Diminishing notional capital and CTR not CTB

DNC applied to my client. PC and HB not received have been taken into account in DNC rules, but seemingly not CTR. SPCRegs 2002 Reg 22 para (3) (c) refers to CTB (not CTR) to be taken into account as a deduction.
The same wording still seems to apply in the IS Regs. There seems to have been no change of definition of CTB to include CTR for DNC.
Has anyone come across this and does PC (or IS) take CTR into account as a relevant deduction in DNC rules treating CTB also to mean CTR?

In my opinion, they are two distinct benefits with different primary and secondary legislation so I do think you’ve identified a problem due to the lack of amendment of PC regs to incorporate CTR rather than CTB in these situations. I’ll discuss with a colleague here and see whether we can get any clarity from Pension Service.

That would be great. applies to IS Regs Reg 51A, and ESA Regs 116 too.. Must surely be intention of parliament that CTB be read to include CTR. Sticking plaster needed for CTB to include CTR in this context.

Paul, Have you had any response yet I wonder from the pension service re the CTB/CTR anomaly?