Most people forget the third part

Panacea comment for Financial Advisers and Paraplanners

20 Jun 2017

Most people forget the third part

We started the week with this statement from the Lloyds Banking Group on behalf of HBOS:

‘Our customers’ safety is of paramount importance to us’: 

‘We have a clear policy that if a customer says that they are considering taking their own life that we must take the statement seriously and take action to protect them. 

Whatever your view of Noel Edmunds and Mr. Blobby may be, I cannot think of any example in my forty plus years in the financial services industry where any bank has ever made such a statement.

It is made worse in my humble opinion because any organisation that makes such a statement, especially via a spokesman, never actually means it. They are so detached from the pain they have caused and in apologising for that, their words simply make matters worse.

Lloyds is not alone, in fact they are quite low down the scale of stock messages of faux regret and condolence.

This month has seen a positive 12 bore load from politicians in particular and if we look back over the year, they have been supported by fading celebs needing a publicity boost, trade unions, regulators various, civic leaders, minority interest groups, broadcasters (BBC) and others of the so called society ‘elites’.

Top phrases used to sound good but little else at the moment are, in no particular order:

  • “Our hearts/ minds/ sympathies go out those affected by this…(fill in the blank)”.

This is a hijacking of an equally irrelevant use of the words, originally used by the military to describe a counter-insurgency policy of various governments. Essentially focused on “community outreach” in times of good versus evil conflict, it is now used in reference to emotional and intellectual support or commitment by those in authority to assuage them from their own inactions that probably caused the very thing they are ‘reaching out to’ empathise with.

Why bother with this type of statement, after hearing it so many times this month alone, from so many, it is devalued to the point of having no meaning at all other than a useful intro line to demonstrate faux empathy that is just not genuinely there.

  • “Lessons will be learned”:

This is sometimes linked to the word “Learnings”. NATO has a great definition of this. “The purpose of a Lessons Learned procedure is to learn efficiently from experience and to provide validated justifications for amending the existing way of doing things, in order to improve performance, both during the course of an operation and for subsequent operations. This requires lessons to be meaningful and for them to be brought to the attention of the appropriate authority able and responsible for dealing with them. It also requires the chain of command to have a clear understanding of how to prioritise lessons and how to staff them.”

A perfectly clear definition, but the reality in UKplc today is that the statement made and the realities of it are travelling in polar opposite directions.

Lessons are never learned, never implemented and personal responsibility is never fully identified, defined or the guilty made accountable.

“I deeply regret”:

A very popular phrase in touchy, feely UKplc, it is a very useful phrase in the apologising person’s verbal arsenal because it doesn’t require you to admit you did anything wrong, at all, ever. In fact the use of this phrase would simply be another way of saying I really could not give a…SHoneT.

“Mistakes were made”:

For those who feel that “I deeply regret” is admitting just a little bit too much responsibility, they can ‘upgrade’ at no extra reputational cost to “mistakes were made.” This is the zenith level of non-apology, used at the very highest levels of government. Prime Ministers like Tony Blair, David Cameron and now Theresa May have used the words. These are seen as better than “I deeply regret” by not only leaving it open whether they are actually the culprits, but also existentially questioning whether there even is a mistake?

I saw a great definition of ‘sorry’ recently. It said that “Being genuinely sorry is actually remembering what the hell you did and having enough genuine regret to sincerely endeavour not to repeat the very thing you know has caused distress or even great hurt”.

The source went on to note,When someone’s on your back like Zorro to apologise to you, or for you to accept the apology, they don’t actually mean they’re sorry. 

What they really mean is :“Look, can you hurry the ‘f…’ up and accept my apology so I can stop feeling bad about it? You perceiving me as (wronging/hurting/abusing/whatever- insert again where appropriate) is terribly inconvenient and my ego doesn’t like the pinch of reality, so if you don’t mind, get a shuffle on, accept my apology and let’s move on so I can slam my palm down on the Reset Button.

It would be great if those making these vacuous public pronouncements could come up with an original, heartfelt message of their own, one that sums up how they genuinely feel and not statements recycled to simply sound good, boost their own fading profiles or to kill off a reputational firestorm.

Better still, just shut up.

Brexit conspiracy theory, they thought it was all over. It is now.

