Financial Institutions Returns: Problem Solver

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Issue Date: February 2015
Overview
It isn’t easy to get everything right all the time. We hope that information in this
document will help you eliminate some of the things that can cause extra work.
We’ve brought together some of the things we see most often or are frequently asked
that can cause a return or submission to be rejected or queried.
We’ve described some of the common problems and have suggested things you
can do to avoid them or solve them.
Data security
A. Data protection
Your responsibilities under the Data Protection Act 1998 (DPA)
We do not set any particular security standards for data sent to us from businesses but
are happy to work with anyone who needs to send us data to help secure it. Under the
DPA, YOU are responsible for the security of personal data until we have received it.
B. Sending returns
Although you are responsible for the security of the data until we receive it we
recommend that all financial institutions should send their data as securely as
possible.
Links to the permitted formats and methods of submission will be detailed in your
notice
C. Encryption
I
SET
Returns submitted via our SET service have to be encrypted using the HMRC SET PGP
key. Registered users of the service will automatically be supplied with the
appropriate key in good time before their submission is due
II
Non SET users
If you are not able to use our SET service we would recommend that you encrypt the data
and send it by the alternative means detailed in the notice.
If you cannot locate your notice or your hardware or software prevents data encryption,
please contact CNI in Cardiff using the contact details at the end of this document
Returns being sent by e-mail can only be protected using WinZip
Returns being sent on physical media such as CD, DVD or USB stick can be protected
using WinZip or any form of self-decrypting software

If you use WinZip we recommend that, you use at least v9 and the 256-bit AES
option, together with the Mask Password Option. We also recommend that the
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
password selected is at least 20 characters long, contains upper and lower case
characters, at least one special character and contains no dictionary words.
If you are password protecting your return using PGP you must select the option
‘PGP SELF DECRYPTING ARCHIVE.
D HMRC DCDM PGP public key
Due to the low usage of the HMRC DCDM PGP public key and the availability of other
methods of securely submitting data, the above key has been withdrawn. Returns can
be submitted via our SET service OR encrypted using WinZip and submitted by the
alternative means detailed in the notice
E Return of Media
Since 1 April 2010 HMRC no longer returns any media to financial institutions once we
have processed Statutory Information Returns. HMRC have introduced a comprehensive
data security programme, which is under constant review, and part of this programme
required the Department to minimise the risks associated with the movement of data on
portable media.
In this regard, a key risk was the possibility of media being lost or intercepted in transit so
wherever possible we are adapting our processes to reduce the need to move media. We
have received legal guidance about our responsibilities concerning reusable media such
as USB storage devices. We have been advised that we have no legal obligation to return
media although we have previously done this on request. We have looked at ways of
deleting data from reusable media but we found the process inconsistent as we were not
able achieve a guaranteed level of cleansing.
We realise this change will have implications for data providers who use reusable
media but we think that, on balance, our obligation to protect customer data must
take precedence. We are sorry for any inconvenience this may cause you but we
hope that the availability of our Secure Electronic Transfer (SET) service mitigate this
Submission information/labels/contact details
A submission information
I SET
All SET returns should be named in accordance with the SET file naming convention. The
SET file name contains the following information
1. HMRC reference
2. Sub number
3. Batch number of the file for that reference/sub number/year
4. Total number of batches being submitted on this occasion for that reference/sub
number/year
5. Year
All five items are required to enable us to process the file correctly
Each file needs its own name so that we can identify it. Please do not zip files together or
in groups. Without the correct information we will not be able to process the data. To
avoid the return being rejected or queried you must always use the SET file naming
convention:
HMRC Ref_Sub number_Batch number_Total number of batches_Year
Example: A9876 _ 03 _ 001 _ 001 _2011
HMRC Ref
Sub number
Batch
number
Total number of
batches
Year
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Using the naming convention would create a file name that would look like this:
A9876_03_001_001_2011
For example, if on this occasion a Financial Institution with the HMRC ref A9876/03 is
sending in two batches for 2011 the files (batches) would be called:
A9876_03_001_002_2011
and
A9876_03_002_002_2011
Batch 1
Batch 2
If the return was a single file (batch) it would be called:
A9876_03_001_001_2011
II Physical media
Submission documents (media report information) are required to identify the sender and
package contents. If the details on the document are incorrect please tell us the correct
details by emailing the address at the end of this document.
