Ode to the small city centre business

First, they wanted to ‘save our NHS’ and demanded that we all stay at home, I did not speak out—because I believed the science led, government advice

Then they came for the big businesses to furlough staff as well as getting those not on furlough working from home. I did not speak out— because my business was only a small one and I believed the science led, government advice and wanted to keep the NHS safe.

Then they came for the travel industry, and I did not speak out—because I was not about to go on holiday as mine was cancelled weeks ago and I still believed the science led government advice and wanted to keep the NHS safe.

Then they came for my business. I no longer believed the science led, government advice or that the NHS needs keeping safe any longer as it is running at only 50% capacity and coping very well indeed. By not making those ‘big businesses’ and civil servants get back to their offices, there was no one left to speak for me as all my customers who worked in those offices will never come back.* 

By the time the country awakens from the post Covid19 stupor, the big city centres as we know them, will not ever be the same.

Let’s spin some thoughts and consequences out here with this scenario. 

Big firms and the civil service keep staff from a wholesale return to those huge offices, even today only 10% have returned to London

Employers will now want to reclaim London weighting paid while home working yet no longer relevent, company cars to be returned as they no longer are needed- nobody goes to meetings any more, expense accounts removed etc

No commuting means that you can live anywhere while working from home, just as long as you have an internet connection that is reliable

As you can now live anywhere, your very expensive ‘commuter belt’ home will collapse in value as the commuter belt could now extend to Sydney, NSW. 

If that thinking is taken to its extreme, why employ staff living in a commuter belt at all when the staffing costs could be much less using home workers? And of course, we all know where that ends up if you look at the growth of the call centre!

No commuting or business travel means no aircraft, airports or trains are needed as they were, no Crossrail, no tube, no remora support businesses are needed in cities like, for example, London, Manchester, Leeds, Edinburgh. That means service sector job losses- no customers for airlines, hotels, restaurants, theatres, coffee shops, sandwiches, shoe repairs, tailors, chemists, doctors, dentists, even Deliveroo…..the support list is endless. Not one will be left because big business is in no hurry to get staff back! 

Sometimes, by believing they are keeping their staff safe working from home when the chances of most of the population getting Covid19 are less than being hit by a bus, employers have lost sight of the social responsibility they owe to the areas they have chosen to invest and locate their office workplace.

Please big brands, and of course ALL government departments, get your staff back in the office now before it is just too late!

And for those big distribution firms in the financal services world, your customers pretty much all come from financial advisers large and small, they are their clients. So many of these businesses that will die if workers do not return to their desks now are IFA clients. They were the source of your inflows- investment, pension funds, life assurance, mortgages.

No SMEs equals a big reduction in new business opportunity and a major threat to fund outflows in hard times for the unemployed who will be unable to afford investments, pensions, life assurances, their mortgages or when most needed, financial advice.

All because of the failure to see a call from Government and the business world to the many thousands of their staff to return to their offices.

Only today I understand that the UK working population that is back at work is some 34%. France it is 83%. As of August 2, 2020, approximately 9.6 million jobs, from 1.2 million different employers were furloughed in the United Kingdom

Let’s just get back to work!

An adaptation of  the famous verse by Martin Niemoller

Oh Beirut, what has been done to you now?

Forgive me for going a bit off piste with this?

Back in the early seventies, the world was a different time and place, and in my travels, Beirut was often a much-treasured stop over. 

It was, at the time, THE most sophisticated, truly cosmopolitan city in the middle east. Forget the Emirates, at that time places like Dubai, Abu Dhabi, Qatar, Oman were simply cockroach riden dust bowls with frankly no redeeming features other than an airport to get out.

When I first heard about the explosion, I noticed that the blast maps seem to take in an area around what was then known as St George’s Bay. And at St George’s Bay the place to go and be seen in the 70’s was the St George Club.

I am not sure how badly it may have been damaged in the blast, but when I checked their website this very ominous entry was to be found.

“The Saint-George Hotel is located on Saint George’s Bay, named after the legendary hero who slew the dragon terrorizing its shores.

