PSCs - Multiple active entries for same individual

[voracityemail]

I found some instances where there is more than one active entry in the PSC list for a given person. Is this correct?

I was assuming that on receiving updated information about a given person / entity CH would update their entry. Or, possibly - if this was held to be a "new" appointment somehow - old entries for them marked as "ceased" like the officers data set.

Examples:

https://beta.companieshouse.gov.uk/company/09663466/persons-with-significant-control
2 psc entries for one person, notified a year apart. Only difference is address, both active.

https://beta.companieshouse.gov.uk/company/09772810/persons-with-significant-control
2 psc entries for one person, notified a year apart. Only change is address, both active.

https://beta.companieshouse.gov.uk/company/10920731/persons-with-significant-control
2 psc entries for one person, notified on same date. 2nd provides extra natures of control.

https://beta.companieshouse.gov.uk/company/08268647/persons-with-significant-control
2 psc entries for one person, notified in different years. Only change is 2nd provides extra natures of control.

[voracityemail]

On thinking - I suppose it's (just) possible that someone provided a day of birth on their update to CH which didn't match your existing one. Speculation as in these ones we can't see that data. That could have lead to CH categorising this as a different individual? However even if this were the case in 3 of those cases there is only one person in your lists, the names match, they're already listed as owning 75% or more of shares e.g. that should indicate another issue!

[voracityemail]

So is the PSC update process like the following then? (It is not entirely clear to me from the forms e.g. the actual update details (PSC04, 5 or 6) e.g. https://www.gov.uk/government/publications/give-notice-of-change-of-details-for-person-with-significant-control-psc04
..or the or the "Give notice of update" (PSC09).
https://www.gov.uk/government/publications/give-notice-of-psc-statements-psc08

• CH just retain all PSC notifications.
• If someone files an update (of an existing PSCs details) this is added to the list. The previous one(s) for that PSC will not be marked in any way e.g. with a "ceased_on" date.
• "ceased_on" would be expected when a company filed that a PSC / RLE / ORP ceased to be so.

What happens if an update is filed to alter a PSCs details (different natures of control) but also has e.g. alternations to the name? How would we know if this was an update to an entry for a previous existing PSC, or a new one? What if the update was to correct an incorrect DOB? Or for a company which had been listed with incorrect name and number initially?

From my reading of the forms it would seem that an update will clear previous natures of control rather than being "additive" - is this correct?

Example:
https://beta.companieshouse.gov.uk/company/08268647/persons-with-significant-control
In the earliest PSC information for Mr. Ross Callister, his natures of control are given as:
Ownership of shares – More than 50% but less than 75%
Ownership of voting rights - 75% or more
Right to appoint and remove directors

The update changes the share ownership and voting rights:

Ownership of shares – More than 50% but less than 75%
Ownership of voting rights - More than 50% but less than 75%

Presumably this update cancels the "Right to appoint and remove directors" also.

[voracityemail]

In the case of natures of control and what applies when:

https://beta.companieshouse.gov.uk/company/10920731/persons-with-significant-control

Two PSC records, Notified on the same day, identical except for Natures of Control:

1) Ownership of shares – 75% or more

2) Ownership of shares – 75% or more, Ownership of voting rights - 75% or more, Right to appoint and remove directors

In this case I can see from the filings that (1) comes about via the Incorporation (filing history date 17 Aug 2017) and (2) from a notification of a person with significant control (filing history date 25 Aug 2017).

The filings make it clear that the NOCs in (2) currently apply. However, simply looking at the PSC list it wouldn't be clear (to me) which of the above applied. Again - if rules on this (the PSC list at CH) are stated somewhere please let me know.

E.g. it could be:
a) If there is more than one statement relating to a PSC only the latest (Notified on) applies.
b) If more than one statement relating to a PSC has the same Notified on date, the latest is the last one returned in the data from the API (in default sort order).

Any advice?

[voracityemail]

Think I've got it - it seems that there's an issue in the process occurring in all my examples:

1. A confirmation statement (or incorporation) is filed stating there is a certain PSC.
2. CH add an entry to the PSC list for that PSC.
3. A PSC01 ("Give notice of individual person with significant control") is filed for that same PSC - as opposed to e.g. PSC04 ("Change of details of individual person with significant control"), PSC05 ("...relevant legal entity with significant control" - for corporate PSCs) or PSC06 ("..other registrable person with significant control" - for "legal persons with significant control") - or their equivalent for other entities.
4. CH then add another entry to the PSC list e.g. there is no check to see if this filing is appropriate.

This filing sequence could be happening because:

• The filer didn't understand that the CS01 / incorporation already covers the PSC reporting requirement.
• More likely in my view: the filer meant to make an update and thought that the PSC01 form was correct for that rather than PSC04 (for individual), PSC05 (for company) or PSC06 (for legal person).

In my examples the relevant filings are:

1) https://beta.companieshouse.gov.uk/company/09663466/persons-with-significant-control
26 Jul 2016 CS01 Confirmation statement made on 30 June 2016 with updates
(This listed Mona Lisa Bashir as a PSC).

12 Jul 2017 PSC01 Notification of Mona Lisa Bashir as a person with significant control on 6 April 2017

2) https://beta.companieshouse.gov.uk/company/09772810/persons-with-significant-control
12 Sep 2016 CS01 Confirmation statement made on 11 September 2016 with updates
(This listed Roger Manuel Carhuatocto Escudero as a PSC).
11 Sep 2017 PSC01 Notification of Roger Manuel Carhuatocto Escudero as a person with significant control on 6 April 2017

3) https://beta.companieshouse.gov.uk/company/10920731/persons-with-significant-control
17 Aug 2017 NEWINC Incorporation
25 Aug 2017 PSC01 Notification of Marc Henham as a person with significant control on 17 August 2017

4) https://beta.companieshouse.gov.uk/company/08268647/persons-with-significant-control
05 Nov 2016 CS01 Confirmation statement made on 25 October 2016 with updates
(This listed Ross John Callister as a PSC).
27 Oct 2017 PSC01 Notification of Ross John Callister as a person with significant control on 6 April 2017