We have redesigned the submission documents to fit onto one page and wherever
possible will include them with the notice. The new version also asks for the number of SI
03/3297 (EUSD) cases included on the return where appropriate. If the exact figure is not
readily available, a reasonable estimate will suffice. If you are unable to provide this
information, your return will not be failed and you will not be penalised.
If you need additional submission documents please contact CNI.
If you are not able to submit using SET (which reduces the risk of loss of your data in
transit) we would very strongly recommend that you send all returns so that they can be
delivered during our normal office hours (08.00 – 16.30 Monday to Friday). We also
strongly recommend you send them in tamperproof / tamper evident packaging with
documentation that details:
• HMRC ref
• sub number
• company name,
• year of return
• contact details of sender
If you send more than one media item (CD, DVD, memory stick) in the same package
please make sure each item is clearly labelled so that it is identifiable and we can match
it to the paperwork.
If you send us anything that holds personal data you must consider the security of that
data.
You are responsible for the media and the data it holds
until it is received by HMRC.
B labels (physical media only)
Previously very few of the labels that CNI issued were used, so from 2011‐ 12 we will not
send out labels automatically. The information required with any physical media sent to
CNI will instead be detailed in the notice. We will however still provide labels on request.
If you still require labels please e‐mail CNI at the address at the end of this document
quoting the reference (including sub number) for which you require labels.
When you send us media please make sure you identify each item separately. This should
include:HMRC reference and sub number
Name of Financial Institution
Tax year
For example, if you are sending us three CD’s, all three should show the relevant HMRC
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reference and sub number, your institution's name and the tax year.
C Contact Details
Your Contact details
Please keep us informed about changes to contact details. We are required to send all
correspondence to your registered office address but we also need the contact details of
the person who submitted the return. Please keep this information up to date
HMRC Contacts
Unless you are using SET (Secure Electronic Transfer) send your return to the Centre for
National Information at the address at the end of this document
Do not send your return to anywhere else in HMRC.
For advice on how to submit returns or for advice about how to complete the forms
contact CNI at the address at the end of this document
To request OCR forms please telephone HMRC’s orderline on
0300 200 3610
(8am to 10pm Monday to Friday)
Permitted return formats
1 creating your returns
Each return type has more than one format for submitting the return and you can submit
your return in a single format or in a number of formats. Normally most institutions
submit their return under a single sub number which is usually sub 01. E.g. A1234/01.
If you are submitting your return as a number of files produced by separate systems or in
different formats ideally each file should be submitted under its own sub number.
For example if you have a text file produced in London, a separate text file produced in
Belfast plus a few exception cases which can be submitted using the HMRC spreadsheet
the ideal return should be under 3 sub numbers
01
02
03
London
Belfast
Spreadsheet
If you need additional sub numbers to submit your return please contact us to discuss
your requirements as only sub numbers allocated by CNI Cardiff and agreed in advance
should be used. If we agree to open new sub numbers we will agree with you short
internal descriptions such as those above. These descriptions will only be used in
discussions with yourself should a query arise with the return received.
Current formats
2 Magnetic Media Specifications
As advised in Bulletin 8 we renamed these specifications “Electronic Flat Text File
Specifications”
Electronic Flat Text Files. This is our preferred option as this type of file loads directly onto
our systems. The files are created using the relevant Electronic Flat Text File specifications
and are suitable for returns of all sizes. The latest version of the specification can be found
on our website and can be accessed using the relevant link in the section ‘What is
reportable’
3
HMRC spreadsheets
HMRC has recently developed spreadsheet formats for all of the schemes covered by this
document. The spreadsheets can be accessed from our web site using the links in the
section ‘What is reportable’. Only the latest spreadsheet published on the HMRC web site
will be accepted. The only limitation on the spreadsheet is the number of lines available
in the version of Excel that you are using. If you currently submit your return as a text file
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you can continue to submit in that format.
4 Paper forms
Paper OCR forms. These are our least favoured option for a variety of reasons.




It is not possible to encrypt paper forms so these are the least secure option.