Today the bay and its inhabitants are under renewed attack from a hybrid corporate monster: Solidere; which – neither private nor public – is devouring public and people’s property to line the pockets of its backers.

The giant development firm has driven all legal owners and leaseholders of property from the shores of Saint George’s Bay, leaving only the Saint-George Hotel fighting a ‘David and Goliath’ battle to stop Solidere’s long term plans to land fill the bay and build more high-rises”.

Corruption was, is and will for some time be a problem for the Lebanon and it’s stability is made more uncertain with the political issues that prevail.

But, the entry on the website made me think, was this explosion due to the seemingly unknown contents of the storage facility?

Or was it the desperate final act of a development firm to clear a site once and for all that went just a bit too far? 

Conspiracy theory?

Questions should be asked, answers may be an expectation too far?

That ain’t workin’, that’s the way you do it

How does that song go, ‘Money for nothing and your cheques for free?

Is this why so many may not be happy to return to work? 

What is going on, mortgage holiday for 6 months (now as recommended by the FCA) credit card payment holidays, car finance payment holiday, state sponsored paid furlough, self -employed income support, business grants and more (I am sure I must have forgotten something here).

With all this is on offer, why even bother thinking about a return to work? 

When the time for ‘learnings’ arrives, I am sure that blame will be laid at the wrong targets for reputational preservation and no lessons learned at all. In fact, right now there will be various civil servants and ministers doing their very best to make sure career saving blame is laid at someone else’s door. In fact, listening to the weeks news I think it is already happening.

BTW, ‘learnings’ in today’s Covid19 world is a word that you and I might have lengthened to a phrase such as ‘WTF happened’!

We do not need any more ‘free money’ holidays. Let’s get back to work now UKplc and earn the money.

Large, City based institutions in particular, need to get back!

If thought has not been given, do think of all of those ‘Remora’ businesses, especially the SME’s that depend on these big firms being back at their desks. Think of shops, restaurant’s, health clubs, bars, support services like drivers, couriers. The list is endless and not all may get the government bailouts. 

In keeping bigger businesses ‘working from home safe’ the result is the destruction of thousands of smaller business who rely on the support of those bigger firms in normal times for their income in return for services. 

In late summer or early Autumn reality will hit for millions with social distancing and catching a virus will be the least of their worries. 

No free money by way of mortgage payment holiday, no car loan, rent and credit card payment holidays any more will see a stampede to get back to work only to find that the job they have been collecting money from the state for passing a monthly salary ‘go’ is no longer there. 

It has entered the world of Monty Python’s Dead Parrot.

No,no, he’s not lost his job, he’s on furlough’!  

I recall that after a long exchange the sketch morphed into ‘Well! I never wanted to do this job in the first place. I wanted to be… a lumberjack!

And we all know how that ended up.

How did that phrase go from another great former Prime Minister…? Never in the field of human conflict was so much owed by so many to so few?

I think in today’s lockdown world this should read “Never in the field of infection prevention will so much be owed by so many to protect so few”?

That debt could be as much as £298bn* just for this financial year (April 2020 to April 2021), according to the Office for Budget Responsibility (OBR), which keeps tabs on government spending. This harsh reality puts this debt as some £8.67m per life lost or £4,447 per head of population?

And that really is Dire Straights.


Ordinary, said Aunt Lydia, is what you are used to. A Covid19 update


I feel we are about to enter the dystopian world of Handmaids Tale. Aunt Lydia went on to say “This may not seem ordinary to you now, but after a time it will.

I have been quite sceptical, some may say quite wrongly, about this virus and the impact it’s having and the regrettable deaths that have come about. I should declare an age group interest. I fall into the age range of ‘at risk’ so in many respects I should, as Sir Hector Sants once said, ‘be very afraid’.

However, these stats from the Sunday Times, 29th March, have not done much to dampen this scepticism.

·      There are now 2.6 billion living in Covid19 lockdown, globally.

·      About 630,000 have been infected, they report, globally.

·      Some 28,000 have died globally and no doubt many more will do so. A 4.4% rate against infections.

