertaking regular tracing of gone away or lost
customers, but in most cases this means employing a third party who has their own list of names
and addresses who provide matches with the information provided from the financial services
company. This is not tracing – this is just playing snap with customers names and addresses.

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Raising the Bar

Wed, 13 Jul 2022 15:17:53 GMT

Gone Aways

The scale of Gone Aways is immense reflecting some +10% of all customers at Life and Pensions companies and +5% of all customers in Asset Managers and Banks. Our evidence is that this number is increasing yearly. Our evidence is also that 15% of these Gone Aways are in fact deceased.
For the avoidance of doubt, our definition of a Gone Away is someone that an Institution knows is not at the address on file. Many in the industry do little to contact the Estate/Beneficiaries of those customers who are known to be deceased, simply awaiting reengagement initiated by their customers’ beneficiaries (which can only occur if the beneficiaries are aware about the policy/asset which in far too many instances is not the case).

Actions to Date and Why the Gone Away Problem is so Acute.

Some in the Industry who have started to address this issue have engaged with companies which provide Digital Linked Address Matching Services (or carry out Digital Linked Address Matching themselves).
This process involves comparing a file of their customers’ name and last known address information to that of available data from companies like credit reference agencies.
Digital Linked Address Matching is ineffective where databases are themselves not accurate, or, with an increasing population mobility, where people have moved out of the area or relocated overseas.
The Death register typically has the name of the hospital and last known address (which could be a Care Home) and the customer may have moved since taking out the policy/investment etc. Mortality screening uses Digital Linked Address Matching, so the lack of accuracy here should be of concern to those employing this service.

It is important to note that, whilst Digital Linked Address Matching may provide some frequency of results, the standard operating procedure is to provide the client with a ‘residency score’ or ‘gold, silver, bronze’ assurance levels. Many of these updates will in fact be erroneous and cause an institution to spend time and effort, with unnecessary cost, writing to invalid addresses. The true success of the Digital Linked Address Matching can only be ascertained following a reengagement process.
The weakness of Digital Linked Address Matching is evidenced by the number of Gone Aways left at an institution following the regular employment of these services.
Most in the Industry stop after this step suggesting ‘Nothing more can be done’.

At Vestigium, we are doing more as detailed below;

Gone Away Solution
Deceased Customer Solution
Holistic Solution

1. Vestigium Gone Away Customer Solution

Vestigium has industrialised the process of forensic tracing for the purpose of asset reunification and/or re-engagement with Gone Away customers, specifically targeted to the Financial Services Industry. This reduces the scale of the issue, fast.
Vestigium’s methodology is to implement researcher guided forensic tracing querying combinations of in excess of 50 data sources on an individual basis to trace a known ‘Gone Away’ individual from their record-held address, to the address which they currently reside at.
Vestigium follows individuals through their address history and confirms at each stage. This is important as some individuals have been ‘Gone Away’ for years and their personal circumstances will have changed a number of times (this can include name changing as well as address changing or expatriation).

The current address is confirmed using recently renewed data sources such as electoral roll, telephone records, information on insurance products bought at the property, right through to open source intelligence and other methods.
When a Gone Away is found to be deceased, this is confirmed using DDRI, HALO, GRO, Probate records. Other genealogical methods may be used in the cases where the Gone Away has been deceased for some time.
Vestigium’s track record is to immediately find c.50% of a file not able to be found by Digital Linked Address Matching, with greater numbers over time. Of the 50% found immediately, Vestigium’s track record identifies c.30% are deceased.
Vestigium works to a targeted 99% accuracy for its results.

Vestigium classifies data into 3 categories; ‘found’, ‘pending’, and ‘never likely to be found’.
For those customers ‘found’, Vestigium provides the new details to its clients to enable them to re-engage.
‘Pending’ means that, in Vestigium’s view, the record held data is adequate for an eventual match, but the customer has yet to emerge into view on data sources to Vestigium’s confidence level of c.99% (an example of this is where a customer has recently moved and is yet to appear on data sources at the new address). Vestigium provides a Repository where these details will sit and are re-researched over time as data sources renew and become increasingly comprehensive, until a current address can be confirmed.
For the Industry this is Live-Archiving, where the Industry hasn’t given up but awaits consumers re-connecting. Vestigium believes this continual method helps institutions meet regulations including the FCA’s Principle 6, Treating Customers Fairly, and assists firms to meet the guidance set out on the fair treatment of vulnerable customers.

Vestigium will sign off ‘bad data’ as never likely to result in a match, so that clients can be confident in discontinuing spending resource on these records.

2. Vestigium Deceased Customers Solution

Vestigium is aiding its clients by tracing the next-of-kin, or Executors, of deceased customers to a current address.
Where customers of institutions have left probate, Vestigium will purchase the Will from the government, and trace the named Executor to their current address using the methods outlined above.
Vestigium provides its clients with both the current contact information for the Executor, and a copy of the Will/Probate documentation.
For those customers who haven’t left Probate, Vestigium employs genealogical methods combined with our above explained tracing methods, to locate the nearest available next-of-kin at a current address. Vestigium provides this information and details of the relationship of the next-of-kin to the deceased customer (e.g. sister/niece/spouse etc.).