You can only use original forms supplied by HMRC as photocopies and
downloaded forms are not acceptable.
The forms are usually laborious to complete.
The quality of the data is directly affected by the quality of their completion.
For these reasons if you are not able to submit a plain text file we would prefer you to
use the relevant HMRC spreadsheet.
Return problems
A Failure to follow the published guidance
The BBSI (formerly S17) page on the Gov.uk website contains detailed guidance about
how returns should be submitted. We receive requests for assistance from people who
have not read the guidance or are not aware it is available. Please ensure that everybody
involved in creating or submitting returns knows where they can find the guidance. If you
are reading this as an electronic document select the hyperlink above or copy this web
address into your browser address bar:
https://www.gov.uk/government/publications/type-17-and-18-bank-building-societyinterest-and-other-interest-returns-of-interest-and-eusd/bank-and-building-societybbsi-european-union-savings-directive-eusd-and-other-oi-returns-of-interest
1
Electronic Flat Text Files
In the Electronic Flat Text File specifications you are required to create a flat text file
consisting of a series of fields.
A) The fields must be in the correct order and the correct length.
B) If you set the length of a field in the type 1 record the length of the field should be
long enough to accept your longest record. All other occurrences of the field in
the return should be the length you have set. Normally you will put your
information at the start of the field (left justify) unless otherwise detailed in the
specifications and add spaces on the right until the field is the length specified.
Some fields that you set are linked together, for example ACCOUNT ADDRESS LINE
LENGTH and ACCOUNT ADDRESS LINE COUNT. If you set these as 30 and 4 it
means that every time an account address is reported we will expect it to consist
of 4 fields of 30 characters – total 120 characters (30 X 4).
C) If you manually insert or delete information be careful not to inadvertently
change the length of the field as this may cause other fields to misalign and the
return may be rejected as a result.
2
Spreadsheets
It was envisaged that the new spreadsheets introduced for the 2012/13 reporting year
would make submissions of returns easier as well as providing a suitable alternative for
institutions who had previously reported on OCR forms. We have experienced some
errors where it seems the guidance detailed on the spreadsheets has not been followed
and this has resulted in returns being failed.
Typical spreadsheet failures are:
A
Inappropriate spreadsheet used
Only the latest version of the spreadsheet downloaded from our
website will be accepted
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B
C
D
E
Altered spreadsheets
Spreadsheets should not be altered e.g. 
adding or removing columns

adding or deleting sheets from the workbook

changing the order of the columns
Failure to follow guidance
For example:
 not completing mandatory columns,
 using more characters than detailed (N.B. Excessive characters including
spaces will cause the return to misalign leading to failure)
 the inclusion of unwanted characters such as separators in dates and
NINO’s (N.B. Hidden separators such as spaces count as characters)
Address problems
 addresses should be ‘left justified’ in the relevant fields
 the first two address columns are detailed as mandatory. At least two
lines are required to report an address, with the exception of BFPO
addresses
N.B. Any returns that contain missing addresses for one or more records
will be failed
Inappropriate characters
Some institutions have pasted characters such as ‘tabs’ into the
spreadsheets. The use of these types of characters will cause the data
to misalign and the return will be failed
B Tabs
You must not use tabs. Using tabs will cause your return to fail. Always use the space
character or fill with zeroes in accordance with the instructions for that field. Make sure
you have correctly justified the data.
We identified in October 2012 that a number of returns that had failed for containing
tabs had been checked prior to submission by importing the data into excel before being
converted back to a text file. We have established that converting the excel file back
into text inserts tabs into the file.
Whilst we encourage the checking of data prior to submission the presence of tabs in
the text file will cause the return to fail. One possible solution is to keep a copy of the
original text file and if the checks in excel are satisfactory submit a copy of the original
file or make any required corrections to a copy of the original file.
You are permitted to use carriage return but only at the end of each record.
For example, at the end of the Type 1, every Type 2, every Type 3 and the Type 4. In this
way each record will begin on a new line and you can usually tell if any fields have gone
out of line as they should appear as straight lines down the page. Our systems will process
your return irrespective of whether you use carriage return or not.