Panacea comment for advisers and Paraplanners

13 Jun 2017

Brexit conspiracy theory, they thought it was all over. It is now.

Winston Churchill said, “The best argument against democracy is a five-minute conversation with the average voter.”

I have been reading a very interesting book by Sunday Times journalist Michael Hume called ‘Revolting. It is a tome exploring in some detail how the establishment elites are or might be seen to be undermining democracy.

Now I am not a big fan of conspiracy theories but I had a bit of a “Damascene conversion” today and I will share my thoughts with you.

Brexit is the new ‘Gunpowder, Treason and Plot’. It is Cavaliers and Roundheads. It is Braveheart. It has divided the nation and it is about to get worse. In fact so much so that it may end in civil unrest with the electorate ‘revolting’.

Here goes my very simple conspiracy theory.

The referendum produced a result that the establishment neither expected nor wanted. A bit like the Trump Presidency or even the resurgence of the Labour party in the last weeks of the election, depending on your political leanings of course.

When the Brexit result was declared, instead of triggering Brexit the very next day as he said he would, David Cameron resigned, buying the elites some time.

And with that the establishment wheels started to turn to ensure that the right outcome of that referendum would eventually prevail. Behind closed doors those elites that control so called democratic UK set in train a series of actions to ensure that outcome prevailed.

It would take a year or two but….hey ho, wheels with a precise function move slowly.

Establishment wheel 1: The conservative party needed a new leader. Strangely, after some very convoluted, overt Machiavellian machinations, Boris was sidelined (knifed) by Michael Gove, Theresa May won the contest on 11 July 2016, after the constructive withdrawal of the only other candidate, Andrea Leadsom, left her as the sole candidate without any vote needing to take place.

This ensured that a PM was in place who was a remain voter. She did not trigger the Brexit process either, feeling it best for the nation that a delay happened giving those elites time to start making some carefully calculated mischief. And that is what they did.

Court cases, more court cases, EU threats were all the hazards being put in the way to try and get some momentum to make the country think again, vote again- like Ireland (until they got the vote the establishment elites and the EU wanted).

None of this worked and in order to ensure that some clear blue water was put in view to keep the Brexiteers happy, on the 29th May 2017, Theresa May formally wrote to Donald Tusk announcing the intention of the UK to leave the EU.

Establishment wheel 2; The Brexiteers were now happy but there appeared to be no strategy declared to deal with the negotiations. Many said this was because there was no strategy.

That could be because the end game here is that Brexit as wished for by the majority Brexiteers was never going to be allowed to happen. To ensure that outcome a very cunning plan indeed needed to be put in place.

It would cost politically but that did not matter. It is/ was about country, about the elites who control UKplc and certainly not about the people or indeed politicians.

Establishment wheel 3: Theresa May, in thrall, possibly hock to the Remain elites had to take some desperate measures. She claimed that an election was needed to boost her majority to ensure the ‘right outcome’ for UK plc prevailed, giving her negotiating strength in Brussels.

The right outcome for the Brexiteers was so called ‘hard Brexit’. The right outcome for the elites was a soft Brexit or perhaps no Brexit at all.

Establishment wheel 4: The problem with boosting the majority was that this was the very last thing the elites needed. The polls were suggesting a triple digit majority that surely would see ‘hard Brexit’ the result.

But the elites cunning plan was on track, instead of setting the election date to fit with the local elections- the most obvious option for a so called ‘snap’ election, the date was rolled back several weeks to allow campaigning to take place.

Something that would definitely muddy those clear blue waters.

Establishment wheel 5: With waters muddied, Tiny Tim went to work on the Brexiteers, to little effect. The Conservative lead was still looking impressive and Brexit on track. Manifesto time for the elites was the ‘nuclear’ option’ and the button was pushed.

Establishment wheel 6: The so-called leaked Labour manifesto started the wobble the élites needed, more state spending on the NHS, infrastructure, free university education, nationalising the railways and utilities but it was still not enough. What was needed to ensure true chaos and a Brexit sanity sabotage was something almost unthinkable.

Establishment wheel 7: With a Conservative majority still looking at upper two figures the final act was played out. The core Conservative vote is the old. They actually go out and vote.