3. Vestigium Holistic Solution

Vestigium takes the full customer file and runs a regular ‘Living as Stated’ check provided by our software supplier. This provides negative assurance only; ‘there is nothing that we are aware of that leads us to believe that the customer has moved location or died. It is recommended that this is carried out annually or twice annually.
Following this check there will be customers records highlighted where there is some evidence of change. These records can then be subject to a full forensic trace as per (1) above.

The Regulators Expectations

The FCA’s Final Guidance (16/8) on the Fair Treatments of Long Standing Customers implies that they expect firms to proactively minimise new Gone Aways whilst understanding the key drivers to achieving a reduction in historic Gone Aways, not simply by periodically repeating the same process but taking effective steps to re-establish contact with their customers.
It is not surprising that the FCA has recently launched its consultation on the Fair Treatment of Vulnerable Customers. Such customers may well represent a significant number amongst Gone Aways at some firms.

De-bunking the Myths

Wed, 13 Jul 2022 14:42:00 GMT

Introduction

This paper has been written for the benefit of Non-Executive Directors of FS or Environment, Social and Governance (’ESG’) Committees or Sustainability Committees who may be interested in understanding what their organisation is doing to maintain accurate customer data, keep in contact with the potentially vulnerable customer, and engaging with the Executors/ next of kin of Dead Customers.
It should help these Directors ask the right questions of their Executive teams and gain a clearer understanding of their responses.

Over recent years as the writer endeavours to get FS on-board with doing more to support customers in this area the writer has listened to many statements and questions around this issue, and he has produced this paper for the benefit of senior FS Directors to be used as an aide memoire when confronted with serious stone walling. It was inspired by an old episode of Yes Minister when the Minister had Sir Humphrey Appleby’s’ (‘SHA’) standard replies to his questions already in his pocket when he quizzed SHA, much to SHA’s chagrin.

This paper has as its primary focus the areas of Financial Services which attract retail customers. This paper excludes Banks as a utility (current accounts) but includes Banks as Asset or Investment Manager or Life assurance or Pension provider. (‘FS’). General Insurance is not discussed as this business is usually renewable annually which dictates an annual customer FS interaction.

Definitions

Financial Services as defined above (‘FS’)
Life Assurance – (‘Life’)
Pension Funds – (‘Pensions’)
Asset Management, Investment Management, Trading Platforms, Private Equity, -(‘IM’)
Gone Away Customers – (‘GA Customers’) Customers living at a different address to that address held for them by their FS provider
Back- office administration (‘administration’) – the administration of customer data beyond that captured at point of sale

General Remarks

There has for many years been a strong Regulatory focus on point-of-sale data capture for accurate completion of Know Your Client (‘KYC’) information and for the documentation of customer and client understanding of risk profiling assumptions to address any potential mis selling risk. Costs associated with this work are by and large well embedded into the cost of sale.

This paper’s focus is concerned with FS customer data processes for the maintenance of data accuracy beyond point-of-sale.

It is true to say that maintenance of customer data post sale has not attracted the same level of attention or resource. FS treat administration as the poor relation of new business development housing customer data on out-of-date administration systems staffed by under resourced employees. The cost associated with the maintenance of accurate customer data comes out of the annual management charge (‘AMC’). The AMC is also a source of Profits to FS and costs are tightly controlled. Evidence of Poor FS Administration for the maintenance of accurate customer data,.

The writer’s evidence that the maintenance of accurate customer data is under-resourced stems from the writer’s experience with working on FS customer data. 5-10% of clients’ customers on first review are recorded at wrong addresses and that 30% of the above have died. The writer’s client base is largely IM but there is evidence that Life and Pensions would follow a similar profile.

Indeed, the Pensions Policy Institute talks of £20bn in 1.9m pension pots tied up with bad data issues If this is Pensions alone it would be fair to say that £50bn might be a best guess for the entirety of FS.

It is telling that no accurate assessment is available.

Lowballing the above numbers and assuming only 10% are Dead leads to £5bn not being notified to the next of kin of UK Customers.

At a minimum Fees are being earned and charged without authorisation.

The vulnerable beneficiary spouse in a care home is not being supported financially and at the other end of the financial scale the Exchequer misses out on the Inheritance tax take and the country is not getting the benefit that would accrue by pumping these funds into the economy via payments to legal beneficiaries.

The Australian Securities and Investment Commission supported by Professor Elise Bant of the University of Western Australia in April 2022 fined Westpac Bank A$40m for taking fees from Dead Customers. This followed a previous fine on AMP and the writer encourages the reader to read Professor Bants earlier article ‘Charging Dead Clients is Dishonest really? Who Knew?’ The ASIC is currently clearly taking this matter more seriously than our own FCA but one should not by complacent and rely on the continuation of benign regulation.