C Incorrect encryption/password problems
If we cannot access the return or the data you send us we must reject it. We will
require you to resubmit the return having made alterations to enable us to
access the data. In some cases we may be able to fix or repair small problems
but you should not assume this will be the case. One of the most common
reasons is that the password supplied doesn’t work. This may be because the
password notified to us
 doesn’t agree with the password used to protect the file
 because of a transcription error or
 an old password was used.
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Incorrect use of PGP encryption.
HMRC DCDM PGP public key
Due to low usage and problems encountered with the use of the HMRC DCDM PGP
public key we have withdrawn it from use. This does not affect paying agents who
submit using our SET service who should continue to use the PGP key supplied by the
SET team
Note returns submitted on physical media should not be encrypted using the SET PGP
key
We have received some returns encrypted with PGP which we have been unable to
open.
We believe that this is due to the user selecting the wrong encryption option.
If you are password protecting your return using PGP select the THIRD option “PGP
Self-Decrypting Archive
DO NOT USE the following options
OPTION 1 “RECIPIENT KEYS”
OPTION 2 “PASSPHRASE”
OPTION 4 “SIGN ONLY”
Passwords
Please send your password to the email address detailed in the notice
Please title your email with your return type and your return reference number. For
example, an email containing a password for a BBSI return for A9999 sub return 01 for
2013 should be titled:BBSI A9999/01 2013
Note we will interpret S17, T17, S18 and T18 returns as being BBSI or OI returns.
Password Dos and Don’ts
To help avoid problems please do not use ambiguous characters such a 0 (Zero) and O (as
in Oscar). If your password generation is automatic and generates these types of
characters please make sure that these are clearly identified when the password is sent
using numbers and the phonetic alphabet as above. This will help us speed up the process
and avoid the need to contact you.
Please include the reference number, sub number and year of return in the email subject
bar. We continue to receive a large number of emails that do not contain reference
numbers, sub numbers or year.
Passwords should be e-mailed EACH YEAR to the e-mail address detailed in the notice
The recipients of the e-mails do not have access to the internet or other methods of
decryption than those stated so please do not send links to websites to obtain passwords.
Often when we have problems with passwords we have difficulty in identifying who
submitted and/or encrypted the return. Please ensure that the documentation that
accompanies your submission contains complete up to date contact details.
The system is designed to send single passwords. Multiple passwords can be submitted
on an Excel spreadsheet attached to the e-mail.
Do not submit a password for one return and advise that the password;
will apply to all other returns submitted
is the same as last time
is the same as for last year's return
The processing department cannot link passwords submitted in this way.
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WinZip passwords can be copied and pasted which reduces transcription errors
For security reasons you should use a different password for every file
submitted, and always follow all guidance for submission. Do not send
passwords with the returns, but send them separately. We cannot link
passwords from other returns so if you tell us to use the same password as
another return we will still have to ask you to send us the password. We never
recommend using repeated passwords; you should always use a unique
password on every return.
D Invalid or incompatible characters
If you send returns containing unwanted, invalid or incompatible characters or
other information that may affect the processing of the return we may reject
them. To reduce the risk of the return being rejected or further enquiries being
made please make sure you follow the specifications and avoid using any
characters that may cause problems.
 We can accept electronic returns using upper and lower case characters or
any mixture of the two.
 All Headers and data must be encoded in ISO Latin 1 or EBCDIC character
sets.
 Headers and Data must use the same character set.
Only the following characters are allowable:
Upper Case Alphabet A to Z
Left Hand Parenthesis (
Ampersand &
Space
Lower Case Alphabet a to z
Right Hand Parenthesis)
Apostrophe ‘
Full Stop.
Hyphen –
Oblique or “slash” /
Comma,
Numbers 0 to 9
Numeric data must be expressed as digits and as printable characters. For example,
number 12 should be expressed as character 1 and character 2. Where fractions of
numbers are being reported, these should be expressed in decimal and as printable
characters, for example 1.25 should be expressed as character 1, character ., character 2
and character 5.
It is VITAL that the following characters ARE NOT used in data:
Asterisk *
Semi-colon;
Vertical bar |
E Incomplete returns
If you identify that you have not included all relevant data in your return please submit a
supplementary or additional return containing only the missing data. If you re-submit the
full return we could capture the same information twice resulting in unnecessary contact
with your customer. If you are not able to submit a supplementary return please contact
us to discuss the options available.