They have worked hard for a lifetime, paid into the system, gone through wars, plague, famine, pestilence, recessions and even a number of Labour governments are still live in their thoughts. All those strikes, union power, three-day working weeks. They would never vote for Corbin.

Establishment wheel 8: How do you stop that mindset? Simples. You produce your manifesto last and in it you lay the ground to take away all your entire core vote that as a party have strived to retain.

To add a bit of toxicity to ensure more Labour votes you propose to end the fox-hunting ban, refuse to rule out tax increases and bring back Grammar schools.

The result? Job done, electoral chaos, a country fed up with elections, a Prime Minister who has no power without DUP support and what’s more cannot resign without risking yet another election that Corbin might actually win.

Not quite the ‘Up yours Delors’ result for the Brexiteers anymore.

Michael Gove was on record as saying “I think there’s a grassroots feeling of being betrayed by the elites in some way: that the system is working for itself and not for the people at the bottom”.

He was right, but it has escalated further up the system now.

Just a thought, after all, what do I know?

Politicians and Pyrrhic victories

Panacea Comment for Financial Advisers and Paraplanners

12 Jun 2017

Politicians and Pyrrhic victories

As the dust settles on the political mess that surrounds us, I, like you no doubt, have been reflecting on what ‘learnings’ (that wonderful word that those who should be responsible trot out when they have messed up) have been coming out, a little before Thursday and now in the swirling dust cloud of verbal spin, catch phrases, excuses, retributions, pollsters and egos.

My own MP, a junior minister at the Ministry of Justice, visited me last week and expressed his concern that the Tory party had gone ‘off piste’ into danger.

In skiing parlance this was because the small group of skiers had no guide, had not listened to a weather forecast and had no piste map with them or even an avalanche safety device.

I tend not to be too political. This is because I have met a few MPs over the years, some on the TSC, some who were not. I have been amazed at their arrogance, general stupidity and lack of any knowledge of real life.

The nation today should be, in Hector Sants speak, ‘very afraid’.

Why?

Because it now comes to light that the government, since Brexit, has in effect been run by two unelected individuals. They have excluded many senior ministers and MPs from the formulation of policy, a campaign strategy and manifesto.

That is bad enough.

What is worse is what we find out now.

Not only do we have an idiot as PM, we have a bunch of spineless ministers who sat there and said absolutely nothing. Not even a whimper of discontent, in effect offering up a ‘Nurnberg defence (we were only acting on orders) in fear of their jobs in the next government that was expected to have a hundred plus majority.

And even worse, the post election complete lack of contrition. Today from Michael Fallon on the Andrew Marr Show, making possibly the best Uriah Heep impersonation I have ever see by a politician.

Readers of Charles Dickens will know that the character is notable for his cloying humility, obsequiousness, and insincerity, making frequent references to his own “‘umbleness”.

And this lot want to form a government to see the nation through the Brexit process?

Once again I am reminded of Bob Monkhouse’s quote about his career aspirations. He said, “everybody laughed when I said I wanted to be a comedian. They’re not laughing now”.

In this case think of Mrs May. Nobody laughed when she called an election that was not needed. Well, they’re all laughing now.

God save the Queen.

We’ve got to start thinking beyond our guns- those days are closing’ fast

We’ve got to start thinking beyond our guns- those days are closing’ fast

When contemplating the future of the financial advice industry, I can’t help but be reminded of the late sixties movie The Wild Bunch. Set in 1913 Texas, the film follows an ageing gang of outlaws looking for one final score as the traditional American West disappears around them.

Substitute the slow motion, multi-angle view of the world in 1913 to that of 2017, where our industry practices are on the cusp of potentially drastic change that could create uncertain future. Virtual reality now prevails, technology is king and in our world the day of the robo- adviser is nigh. But while I wouldn’t want to compare today’s hard working advisers to the dramatic personalities of The Wild Bunch, there’s an undeniable parallel between these characters facing retirement and some troubling figures around the future of the financial advice sector.

 

The current age demographic of the industry, based on our community analysis above of some 18,000 is certainly veering toward the older generation. New entrants to the industry as at Q4 2016 were lower that Q4 2015*. To make matters worse the number of advisers de-authorising in the same periods exceeded those joining*.