At this point the writer would like to compare and contrast the above with the UK Department of Works and Pensions who in a House of Commons Public accounts Committee paper of January 2022 confirmed that 134000 pensioners (largely woman) had had their pensions determined incorrectly to the tune of +£1bn. The writer is not in the business of criticising the Department for the original mistakes made but is essentially in the business of redress. It is telling that the DWP is not looking at paying the estates of these woman if they are dead but pocketing the money as a windfall. It is made more difficult to argue for improved behaviour in FS when the bar has been set so low by government.

On a more positive note the author’s ‘caring’ clients www.vestigium-services.com are starting to make progress in this area albeit for some the work tends to be siloed into project based work competing against other projects for resources rather than holistic and part of Business as usual(‘BAU’) .Indeed the FCA’s own guidelines only follow the project based approach requiring certain actions after certain time periods (see further on).

About the Customer

The customer of FS is of certain wealth and has been or is in employment. The customer profile is aging as more wealth is tied up in the older generation. As the customer ages there is more chance that the customer might be considered temporarily or for the long term vulnerable.

There is scant evidence of FS tracking customers from point of sale to various lifestyle changes (i.e., house moves) to care homes to death. Without this communication it is difficult to understand how compliance with ‘FCA Guidance on the Fair Treatment of Vulnerable Customers’ is being met albeit much of the Guidance is centred around when a customer contacts the FS and little on the other way around.

FS Actions and Myths around the Maintenance of Accurate Customer Data

Why Does It matter?

The Life salesman sells ‘peace of mind’. ‘Your loved ones will be taken care of if you die’. He doesn’t qualify this by saying ‘only if your loved ones know about it’. The customer often has these savings for ‘end of life care’. Not communicating to them at end of life is unethical. The Aged and Vulnerable deserve our care.

We never did this in the past?

Agreed but the world moves on. Technology has enabled cost effective solutions now available

ESG is also new. The S and G is applicable to this paper.

We use Experian, Equiniti etc and they couldn’t find these customers?

Most FS now adopt a form of ‘batch tracing’ on their known Gone Away Customers. It is generally called Batch ‘Tracing’. It is not tracing at all but simply applying some company’s customer file against a FS file and seeing if there is an address match.

This is usually to an accuracy level of <40% ,40-60%,>60% which says it all. It is totally inaccurate as the computer digital match may well be to a different person with standard surnames. Going to a credit agency is senseless as no dead person ever applied for a credit card

Why do Batch Tracing if it Doesn’t Work?

It is used because it is cheap circa £1 a customer and it fools Non-executive Directors and the Regulator that ‘things are being done’. The whole process of locating new addresses is not cost effective due to poor response rates The myth goes on to say that writing out to customers at a new address and asking them to reply elicits reply rates of < 30% hence why bother.

Firstly, the low reply rate will be low if half the new addresses are wrong (see further above).

Secondly by Tracing properly (Right First Time) and working to a 99% success rate on new addresses no mailing confirmation is required. FS can just mail the new address as and when they need to. New addresses take precedence, but old addresses are not deleted in case of the odd (,1% mistake) and also a trail of addresses will greatly assist re-engagement and proof of identity when pay-outs are due at a later date usually on death. Without these accurate new addresses FS has little chance of knowing when a customer has died.

We regularly contact the families of known Deceased. This is a small part of the issue being dressed up as adequate Governance. This applies to the families of customers that have proactively been in touch when a customer has died. One would expect FS to follow up and they do. Few companies however proactively carry out maintenance of their customer data, confirming death and then writing to the Executor/Next of Kin. Proactive contact here is sensitive. Mistakes might be made. FS are not addressing this issue in their BAU process. Right first time Forensic proof is required, and this is generally not being done.

The writer knows of a caring enlightened FD of a large Life and Pensions company years ago before the internet who asked for such a review of his customer base who set aside a flower budget for the inevitable errors. Error rates now should be much lower (<1%) but sadly because of the lack of Right First Time Forensic Tracing and the prevalence of batch tracing (discussed above) with its inaccuracy no one wants to write out condolences to many customers who are still alive! So best to do nothing is the standard approach.

Does Keeping the address current matter and is Gone Away work necessary?

It matters greatly. On Death of the customer the Government Death Register (‘DDRi’) might say ‘Died Norfolk and Norwich Hospital, last known address Norwich’ but if the FS has the customer living in London (at an old address) then FS Mortality Testing will not pick this up. Hence Charging the Dead goes on. Mortality testing is a blunt instrument. This matters not to FS holding bad data reserves, but bad data reserves do not help the individual customer.

'We haven’t stolen the asset; all our customers Executor or Next of Kin needs to do is contact us.’

FS should know that the Executor may not be aware as wills generally say ‘and all other assets to be divided … without naming each and every FS company and product.
FS should also know that Next of Kin may well not be aware of assets held by parents.
FS should also know that Spouses of the dead may be incapacitated (dementia) or in Care Homes.