I was further alarmed by some stats on Friday 27th March’s Downing Street briefing. I was not aware that some 33,000 NHS beds are/ have been/ are being made available for Covid19 patients, the equivalent the spokesman said, of around 50 UK hospitals. On top of this we have the Excel centre in London being converted to one of a number of   ‘Nightingale Hospitals’ with up to 4,000 beds being made available. Birmingham is about to follow suite along with Glasgow in their exhibition centres. On top of that David Lloyd Clubs have offered their closed centres as temporary hospitals.

So, while Covid19 seems to have a massive resource to assist when the call comes, hopefully it will not in such numbers, but what about the patients who should have been in those 33,000 beds in 50 hospitals right now.

Any death is regrettable and creates huge outpourings of grief for those directly involved. But in the general scheme of things, the Covd19 numbers are quite low. For example, road deaths in the UK in 2019 were reported to be 1,870. *Dept. Transport

Cancer deaths in 2019 were estimated to be 606,880, of these 142,670 were lung and bronchus related. In 2019 there were 228,150 new cases of cancer that were lung and bronchus related. *seer.cancer.gov

In the UK those who have died now total some 1,408 (at 30th March) with 22,141 being tested as positive out of 120,776 tests so far carried out. What we do not know, and may never know is given that in 2019 new lung and bronchus related cases stood at  228,150, how many of these have sadly died with the cause of death being recorded as solely Corvid19 when in fact it was a complication of those underlying conditions further complicated by Covid19?

While we remain locked down, medically, great effort is being made to ensure the NHS is given the recourses it is asking for, yet we are still seeing flights coming into the UK, today from amongst other Covid19 infected hotspots places in Iran, USA (New York in particular) and China. BTW, the USA and China will not allow us to travel to their countries at the moment.

Passengers and crews are not keeping safe distances apart on the flights, those deplaning are not being checked and, in many cases, just getting on public transport, shoulder to shoulder, straight into London without any audit trail of movement or destination.

On a brighter note, after all those reported deaths and the heroic efforts of the NHS, the Beckhams have reportedly purchased a $24million apartment in Miami’s One Thousand Museum building. I am sure that all those who have lost their businesses, now out of work, struggling to make ends meet, registering for the various almost impossible to qualify for benefits the government has made available to the self employed and small limited company directors, will be much cheered by what is increasingly been seen as a vacuous waste of space in a social media, privilege driven society world that needs a massive reset. (got that off my chest)

Something is very wrong with this whole thing.  As the saying goes “Nolite te bastardes carborundorum.

Diversity, political correctness and the FCA


Back in January, I came across an article suggesting that Governments have always been vulnerable to forms of themed political craziness. It is an interesting read.

Civil Service applicants are being advised that during their interview process they should ‘demonstrate insight into the link between the moral and business case for equality and diversity and achieving organisational priorities’ and explain how they ‘actively promote diversity and equality… inside and outside the Civil Service’.

The BAFTAs have adopted the same theme and the Oscar’s had a go. Diversity is what it is all about now.

My sister is a ‘CoE’ vicar, I remember her telling me a while back that Sunday sermons have a weekly theme dictated by ‘Head Office’ that is expected to be adhered to across the land.

With this ‘top down’ theme, in 2020, it’s now the regulators turn.

Should we be worried in the world of financial services that this quasi state inspired thought creep should be leeching its way into regulation?

A couple of weeks away from his move to the Bank of England, the FCA’s CEO, Andrew Bailey used a PIMFA conference to bang the drum for diversity.

He used the speech as a platform to highlight that:

  • Diversity and inclusion are central to how we act as a regulator and as an employer.
  • Fostering a culture of diversity and inclusiveness can contribute to changing the behaviour of firms for the better.
  • The culture and governance of firms is a priority for us, but we do not prescribe what this should be.

It is quite a speech.

  • Bailey lists many things that the FCA believe to be relevant to the industry, in particular noting that, “We don’t respect institutions – private or public – because they have been around for a long time, or because they are populated by a certain sort of person. We suspect that leads to narrow thinking and is not representative. In other words, we put a much more tangible value on the practice of diversity – of people, backgrounds and experience, opinions and thinking, and rightly so”.