It may not come as a surprise that the number of financial advice firms currently being set up in the UK is also falling, with just 334 businesses authorized by the FCA in 2016 according to an FCA Freedom of Information request. It’s not hard to see a link between these dwindling numbers and the lack of fresh business ideas that is often brought about by bringing young talent into an industry.

Barriers to new entrants can be many and varied. Cost is a primary factor, especially for those looking to start a new business. From June this year the new minimum capital resources requirement of £20,000 comes into force.

For most smaller, established, firms it will be based upon the greater of £20,000 or 5% of the previous years’ income. This is in effect dead money and based on the £20,000 minimum, new firms would need to have a minimum year one potential turnover approaching £400k to warrant the lock up of this money.

Fees for a new firm add up quickly, freeze the £20k then add in staff costs, office costs, professional fees, technology, marketing. Possibly followed by an FSCS call. And then comes the need to find a paying client.

If you are moving from an established firm it is highly likely that there will be contractual restrictions placed upon you regarding client ownership and possibly a geographical restriction along with a time based one.

Put bluntly, all of this means that those seeking to create a new business are betrayed by the sheer cost imposed upon the entrepreneur, the ambitious, the wealth builders of the future by regulation. Rather like The Wild Bunch gang, our industry could well be on the precipice of extinction altogether. Is it any wonder then that we’re struggling to attract younger generations to the financial advice sector?

* Statistics based on Equifax Touchstone analysis of our database and CF30 FCA data

Compliance and the Stupidity Paradox

Panacea comment for Financial Advisers and Paraplanners

13 Feb 2017

Compliance and the Stupidity Paradox

Compliance is an important part of the whole world of financial services and indeed many other worlds of business and governments.

In the world of financial services regulatory compliance “describes the goal that organisations aspire to achieve in their efforts to ensure that they are aware of and take steps to comply with relevant laws, policies, and regulations.

The rules are well defined, as we all know, in the FCA handbook. For the avoidance of any doubt, the regulator has even provided an introductory guide.

Regulated firms must follow FCA rules. The rules it would seem are clear (to the author/s) but the interpretation and purpose of them at times makes little sense.

A book, published in 2016 by the City University of London called the ‘Stupidity Paradox’ investigated common sense in decision-making.

Professor André Spicer’s research included input from management consultancies, banks, engineering firms, pharmaceutical companies, universities and schools.

The ‘outcomes’ of investigations into the ‘Stupidity Paradox’ revealed many examples of when common sense decisions are simply ignored.

Examples included: 

  • “Executives who more interested in impressive power point shows than systematic analysis.
  • Companies ran leadership development initiatives which would not be out of place in a new age commune.
  • Technology firms that were more interested in keeping a positive tone than addressing real problems.
  • Marketing executives who were obsessed with branding when all that counted was the price.
  • Corporations that would throw millions into ‘change exercises’ and then, when they failed, do exactly the same thing again and again

I just love the last one.

Professor Spicer’s concludes by asking, “Why could such organisations, employing so many people with high IQs and impressive qualifications do so many stupid things”.

I am reminded of the definition of a camel. It being a horse designed by committee.

I have worked since the early 80’s in the industry thought six different regulators- NASDIM, LAUTRO, FIMBRA, PIA, FSA and FCA. The average lifespan of a regulatory body being some six years.

With the exception of the FSA transition, rulebooks, even staffing, for the predecessor bodies have been subject to rewrite and new hire, not a roll over. The FCA transition was a re-skin.

What does ring loud and clear is that regulators do not, in the most part, seem to learn from past mistakes. Not only are ‘learnings missing, they more often than not refuse to accept responsibility or blame for past mistakes.

The FCA is now approaching four years old. So, in theory only another two to three years to go until yet another metamorphosis occurs. In that time it has seen two chief executives and a significant turnover of very senior staff embarking on a journey working for the firms they used to regulate.

Regulation is an industry. The thousands of pages in the FCA manual require firms in turn to employ thousands of people with high IQs and impressive qualifications to interpret the rules and ensure that their business implements them to the letter.

FCA research from 2015 found that 88% of large firms and 44% of small firms increased the amount of time and money they spent on compliance and the cost of regulation, according to New City Agenda is some  £1.2 billion.