Losing AUM will be the inevitable result in this exercise.

This may be true for late adopters of proper Governance but the first to engage might find particularly in IM a ‘dividend’ from improved Brand and Reputation.
‘Thank you for tracking me down and informing me of this windfall. I didn’t know. What would you suggest I do with this asset? I trust you’.

For Pension Companies improving mortality testing (see earlier) would potentially release liabilities. For Pension Funds relieving deficits by releasing Reserves would be to the advantage of the Shareholders of the Sponsor company and the Pension Protection Scheme. Life Companies should be reserved. For Pension Annuity Companies notification comes from the Banking Industry closing Bank accounts.

We agree, but not for joint lives.

Seen on a Life and Pensions company website. ‘Last quarter we found the beneficial owner of £1m in unclaimed assets. For retail customers perusing the website this is magnificent! FS practitioners know that this is ‘self-serving propaganda’ and at an average Life policy of £18k this equates to finding 56 customers. They have >30000 Gone Aways. 1-3% Dead customers on the book are a low number.

For a trillion £ industry the writer disagrees.

The cost of this work is inexpensive in comparrison to the over-reserving of funds.

On a current file of active customers having carried out a Digital Health Check on that file the results empirically will be that circa 3% might require Forensic work to locate and 1% might be Dead and require Forensic work to locate Executors and Next of Kin.

This might incur costs of circa £2 when spread over the whole file. Targeted Forensic and Holistic non-project-based solutions can work.

Doing nothing for 3 years after 2 exercises of Batch Tracing in the first 6 months) and hence technically following FCA Guidelines is cost ineffective as it doesn’t achieve the results, if it did, we wouldn’t have this issue!

Charging all customers because some are Gone Away is unfair on the others

This argument is sometimes used by Actuaries who have never understood how insurance works!!

The Overstatement of liabilities (in a Pension Fund) is also a secondary issue to Pension staff as it is a shareholder problem, and everyone likes the comfort of over-reserving.

The consumer and shareholders and Pension Protection Fund and the economy are the loser. Over-Reserving by 1% on Deferred members would potentially release hundreds of millions from the liabilities for the largest 50 DB Schemes.

The Pensions Dashboard Will Not Solve This Issue.

How embarrassing, this argument has been trumpeted for years. The Pension Dashboard will only be a ‘yellow pages’ of where one might look for Pension pots. It is not a proactive help at all to those who don’t know to ask.

The Unclaimed Asset Register UAR is being de-commissioned, it didn’t work.

The BBA My Lost Accounts is a manual post box which some consumers use to contact the Banks but only tells the consumer about dormant assets held (>14 years dormant) and the consumer will get a negative search if their account is 13 years and 11 months old.

Consumers are nervous about supplying personal data to a Repository (as the author knows as he tried). All of these solutions are used to trumpet the message from FS that ‘they are doing ‘things.

There is a possibility that new active business could be administered better than historically i.e. email addresses but Legacy requires remedial action.

What is wrong with not finding the customers Next of Kin and just giving the assets to Charity?

Simple answer - It’s not FS Money to give to Charity. The Banks got away with this argument during Gordon Brown’s term as Chancellor (2008 Banking Act) The argument shouldn’t hold up.

The Dormant Asset Commission now accepts (see Consultation to Expanding Dormant Asset Scheme Feb 2020 Executive summary) that charitable donations should only follow serious tracing efforts. Closed Life and Pensions Companies have a significant Issue because of the large Legacy customer base in run off bad customer data is a significant issue.

Yes, it will cost to solve the Legacy Issue of the Closed L&P industry and this the author fully accepts and has sympathy with the industry. To clear this issue out will require a small change in Regulatory approach. See below.

In the 1990s and 2000s outsourcing of this function became prevalent where Finance Directors took re-engineering savings up front without doing the work themselves by negotiating tight contracts with Outsource Administrators (‘OA’) The OA applied a growth strategy akin to a Ponzi Scheme relying on volume to create value and the required profit margin. BAU processes and business practices were engrained in contracts which are in many cases more than 30 years old.
The result has been little process improvement and reduced levels of customer service and the OA charging high fees for ‘add on’ work which is in turn resisted by FS.

Indeed, the cost associated with Tracing is only part of the picture as OA charge heavily for producing data extracts, retyping new addresses and of course mailing everyone (see earlier for why this isn’t necessary following right first time tracing activity. All the above work is not seen as BAU but a one-off project which is abandoned if resource is required for other more urgent activity.

Added to this Historic Data collection could not include before the internet email addresses and not until recently, mobile numbers.

Customers are more mobile since the days of Industrial door to door pensions and now would move home 3 times in the life span of a 25-year Life policy.

The government Death register the Ddri has only been in operation since late 2006 and is only updated for UK citizens dying within the UK. A wrong address held by FS would not activate a Ddri match. Mortality testing as it is called within Life and Pensions is a blunt instrument indeed.