In my experience of nearly 40 years in the financial services world this is simply an example of a mind bending failure to understand those it regulates and those that it regulates for.

Regulators in general are not overly respected by those it regulates or those it is there to protect. Funnily enough for the same reasons- they do not listen, do not operate with a common sense mindset, do not learn from ‘learnings’ and are never terribly approachable or accountable.

In the financial services industry regulators do not have any longevity at all and so by default cannot assume respect is earned by time served, something he has overlooked. In my time we have gone through amongst others IMRO, LAUTRO, NASDIM, FIMBRA, PIA, FCA, FSA, over the last 30 years that averages one regulator every four years or so

Bailey goes on to say that the FCA has 3 operational objectives given by Parliament: “the protection of consumers; the integrity of markets; and ensuring competition exists in the interests of consumers”.

So, I am not sure how we have arrived with a fourth- diversity. Is there an audit trail for this objective announcment?

This seems to be an independent mandate by the Olympic Park ‘Wokes’. The FCA sets targets for both gender and Black, Asian and Minority Ethnic (BAME) diversity at senior levels in the FCA. It supports organisations such as Stonewall who in turn rank the FCA as part of Stonewalls top 100 LGBT friendly employers.

This recognition, the FCA says, sends a strong signal to industry, consumers and other external stakeholders about our commitment to diversity and inclusion.’

But it does not endorse the effectiveness or efficiency the FCA. Is diversity within the financial services industry now more important than treating customers fairly, the protection of consumers; the integrity of markets and ensuring competition exists in the interests of consumers”.

Are consumers actually interested, are regulated firms actually interested how ‘well diverse’ firms are? Britain seems to be following America down a potentially rocky road.

Many lessons have emerged from America’s adventures in diversity and inclusion, lessons the UK ought to learn sooner rather than later. To draw on some research, appeasing diversity advocates is a poor strategy.

As observed, “if you begrudgingly submit to some preferential policy, reasoning that diversity advocates will be satisfied once it is implemented, then you have the logic of progressive activism backwards”. As a space gets more diverse, diversity advocacy does not decrease; it increases. Think LGB to LGBT to LGBTQ to LGBTQ+!

As a footnote, in December 2019 we learned that an FCA senior had a post removed from the FCA staff blog Pulse. It was commenting on diversity promotion at the FCA and was not seen to be on message, diversity now outranks free speech at the regulator!

So FCA, can I suggest that you stick to those three operational objectives and especially get them right before you embark on any other unwanted, un-needed deviation from that path that involves industry fees being spent where they really should not be simply to get ‘rainbow rankings’.

As a footnote, as Andrew Bailey assumes the BoE hotseat, he may wish to reflect upon diversity issues at the top there.

The Bank of England has never had a female governor. The FCA and all those it follows has never had a female in the top role

Last year, Phillip Hammond faced criticism when the only man from a shortlist of five candidates was appointed by the Treasury as the latest member of the Bank’s Monetary Policy Committee, Jonathan Haskel, joined the nine-strong MPC, which includes only one woman – Silvana Tenreyro.

Shriti Vadera, the chair of Santander UK; Janet Yellen, the former head of the US Federal Reserve; Sharon White, the chief executive of Ofcom; and Dame Minouche Shafik, director of the London School of Economics, were all potential contenders for the governor role but only two applied.

It’s a funny old game is diversity.

Coronovirus, is it all just fake news?


As UK and global hysteria increases, stock markets crashing, holidays ruined, flights to the far east cut, schools closing, self-isolation increasing, even C4’s Jon Snow, 6 nations rugby put on hold and globally goodness knows what else to try and contain the march of the Covid19 virus.

But is this really all a bit of an overreaction in the world of ‘wokeness’.

Flu epidemics happen every year, some worse than others, some years seeing more deaths than others, but I have never seen reactions such as the world is seeing now.

Although not the flu as we have come to know it and inoculate against, it is nevertheless still flu.

A reflection that may assist in some hysteria balance.