But, and here is the big BUT. The finer interpretation of some rules would suggest that rather like in the Italian Highway Code, red lights are a suggestion, some rules make no sense in their implication.

We would love to know what examples you have of the Stupidity Paradox in financial services regulation today?

The Stupidity Paradox: The Power and Pitfalls of Functional Stupidity at Work (Profile Books), by Mats Alvesson and André Spicer.

André Spicer is Professor of Organisational Behaviour at Cass Business School, City University London.

Mats Alvesson is Professor of Business Administration at Lund University and a Visiting Professor at Cass Business School.

88% of Advisers would not use an outsourced Paraplanner

Nearly nine out of ten advisers say they prefer to employ a full-time paraplanner as part of their in-house team instead of turning to an outsourced paraplanner, exclusive research from Panacea Adviser has revealed.

The survey of just under 90 advisers asked if advisers consider outsourced paraplanning an attractive option for their firm, to which 88% responded to the contrary that they currently favour having a paraplanner on board as a permanent member of their in-house team.

Less than 1% of advisers surveyed said they would consider outsourcing paraplanning in the future.

We believe that the Retail Distribution Review (RDR) expedited the already expanding nature of the Paraplanner’s role and made them a ‘must have’ resource for many smaller advice firms looking to maximise their earning potential.

Against this backdrop, we might have expected to see a sharp uptake in demand for both in-house and external resources, something which makes the lack of popularity surrounding outsourced paraplanners in our latest survey a somewhat surprising result. However, in our opinion, this does not suggest that outsourced paraplanners somehow have less to offer than their in-house counterparts, they just need to do more to shout about the time saving and other benefits that outsourcing can bring to adviser firms.”

INDUSTRY VIEWS ON PARAPLANNING

The research also gathered opinions of both paraplanners and advisers, highlighting some of the key challenges – and benefits – that using this type of external resource can bring for advice firms.

Nathan Fryer, Director of outsourced paraplanning firm, Plan Works, said:

“I can fully understand why advisers would be apprehensive about outsourcing work of this nature to a third party. In many ways if I were advising myself, and could afford it, I would most likely look to employ a full-time paraplanner too. After all, inviting a stranger into what is quite often an adviser’s “life work” can be bewildering. 

“It’s this that makes communication so key when it comes to outsourcing, explaining why many outsourced paraplanners actually offer a bedding in period for the two parties to get to know one another and identify how they can work together.

While it is also true that having someone in-house can assist with other tasks such as admin and marketing, paraplanners are actually becoming increasingly few and far between, which means that salaries are also being pushed higher and higher.” 

Morwenna Clarke, CFP from Portland Wealth Management, also commented:

“We actually have a successful outsourcing relationship with a paraplanner at present but, in the past, we have come across issues around data protection when outsourcing.

“It seems that some outsourced paraplanners contracts don’t cover the legal issues around protecting and storing customer data, which could potentially see the adviser breach certain European laws. Another issue that may deter some advisers from turning to an external paraplanner is the changing definition of what constitutes a ‘worker’ under UK law, which may make it difficult to work with an outsourced paraplanner.”

As with every element of your business, it is important to ensure when working with a third party that the proper data protection licences are in place and that advisers work closely with their outsourced paraplanners to identify secure ways of communicating and storing data. This should help overcome some concerns that advisers have around using outsourced paraplanners.

Panacea Adviser provides opportunities for advisers and outsourced paraplanners to connect via its Paraplanner Directory and at no cost.  Here, outsourced paraplanners are able to include business details and links to their own website – allowing them direct access to Panacea’s 19,000 strong community.

For more information on the Paraplanner directory please click here. 

Happy 30th birthday Big Bang

Regulatory comment for Financial Advisers and Paraplanners

26 Oct 2016

Happy 30th birthday Big Bang

It was the great Gordon Gekko who said, “Moral hazard is when they take your money and then are not responsible for what they do with it.”

With these words of wisdom, I felt it might be time to reflect upon the fact that 30 years ago, on 27 October 1986, the closeted clubby world of the City was subject to a positive tsunami of changes that today, for those of us old enough to remember it, was called the “Big Bang”.