Prior to 2006 there is no digital solution to unravelling the number of Dead customers on the FS books apart from employing tracing agencies. This is slowly happening, but FS priorities remain maintaining Income. Looking after customers or their next of kin is often a secondary consideration. Non-contact with customers saves time and cost.

Thoughts To Finish

Know Your Client (‘KYC’) what does it mean in practice if not maintaining adequate records is acceptable practice?

The FCA will be focussing on how FS ensure ‘Good Outcomes for Retail customers. How is this possible with such high rates of Gone Away customers?

Looking after the ‘Vulnerable Customer’. How do we know who is vulnerable beyond point of sale if we are not maintaining good customer data?

How many Dead customers are on FS books? Can we ask? How will the Executive team know how to answer if the question is asked?

Why should FS pay? Share registry firms are charging the customer for tracing work. This seems reasonable when the customer has been out of contact. It would be churlish of the customer to complain about small costs being netted off notified windfalls belonging to dead family members.

Can we have a result based FCA Guideline which asks for reporting on the volume of dead customers held on the FS books and which expects no long-term dead customers being uncontacted (say >1 Year)

Questions to ask your Executive Team

How many dead customers do we have?
How do you know?
How many over the age of 100/90/80?
Is your profile of customer ages above in line with country statistics?
How much are you spending on tracing end to end including mailouts to wrong addresses?

About the writer.

Paul Aggett is a qualified Accountant FCA with+30 years’ experience in FS in Life and Pensions and Asset Management and Chartered Accountancy and FS Consultancy. Paul now is Managing Director of Vestigium Services Limited www.vestigium-services.com which is a relatively new Tracing Agency working with caring FS companies addressing the above issues.

Extensive asset tracking for your customers

Thu, 07 Oct 2021 16:07:00 GMT

It is easy nowadays for consumers to lose track of their assets and difficult for financial institutions to keep up with their increasingly mobile customer base. A customer might have moved address and not notified your institution, or even had an account open for them as a child that they didn't know about until recently.

No matter what has happened, an asset that is marked as your customer’s is still theirs, and it is best practice to keep up to date with their ever-changing circumstances. The hard part is knowing where to start, right? Well, not anymore.

Vestigium offers an extensive tracing service for the strict purpose of asset reunification. We will re-research currently un-found gone-aways against continuously updating data sources, including the Vestigium Services consumer database. We work to save your financial institution time and effort.

To get your institution started, we have put together a breakdown of our services below:

Tracing Gone Aways

Vestigium implements researcher guided forensic tracing, querying combinations of data sources on a case-by-case basis to trace a known ‘gone away’ individual from their record-held address to the address which they currently reside at.

Vestigium follows individuals through their address history and confirms at each stage. This is important as some people may have been ‘gone away’ for many years and their circumstances would have changed several times (this can include name changing, as well as address changing, or expatriation).

We work to a targeted 99% accuracy to ensure your re-engagements, KYC & AML checks are not wasted effort.

Many of your gone away customers will be deceased. How many customers does your organisation have active on its books over the age of 85? Does this seem plausible to you?

For those who are deceased then, the next service applies to them.

Tracing Executors & Next of Kin

If someone has passed away, your institution may not already be aware (either because the death has not been reported to you, or a ‘gone away’ customer is found to be deceased upon the conclusion of a trace as above). Or your institution may be aware that the customer is deceased but have had no engagement from the estate.

Vestigium can help.

If Probate has been left by the deceased, we will purchase the probate documents from the government, and trace a named executor to their current address.

For those who haven’t left probate, we employ genealogical methods alongside our gone away tracing to provide current address details and the relationship of the next-of-kin to the deceased customer. This is referred to as Next of Kin Tracing.

Keeping Your Data ‘Good’

For many institutions who have made inroads to the issue of gone away and deceased customers, they are now looking for a way to keep those efforts up-to-date.

The Vestigium Living as Stated Health Check is an automated screening tool that identifies where there is evidence that any of your customers’ information is potentially incorrect or out-of-date and therefore provides a negative assurance against the accuracy of the rest of the book. Vestigium analyses the results of this check and provides you with a report containing recommendations on forensic tracing work required to rectify any bad customer data.

This allows institutions to embed strong processes to; firstly reduce the amount of gone away customers arising, and secondly quickly rectify where they do arise. This in turn reduces the need for costly project-based remediation work. The service also provides an enhanced mortality screening tool that identifies where further investigation is required to identify death.

Working with Vestigium

We believe our methods help institutions meet regulations including the FCA’s Principle 6, treating customers fairly, and assist firms to meet the guidance on the fair treatment of vulnerable customers and ESG values.

A client can become vulnerable at any time. Keeping in touch allows you to ensure that if anything happens, you are there for them with suitable advice, products, and services.

All this whilst significantly reducing the amount of gone away and deceased customers held on your institution’s books and saving you the time and money from engaging with the wrong people found via low accuracy digital matching.

Whether it's Pensions, Unit Trusts, or Premium Bonds, we can help you.