I recall in the 70’s seeing US news reports of the bodies of ‘Aids’ victims, in sealed bags, being removed from homes by people in Hazard suits as it was thought that this killer disease was caught by touch. Even autopsies were not carried out initially for fear of the person carrying it out catching it too.

A few decades on we can see that was clearly not the case at all.

But back to Covid19.

Some stats to digest. We all love stats.

The US Centres of Disease and Control and Prevention (CDC) estimated that since 2010 influenza has resulted in between 9 million – 45 million illnesses, between 140,000 – 810,000 hospitalizations and between 12,000 – 61,000 deaths annually since 2010.

So far this flu season in the USA, there have been about 175,000 positive flu tests reported and around 3,000 deaths. The 2018/19 flu season saw some 36m symptomatic illnesses reported yet only some 34,000 deaths.

A rise in flu cases across England triggered an alert from the chief medical officer in early December (pre Covid19 hysteria going live) with increasing numbers of patients admitted to hospital and intensive care.

Public Health England said the number of flu cases confirmed in hospitals in the week to 8 December was 472, up from 330 the week before. There were 124 new admissions to intensive care or high-dependency units for flu, up from 80 the week before.

Covid19, which is rapidly spreading across the globe should be the least of our concerns when compared to regular, run of the mill, seasonal UK flu scientists have warned.

The Covid19 virus is not nearly as deadly as the common flu, which experts have warned should still take priority in the medical battle.

Influenza can lead to thousands of deaths a year, with the University of Oxford stating that in 2008-2009, there were 13,000 deaths in the UK alone related to the flu.

The World Health Organisation (WHO) estimates that an average of up to 500,000 people die annually across the globe due to the flu.

Then along came Covid19. At the time of writing, the UK has some 36 infected with the virus with zero UK deaths

Brexit is over, we have a stable government, is this all a hype over flu, created by a media induced frenzy, an overreaction to what is a new strain of ‘flu’ that no doubt will soon see a jab available to prevent it, but only until the next one comes along.

The UK should ‘man up’ a bit. There will be more road accident deaths in the UK in February than from Covid19, more deaths from prostate cancer.

What we should be told is how many more have died, NOT from the Covid19 flu variant, so far in the UK this year?

If we can know those numbers, some perspective could be drawn.

FSCS nil, nicht, nada, rien. HM Treasury £45.5M

A few weeks back I saw that Bank of Scotland were subjected to a fairly whopping fine for ‘Fraud Failures’.

IFAs may recall that in 2012 George Osborne was responsible for the diversion of financial services fines, (originally intended to be offset against the general costs of regulationto reduce the regulatory financial burden on firms that did do the right thing) to the Treasury.

Fines were and still are treated as a windfall revenue source to distribute on a political whim for whatever cause is assumed to be popular with the voting masses.

Osborne said, “It’s only right that fines from those who have demonstrated the very worse of values should go to support those who have shown the best of British values.”  

During 2014 Banking fines were £1,462bn. To put some contextual scale to this massive amount, the total revenues raised for alcohol and tobacco in 2014 was £1,970bn – that equates to 4% of total UK taxation revenues according to HMRC figures.

The FCA was obliged by statute to pay away £1.370bn of the fines the Treasury, the equivalent of 70% of alcohol and tobacco levies for 2014.

Fines are still not being used to reduce costs in a way that may, indeed should be expected.

In my view he is wrong, fines should not be used as a political slush fund to ‘big up’ a government, any government especially in a lead in to an election.

Fines are the purest method of demonstrating that the polluter pays. The FSCS should get this and any surplus after that goes to HM Treasury if they must have it!

Instead, HM Treasury used the fines covering up the military loss of life and limb with a blanket of banking ‘misdemeanours’demonstrates the very worst of politicians behavioural values, especially from differing  administrations of varying political hues (who had placed UK troops in harm’s way with little or no thought for their safety, wellbeing or exit strategy) and is just not on.

With this latest fine, I got this response in regard to an FOI request

“Under the Freedom of Information Act, I would like to know:

Bank of Scotland fined £45.5m for BoS fraud failures

I would be grateful if you would confirm how much of the £45.5m fine was retained by the FCA and how much was paid away to the HM Treasury?”