F Packaging problems
HMRC strongly recommends the use of secure, tamper-proof packaging for transporting
media.
Several problems have been identified with returns received.
Returns where the packaging was felt to be insufficient
CDs received without cases or in unpadded envelopes.
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Using ordinary envelopes that were not big or strong enough for the amount of
media enclosed, frequently resulting in envelopes being torn or bursting open in transit.
Using recycled packaging that had been resealed using sticky tape or staples and
giving the impression the package had been tampered with in transit.
Returns with insufficient information in the package
Cases where no paperwork or contact details were provided.
Paperwork and/or media that did not include a reference number.
Year of return not quoted.
Details on the paperwork that did not match the contents.
OCR (paper) returns were received on incorrect/inappropriate forms and had to be
resubmitted
Changes to reporting
a.
EUSD reporting
A
Croatia
Croatia joined the EU on 1/7/2013 and savings income paid to Croatian
residents from this date should be included on an EUSD return. HMRC has published a
Revenue and Customs brief (12/13) which gives full details of the accession of Croatia
and actions which will be required by UK Financial Institutions. The brief can be found
on Gov.uk using the link above
B
EUSD reportable addresses
We have identified that a number of reports denoted as EUSD
information appear to relate to individuals with a UK address.
In general, individuals with a current UK residential address should be reported
under Sch 23 of FA2011 (previously S17/S18 of TMA 1970). The only exception to this
would be a small number of individuals considered to still be resident in another
member state although based in the UK such as certain embassy staff.
N.B. EU NATIONALS CURRENTLY RESIDENT AND WORKING IN THE UK SHOULD BE
REPORTED UNDER SCH 23 OF FA2011
More details can be found in the Revenue and Customs Brief 34/13, which gives
full details of our findings and what action we plan to take. The brief can be found on
our website using the link above
b.
Changes to Scheme names
The legislation covering the returns previously submitted as section 17 and section 18 of
TMA 1970 was updated in April 2011 and these returns are now required under
PARAGRAPHS 1 and 12 OF SCHEDULE 23 Finance Act 2011 (FA2011). Because the
information to be reported and the acceptable formats were not changed in the interim,
these were renamed Type 17 and Type 18. These returns are now to be renamed in line
with the type of data they contain.
Information previously reported as S17/T17 will now be known as BBSI which represents
‘Bank and Building Society Interest’.
Information previously reported as S18/T18 will be known as OI Other Interest
We updated the name for personal pension (PP) returns a few years ago and they are
now known as RPS RAS (Registered Pension Schemes Relief At Source) returns
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Although most published documentation will be updated in line with the above, the
information type to be detailed in the type 1 record of an OI return will still continue to
be S18 (followed by a space to ‘pad’ the field to 4 characters)
c.
Magnetic Media Specifications – change of name
These specifications were originally written when the only method of submitting this
type of file was on magnetic media. Following the introduction of optical and electronic
media and the availability of our online reporting system SET, the name ‘Magnetic
Media Specifications’ is out dated. Going forward these specifications will be renamed
‘Electronic Flat Text File Specifications’. Although the name is changing the formats of
the files are not.
Where to send your return
Unless you are using SET (Secure Electronic Transfer) send your return to the Centre for
National Information.
Do not send your return to anywhere else in HMRC.
HM Revenue & Customs
Centre for National Information
Ty Glas
CARDIFF
CF14 5ZG
Llanishen
Telephone: 03000 582 413
There is more about SET and how it works on Gov.uk
E-mail addresses
For enquiries and passwords
For sending returns
To request OCR forms please telephone HMRC orderline on Tel 0300 200 3610 between 8am and 10pm Monday
to Friday
What is reportable
For advice on what is reportable or to download the electronic flat text file
specifications or spreadsheet please use the appropriate link below
BBSI, OI and European savings directive
Schedule 23 to FA2011 and the Reporting of Savings Income Regulations 2003
(SI03/3297)
ISA and Junior ISA
Guidance Notes
Annual Information Returns
Registered Pension Schemes (RPS RAS)
Guidance
Annual Information returns
VCT
Guidance
Annual Information returns
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Chargeable events
Guidance
Reporting of chargeable event gains
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