Get in touch today and help your customers be reunited with lost assets.

Responsible Investing

Wed, 05 May 2021 18:51:00 GMT

As the world begins to deal with the larger implications of irresponsible and unsustainable practices and the impact they’re having on our planet and our population, consumers are migrating to responsibly investing their savings in green, sustainable enterprises. The focus of financial investments is no longer solely on returns, as investors increasingly seek out investment opportunities that also deliver positive social and environmental impact. In a recent article by the Express it was reported that:

Sales of ethical and sustainable investment funds have tripled over the past year, with savers investing in fast-growing, clean and renewable energy companies. Last year fund sales trebled to £10billion, thanks to people worried about Covid and the planet.

The boom in green investment is not only here to stay, it’s here to forcibly change the way that we operate and do businesses across the globe, for the betterment of all mankind.

What is the difference between ESG and SRI?

Responsible investing, SRI and ESG in particular, are now buzzwords and growing in popularity across most industries. We look at the difference between these two terms below, but in essence, SRI is responsible investing and ESG is how the impact of those investments are measured.

What is SRI?

According to Investopedia,

socially responsible investing (SRI), is an investment that is considered socially responsible due to the nature of the business the company conducts.

Those that focus on socially responsible, ethical investing are looking for positive, social change from their investment. They look to businesses that give back to communities, providing support and development for all.

What is ESG?

Environmental, Social, and Corporate Governance (ESG) refer to the three central factors used by socially conscious investors to measure the sustainability and societal impact of a potential investment. ESG as defined by Investopedia:

Environmental criteria consider how a company performs as a steward of nature. Social criteria examine how it manages relationships with employees, suppliers, customers, and the communities where it operates. Governance deals with a company’s leadership, executive pay, audits, internal controls, and shareholder rights.

Why is an ESG / SRI model important for businesses and financial institutions?

Born into the digital age, millennials (defined as born between 1980 and 1996) are inherently aware of the devastating impact that consumerism has across the planet. With access to immediate information and the ability to read personal experiences from their peers in the form of business reviews, having sustainable models of Environmental, Social, and Corporate Governance is paramount for the future of every business. Simply put, if businesses are to achieve their investment and growth goals, they will need to invest in the future by realigning their models and practices with the mindset of their younger, socially conscious audiences. Furthermore, if we are to have a future at all, businesses must raise the bar with socially and environmentally responsible, sustainable practices.

Why it is important for financial institutions to reconnect with customers

Fri, 09 Apr 2021 11:46:00 GMT

In this technical age of digital and social communications, amid a global pandemic and an uncertain future, it is now essential for financial institutions to humanize their approach to business and reconnect with the customer. In this blog, we explore some of the numerous benefits that a concerted effort to re-engage with lost customers can have on the customers and financial institutions alike.

Boost Personal and Community Wealth

One huge benefit of reconnecting with lost customers is, of course, the boost in personal and community wealth that this can provide. With falling interest rates and increased unemployment figures, 23% of the UK population alone are now living in financial poverty.

Reuniting customers with lost assets and dormant accounts can only have a positive impact on both the finances and the wellbeing of those that are contacted, many of whom are vulnerable people. With so many families living in poverty, and billions in unclaimed funds across the industry, even the smallest of reconnections can help change the quality of a customer’s life for the better.

Rebuild Customer Trust in The Industry

Reconnecting with your customers and staying abreast of any changes in circumstance will help ensure you can provide a service perfectly aligned with their needs.

The changes and daily restrictions we have experienced over the last 12 months will impact the lives of individuals and communities for many years to come and many families have looked to their financial institutions for help.

It is important to remember that any customer can become vulnerable at any time. Keeping in touch allows you to ensure if, or when, your customer becomes vulnerable, that you are there for them with suitable advice, products, and services. Reconnecting with customers that are owed money builds trust and opens the door to allow them to reclaim their funds and reach out to you, should they need it.

Open The Door To Cross-Selling

With customer trust and reconnection comes the opportunity to cross-sell and upsell your products and services. Positioning your institution as one that cares about the recovery of unclaimed funds, repaying owed money and reactivating dormant accounts paves the way for a longer relationship with the customer.

In a world where the consumer has a veritable choice of options for financial support and services, the trust and integrity you can display simply by reconnecting speaks volumes and displays a level of care and commitment that sets apart financial institutions from their competitors.

Meeting Regulatory Requirements

The expansion of The Doormant Assets Scheme by Her Majesty’s Treasury (HMT) is in support of reuniting customers with lost assets and unclaimed funds. As the consultation document states in the foreword:

“Dormant assets remain the rightful property of their owners, and the scheme guarantees their right to reclaim the amount owed to them at any time. This underpins the entire scheme, and is crucial to ensuring that everyone—from consumers to firms—trusts and supports it”

This means that by law, financial institutions are responsible, and actively encouraged to reunite customers with their owed money, unclaimed funds and dormant assets. With this in mind, actively reaching out to your customers can save a lot of time and resource spent trying to track down owners of accounts that become unnecessarily dormant through lack of communication.

