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:
2 psc entries for one person, notified a year apart. Only difference is address, both active.
2 psc entries for one person, notified a year apart. Only change is address, both active.
2 psc entries for one person, notified on same date. 2nd provides extra natures of control.
2 psc entries for one person, notified in different years. Only change is 2nd provides extra natures of control.
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!
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. Give notice of change of details for person with significant control (PSC04) - GOV.UK
…or the or the “Give notice of update” (PSC09).
Give notice of PSC statements (PSC08) - GOV.UK
- 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:
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.
In the case of natures of control and what applies when:
Two PSC records, Notified on the same day, identical except for Natures of Control:
-
Ownership of shares – 75% or more
-
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?