Your request has been considered, and our response is as follows:

The FCA pays to HM Treasury its penalty receipts after deducting its enforcement costs every year.  The FCA has already retained sufficient penalties to cover its 2019/20 budgeted enforcement costs in the current year and will therefore pay the £45.5m in full to HM Treasury in July 2019.

The entire fine paid to HM Treasury!!!!!!

Is this the right thing to do?

What about any surplus going to the FSCS?

Just a thought.

A nice little earner……..no more

“You make contact with your customer. Understand their needs. And then flog them something they could well do without.”

This appears to be the ‘outcomes view’ of the FCA on car sales and finance and as a result new and used car dealers commission is about to come under the FCA spotlight.

Has the FCA watched too many Minder episodes? Car finance is set to undergo a regulatory kicking of the tyres, a look under the bonnet because, would you believe it, the FCA revealed that it had uncovered unfair practices among some retailers and brokers in the way they make “commission” on sales.

It’s that dirty word again, commissions. The FCA is about to embark on a consultation to justify their unintended, but oh so foreseen by others, outcome and is set to kill off car buying for the ‘ordinary guy in the street by protecting buyers from themselves.

There may be a lot to criticise those ‘Daley- esc’ car dealers, especially those old school ‘bombsite’ traders offering ‘a nice little smoker,’ you know, the one careful lady owner, never crashed, written off, raced or rallied, full manufacturer service history deals and a year’s MOT.

But to just pick out commission in what is a very complicated, sometimes risky to the trade and buyer alike, process of car sales as being the root of consumer detriment shows a staggering disregard for consumer benefit being traded against consumer detriment.

People buy cars, not finance, it is not an advised purchase or sale, or was not until the FCA decided to open-up another regulatory opportunity. Everything to do with car purchase prices, finance or sale values whether new or ‘pre-owned is almost impossible to understand yet car finance forms a very important part of the pricing structure allowing dealers to make a margin whether they are manufacturer main dealers or not. Car finance and buying is the sum of a great number of parts.

The finance is secured, most times, on the vehicle, a highly moveable security. The buyer may not have a good credit history and loans can and indeed are priced according to risk.

That vehicle should be insured (another regulated sidebar and taxed) it should be MOT’d if over 3 years old. To drive it you need fuel (taxed) a licence, drive it badly and you could lose that licence.

Once you have the car, if it is a lemon your stuck with it. If finance is part of the deal, you have a cooling off period with a lot of small print that may prove hard to unravel.

Any car you buy instantly depreciates, a new one by the VAT element alone the minute you drive out of the showroom.

With all this legal and regulatory stuff already going on, to apply FCA regulation to just one part of the process will create a waterbed effect that will just result in consumer detriment.

The FCA reckon that “By banning this type of commission, we believe we will see increased competition in the market which will ultimately save customers money.”

Like everything else regulated, consumers are not always better off, they become part of that waterbed effect.

For those unfamiliar with the Waterbed effect, it is the natural but not necessarily intended potential to squeeze one part of a complicated and complex regulated business model (and the attendant regulatory processes) to cause a serious bulge elsewhere in the process.

That bulge is normally only uncomfortable for the consumer it was designed to protect.

It is also another chance to throw some golden opportunities to CMC’c now that the PPI door has slammed shut.

The FCA say they will consult on the proposed new rules until 15 January 2020 before implementing them at some point during the year.

What this means, for those in the car industry unfamiliar with the workings of the FCA, is that these rules are already drafted and in place to go after very few respondents will have shown interest in responding because, rather like those in the advisory sector, they see little point.

The outcome will be fewer car sales, higher new car prices, depressed used values, more expensive finance, less access to finance for some buyers.

Why, because car sales are linked to finance. Rather like house buying. Gone are the days you ‘paid cash’, perhaps money laundering put an end to that, it is all about debt, depreciation, balloon payments and tax all contributing to the sales process

And like any business that relies on finance options the deal is the sum of the parts and having an a la cart ‘pop’ at one element……commission, is simply madness.