Ultimately, when financial institutions actively and strategically reconnect and engage their customers, this creates a level of humanity, support and trust, which is required to help businesses evolve and safeguard themselves and the customer against accounts and shares becoming dormant. In turn, the trust gained can open the door to cross-selling, and the ability for institutions to provide relevant and suitable support in the event of a customer’s change of circumstance.

At Vestigium Services, we provide support, advice and tools to help you reconnect and stay connected with your customers. You can learn more about the services we offer, here.

A Stealth Tax on the Vulnerable

Wed, 13 Jan 2021 13:03:00 GMT

In January 2021 the UK Government elected to expand the Dormant Assets Scheme, a program where unclaimed financial assets are put towards social and environmental initiatives.

The boost means dormant assets across the insurance and pensions, investment, wealth management, and securities sectors have been made available to help UK citizens recover from the severe financial impact of the coronavirus pandemic. However, your customers will still be able to claim their assets in full at any time.

John Glen MP, Economic Secretary to the Treasury, said:

“Banks and building societies across the UK are working tirelessly to reunite people with forgotten assets. But on occasions where this isn’t possible, it’s right that these funds are used to tackle some of the UK’s most pressing social and environmental challenges. The expansion of the scheme will mean more people are reconnected with their assets, whilst also making more money available for good causes.”

Whilst Mr Glen’s statement rings true, we want to ensure that reuniting people with forgotten assets is never an impossible task by encouraging as many people as we can to register their details with us so we can match them with our caring Financial Services clients.

The financial organisations working with Vestigium Services are intent on tracing their lost and gone away customers, or their customers’ loved ones/Executors/next of kin where the customers are deceased. A significant proportion of lost assets belong to vulnerable people including the elderly and mentally or physical incapacitated, many of whom aren’t catered to by existing dormant asset search services.

We aim to meet the needs of gone away customers whilst supporting the vulnerable through reuniting our clients with as many of their lost customers as possible.

Why Bad Data is Costing Your Organisation

Mon, 02 Nov 2020 22:05:00 GMT

Bad Data is the term used when customer data fields such as Name, Address, or Date of Birth (DOB) are incorrect, incomplete or corrupt.

There are many reasons for bad data, addresses may be historic as the customer has moved home or business address. Customers may have married and/or divorced or changed their name by deed poll. DOB could have been transposed erroneously when transferred from manual records to digital or between spreadsheets or even have been given incorrectly.

Why does this matter Financially?

This matters because you or your outsourced supplier use this combination of data to monitor Death Registers to become aware when your customers die.

Bad Data = No deathmatch.

How many customers do you have over 90 years of age? Does this seem possible?

If you pay interest from the date of death, you have an investment mismatch if you are not invested in cash exposing you to adverse market movements you may be under, or over, reserved where the DOB is incorrect where age is a key variable in the calculation of reserves

Why Does Address Matter, The Customer Will Get In-touch Eventually?

Not if they are unaware of the existence of your Product. The ‘loved ones' of the Life Assured? The Vulnerable?

And you still have the financial exposure above.

And there’s a regulatory risk: If you don’t know where they live or aren’t sure that they live at the address you have on file, how can you provide sufficient information to make informed decisions, such as:

Apply appropriate procedures for vulnerable customers?
Make policyholders aware of options or guarantees in a timely manner?
Prepare policyholders for retirement from age 55?
Payout on a funeral plan policy before the funeral takes place?

These could also have financial consequences – backdating guarantees, options or payments, dealing with complaints, dealing with the regulator.

This is apart from the FCA and ABI requirements relating to Gone Away customers, GDPR etc.

Why Does This Matter for Annuities, the Banks Will Inform Us as to a Closed Account Due to Death?

The account is not closed where it is a joint account.
They do not tell you if the second life predeceases the first.
They may not tell you if the main life dies first and the annuity should reduce or cease.

Result: You are paying out annuities to the dead and holding reserves unnecessarily.

How Vestigium Services Can Help

Vestigium raises the bar on tracing and provides an industry holistic solution through the use of three key products:

Gone Away Solution

For known or suspected Gone Aways and for general Data Clean

Deceased Customer Solution

For Known Deceased Customers and Deceased highlighted by Gone Away forensic tracing

Holistic Solution’ ‘Living as Stated’

Providing regular maintenance of your customer database with a level of assurance on your ‘good’ customer data and highlighting anomalies with your customer data which require forensic tracing investigation

For more information on the services we offer, visit our services page.

For more information on how to rectify this, please read Vestigium's marketing document here.

Governance 360 - A Link Group Podcast

Thu, 17 Sep 2020 09:09:00 GMT

In late 2019, our CEO, Paul Aggett, was asked to partake in the recording of a Podcast for Link Group's Governance 360 series. The podcast talks broadly about lost assets, the benefits of a concerted effort to reduce dormant assets across the financial services industry, and about Vestigium Services as a business too.

