Dr G’s case had twice been before TPO by the time of the latest decision in June. Her partner, Mr T, had died whilst entitled to benefits under a SIPP and despite Dr G having provided substantial evidence of their personal circumstances, joint financial commitments and intentions to provide for each other in their wills etc., the scheme administrator had refused to pay her any of Mr T’s death benefits.
The scheme administrator accepted that Dr G was potentially eligible for benefits under the scheme rules, but claimed that, having taking account of all the relevant factors (listed in minutes of an internal meeting), it had used its discretion to determine that she should not receive any form of death benefit. It also claimed that TPO was only able to interfere with the exercise of discretion where the decision-maker acted improperly in making their decision.
TPO found that, while the scheme administrator had taken into account all the relevant factors in making its decision, it had not shown a ‘causative link’ between the facts and the conclusion that it reached. In the absence of any documented reason to support the decision, this suggested there was "no supportable reason" for it. Further, the administrator had placed too much weight on what Mr T would have wished to happen, rather than considering whether there was a reason to distribute benefits to Dr G given that she was both a dependant (as she was in a financial relationship of mutual dependence with Mr T) and an eligible recipient (as she had an interest in Mr T’s estate) in her own right.
The absence of reasons meant it was thus impossible to establish whether the administrator had correctly exercised its discretion under the scheme rules. TPO directed the administrator to reconsider the distribution of death benefits and to communicate this decision to Dr G with a fully documented rationale for its conclusion.