Here are various examples of car finance and incentives

Manufacturer new car finance either by hire purchase or PCP- personal contract purchase (where you buy the car with a small deposit and after say 3 years you can hand the car back or buy it outright or part exchange in return for another purchase.

A typical rate for a new Mercedes, with finance supported by the manufacture, could be 4.9% but the rate is conditional on taking that finance. Other incentives could be dealer contributions toward a deposit

PCH is personal contract hire, you pay a very low, often manufacturer supported monthly amount, for the use of a new car. You in effect hire it and at the end of the agreement you hand it back. Commissions are much easier to identify and could be up to £1000 plus any make on the car margin. The actual price of the car is another thing entirely, affected by other factors as depreciation up front and VAT reclaims.

Alongside these deals a buyer may be tempted with tactical campaigns where there is manufacturer support to switch brands, so say BMW to Mercedes, that is called conquest money.

Pre-registration is another method of getting car sales complete. Good deals for the manufacturer but not the dealership as these do not count against quarterly targets

Offers are also available for loyalty but not so common.

“Preventing the use of this type of commission would remove the financial incentive for brokers to increase the interest rate that a customer pays and give lenders more control over the prices customers pay for their motor finance, Christopher Woolard, Executive Director of Strategy and Competition at the FCA, said.

There are many things that could be done to protect the vulnerable car buyer, regulating commission is not one of them.

Prices will go up, finance cost will increase, used values drop, that waterbed effect again.


FCA consultations, are they worth the effort? survey

The FCA carry out many consultations, all for very good reasons, at least we hope that is the case. But there is a suspicion in the intermediated distribution world that the reality is that the decision has already been made and that the consultation is there to demonstrate the inclusiveness of the regulator and nothing more.

I may be accused of being a bit cynical, perhaps over 45 years in the industry has caused some battle hardening, but just think about this a bit.

There are some 93,000 active, registered firms on the FCA 2018 register. There are 35,000 organisations with a single registered individual and 57,000 directly authorised firms who have some 120,000 individuals.

So, time to make an FOI (Freedom of Information request) asking; “I would be grateful if you would confirm the number of consultations carried out from 31 August 2018 to the 1st Sept 2019.  The size of the audience involved and in addition I would like to know the total number of respondents in that year and the average number per consultation?”

The reply I got started to ring the alarm bells.

“Your request has now been considered.  The FCA has carried out 39 consultations during the period in question.  However, we estimate that to comply with the rest of your enquiry would exceed the appropriate limit for complying with a request made under the Act, as set out in the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004.  Therefore, for the reasons outlined in Annex A below, section 12 (cost of compliance exceeds appropriate limit) of the Act applies.

When we refuse a request because the appropriate limit has been exceeded, it is our general policy to provide advice and assistance to the applicant to indicate how the request could be refined or limited to stand a greater chance of falling within the cost limit.  However, in this instance, we are unable to suggest a way in which your request can be refined to come within the cost limit”.

I have been concerned for a very long while that consultations are very poorly engaged with.

I asked Rory Percival for a steer.

He said “I imagine 100 or so for significant CPs but I imagine the figure is much lower for many so maybe a lower overall average. You should get a bit of a flavour by looking at some of the PSs where they list respondents”.

I asked him why it was so low?

He reckoned that “many think it won’t make a difference”.” I suspect the main reason as far as a firm is concerned is that there isn’t a culture of responding.

So, not to be deterred, I went back and asked if they could look at the numbers for the last 5 consultations. And got this reply that should make us all very afraid.

“Your request has now been considered, and I can confirm that the information you are seeking is available from our website. 

For ease of reference, the details of each of the five consultations falling within the scope of your request, the figures you have requested, and the page where the relevant details can be found are provided in the table below”.