Above: Paul met with Lindsey (Centre) and Jai (Left) to discuss.

You can listen to the podcast on any of the major streaming services, links below:

Acast - https://shows.pippa.io/governance360/episodes/helping-ordinary-people-find-their-lost-assets

Apple - https://podcasts.apple.com/gb/podcast/governance360/id1484075002?i=1000455281351

Google - https://podcasts.google.com/feed/aHR0cHM6Ly9mZWVkLnBpcHBhLmlvL3B1YmxpYy9zaG93cy81ZGE5YTVjOWQxYzNhN2MwM2E2MmYxOWE/episode/NWRiNmQ4NDc4N2ExYmU0ZDdlZWU3NTBh?sa=X&ved=0CB8QzsICahcKEwj4-Z6g1_TqAhUAAAAAHQAAAAAQAw&hl=en-GB

Spotify - https://open.spotify.com/episode/2C6XwpdjvxSG9KGBzab0xu?si=jiirP48_RXO6XjFZtBU7LA

YouTube - https://youtu.be/hC5fhYRWZ6o

Thank-you.

Expansion of the Dormant Assets Scheme

Thu, 17 Sep 2020 08:44:00 GMT

At Vestigium, we welcomed HM Treasury's (HMT) and Department for Digital, Culture, Media & Sports (DDCMS) consultation on expanding the dormant asset scheme. As the document states in the forward: "Dormant assets remain the rightful property of their owners, and the scheme guarantees their right to reclaim the amount owed to them at any time. This underpins the entire scheme, and is crucial to ensuring that everyone—from consumers to firms—trusts and supports it."

The consulatation investigates how it might be possible to include other asset classes in the currently active dormant assets scheme (which runs for banks and building societies). For some, this expansion may generate queries on what the best way to make this a reality is, for example where dormant shares are subject to full restitution - but that is what the consultation seeks to understand and iron out. Vestigium supports the principles of the Expansion, especially 'Principle 1' which states, "participants' first priority is to trace and reunite people with their assets". Vestigium has proved, via its current client base, that much of this money which is classed as dormant can be returned to its beneficial owners.

A copy of the consultation can be found here.

If you are looking to partake in the expanded dormant assets scheme, and want to follow the first principle of 'Reunification First' then Vestigium Services can help you and your organisation. Please feel free to get in contact with us via info@vestigium-services.com.

Thank-you

£20bn of Lost Pensions

Wed, 16 Sep 2020 15:47:00 GMT

The scale of the UK’s lost pensions mountain is exposed by research carried out on behalf of the ABI. In the largest study yet on the subject, the Pensions Policy Institute (PPI) surveyed firms representing about 50% of the private defined contribution pensions market. From this PPI found 800,000 lost pensions worth an estimated £9.7 billion. It estimates that, if scaled up to the whole market, there are collectively around 1.6 million pots worth £19.4 billion unclaimed – the equivalent of nearly £13,000 per pot.

This figure is likely to be even higher as the research did not look into lost pensions held in the public sector, or with trust-based schemes typically run by employers.

A copy of the PPI's report can be found here.

This estimated figure of £19.4bn is significantly higher than the previous estimate of £400million, the truth is nobody knows the total value - this is concerning in itself. What is known is that the figure is vast. Vestigium Services believe that much of these finances can find their way back to their beneficial owners by employing a caring and concerted effort. If you are looking for your policy holders, please feel free to get in touch with us via info@vestigium-services.com for more information.

The Commission on Dormant Assets Report 2017

Wed, 16 Sep 2020 14:58:00 GMT

The Government first began to address the issue of Dormant Assets in 2008 with the Dormant Bank and Building Society Accounts Act. This led to significantly enhanced reunification of dormant assets by our banking institutions. In December 2015, Nick O'donohoe was asked by the Minister for Civil Society, Rob Wilson, to chair the new independent Commission on Dormant Assets. The Commission’s remit was to look beyond simple bank and building society accounts and consider the full spectrum of potentially dormant financial and non-financial assets. Its ambition was to encourage steps that could minimise existing and future dormancy, reunite assets with their beneficial owners and, where that was not possible, recommend a mechanism to recycle dormant funds to be used to address key social issues throughout the UK.

A copy of the Commission on Dormant Assets Report 2017 can be found by following this link.

If your organisation is wanting to locate up-to-date contact details for its customers, and prevent assets becoming dormant Vestigium Services can help. Please get in contact with us via info@vestigium-services.com

Thank-you.

Vestigium Services in the Parliamentary Review

Thu, 03 Sep 2020 14:34:00 GMT

Vestigium were recently featured in the Parliamentary Review as a 'Best Parctice Representative' partner. The article discusses how Vestigium Services are working 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).

Follow this Link for the Article

If you would like further information about Vestigium, or are yourself from a Financial Services organisation who are looking for their Gone Away customers. Please feel free to get in touch with us on info@vestigium-services.com