Consultation details Number of respondents to the Consultation Paper
PS19/25: Overdraft Pricing and Competition Remedies: Policy Statement 12 respondents to our CP
(Page 6)
PS19/24: Illiquid assets and open-ended funds and feedback to Consultation paper 43 respondents to our CP
(Page 8)
PS19/23: FCA and PRA changes to mortgage reporting requirements 19 respondents
(Page 5)
PS19/22: Guidance on cryptoassets 92 respondents to CP 19/3
(Page 6)
PS19/21: Retirement Outcomes Review: feedback on CP19/5 and our final rules and guidance 62 respondents
(Page 5)


There were 228 in total, an average of 45.6 per consultation.

If firms think it makes no difference to the consultation outcomes, this data could support that idea pretty well indeed as to why firms do not engage.

In democracy, it is reckoned that the electorate deserves the government it elects, the theory based on the assumption that this is the outcome for low turnouts.

In this case regulated firms get the regulator they deserve, if some 93,000 regulated firms can manage to muster an average some 45.6 respondents per consultation. What hope is there for firms to engage with any FCA consultation if those responding feel there is not some very real input to shape positive outcomes that is listened to.

What is the point and why should they bother?



Brexit fallout, would you employ Olly Robbins?


I do not know him, have never met him or have any personal axe to grind but last week’s announcement that the ‘Rasputin’ of Brexit is to leave (when Theresa May leaves office) his  role as head of the European and Global Issues Secretariat, advising the Prime Minister on the EU and to oversee Brexit came as not a big surprise

Brexit has been a very toxic affair causing divisions of an unimaginable scale nationwide.

According to his Wikipedia page some interesting intelligence is gleaned, Robbins’s Brexit  role “led to some Conservative MPs blaming him for an anti-Brexit “establishment plot”, criticising him as “secretive” and comparing him to Grigori Rasputin.

A group of former military and intelligence officials associated with pro-Brexit pressure group Veterans for Britain including the former head of the Secret Intelligence Service Richard Dearlove said Robbins had “serious questions of improper conduct to answer” over defence and security co-operation between the UK and the EU after Brexit.

What was a surprise is that he is looking to follow the well-worn cabinet minister path to the City.

When a minister leaves office he or she should be subject to the Ministerial code, it sets out the standards of behaviour expected from all those who serve in Government.

The business appointment rules note that “Ministers will be prohibited from lobbying Government for two years. They must also seek advice from the independent Advisory Committee on Business Appointments (ACoBA) about any appointments or employment they wish to take up within two years of leaving office. Former Ministers must ensure that no new appointments are announced, or taken up, before the Committee has been able to provide its advice”.

The same rules apply to senior civil servants such as Olly Robbins.

But will they?

The business appointment rules for civil servants has key principles to be observed:

Integrity You must not misuse your official position, for example by using information acquired in the course of your official duties, to further your private interests or those of others.

Honesty You must not be influenced by improper pressures from others or the prospect of personal gain. 

Objectivity You must take decisions on the merits of the case. 

Impartiality You must not act in a way that unjustifiably favours or discriminates against particular individuals or interests. 

The rules note that civil servants should be able to move into other sectors, and that such movement should not be “frustrated by unjustified public concern over a particular appointment”.

But it is equally important that when a former civil servant takes up an outside appointment or employment there should be cause for justified public concern, criticism or misinterpretation.

The aim of the Rules is to avoid any reasonable concerns that:

  1. a civil servant might be influenced in carrying out his or her official duties by the hope or expectation of future employment with a particular firm or organisation, or in a specific sector; or
  2. on leaving the Civil Service, a former civil servant might improperly exploit privileged access to contacts in Government or sensitive information; or
  3. a particular firm or organisation might gain an improper advantage by employing someone who, in the course of their official duties, has had access to:
  4. information relating to unannounced or proposed developments in Government policy, knowledge of which may affect the prospective employer or any competitors; or
  1. commercially valuable or sensitive information about any competitors.

Robbins may have some fantastic commercial value but given the code constraints why would a big City firm want to employ this person in particular, given the hugely negative brand damage aura that his name could be associated with. I’m thinking here of the 52% who voted leave for a start.

Would a two year wait to head to the city be a good idea allowing the passage of time to establish what his real value may be to a prospective City employer as well as what his true cost to the nation may have been too?

Just a thought?