I was working in the City at the time and the financial services world, as we knew it changed forever from that date. The late starts, long lunches, early finishes were no longer fashionable, everybody started dressing like Mr. Gekko, huge mobile phones were ‘hand borne’ not hand held, the colourful LIFFE boys would strut their stuff around the Royal Exchange between trades and generally life seemed to have a very particular and agreeable buzz.

Over the past 30 years what was once a rather staid gene pool of public school chums in pin stripes, a veritable gentleman’s club of friends and relatives, had morphed into a US-stylisation of business practices.

With it came the skyscrapers of Canary Wharf and the City all linked with the considerable diversity introduced by foreign banks as plus points, but, the downside was that it came with a certain killer instinct that would mean even your friends and colleagues were not guaranteed a particular benefit without a cost attaching.

But in the post big bang world, as Mr. Gekko would say, “if you need a friend, get a dog”.

Regulation and financial services have not always been easy bedfellows yet upon reflection the world did seem a nicer, gentler place in many ways in the years building up to that 1986 Big Bang.

Social media did not exist then. What led to Big Bang was that the London Stock Exchange was coming close to, if not actually being found out without the enhancements of Google searches.

The stock market was really an almost regulation free (when compared to today) cartel, fixing commissions and linking this with trading floor admission complexities that would do the Royal & Ancient some credit.

It was a posh, gentlemen’s club version of the old London markets of Smithfield or Billingsgate- but with manners.

We saw a closed shop for the benefit of brokers and stock-jobbers all safely contained in their pin striped, bowler-hatted bunker which in the coming brave new world of class and professional barrier deconstruction would not be seen as acceptable any more.

Margaret Thatcher had been in power for some 7 years and the Thatcher vision of wealth creation by way of the state selling the public something they already owned was underway.

She was warned pre big bang, that this vision would lead to a new culture of ‘unscrupulous practices in the City‘, according to a release of government papers in 2014.

Her Cabinet secretary Sir Robert Armstrong said that a ‘bubble’ was being created that would be pricked” and “that corners were being cut and money made in ways that are at least bordering on the unscrupulous”.

But despite the warning, we still “Told Sid” and the nation rode a gravy train of expectation with flotations of once staid mutual institutions like the Halifax and Abbey National building societies- yes, remember them?

The merchant banks were in gorge mode on these flotations. SG Warburg, Schroders, NM Rothschild, Samuel Montagu, Hill Samuel and Morgan Grenfell were there doing it “very large”.

US investment banks like Goldman Sachs and Salomon Brothers (remember them too?) were also keen on some action but leading up to Big Bang it was not too easy for them to get into the club.

But change was on its way, the days of fixed commissions and closed shops were being replaced by the need to be competitive.

The City was no longer a place for “Gentlemen and Players.”

It was becoming a world of young and thrusting ‘spiv’ market traders who had literally switched venue, being recruited from the perceived ‘low rent’ market environs of Petticoat Lane, Billingsgate, Smithfield and Covent Garden.

And those guys brought their trading skills and “Loadsamoney” culture to the previously hallowed ground of the City and the Stock Exchange.

But now they worked, shouting in trading ‘Pits” or shouting at banks of computer screens waiting for that big deal, greeting it with more shouting and of course the resulting huge bonus moment.

The big success story of Big Bang was Warburg’s swallowing up of Ackroyd and Smithers, Rowe & Pitman and Mullens & Co who in turn were swallowed whole by UBS, then UBS/Phillips & Drew/Swiss Bank empire.

In the feeding frenzy Barclays paid huge money indeed for Wedd, Durlacher and de Zoete and Bevan, Deutsche Bank ate up Morgan Grenfell, Midland Bank (who are they) bought W Greenwell and this then got digested by HSBC. Kleinwort Benson bought Grieveson Grant, and NM Rothschild, Smith Brothers.

And what of the “Gentlemen and Players”?

Well they all retired to their stockbroker belt houses and country estates swapping pin stripe for tweeds, having “trousered” some very serious money.

With this sea change we saw the disappearance of those traditional and cautious values, my word is my bond, trust, nods, winks and tips were all to be replaced by what is now seen in many quarters as a reckless abandon, using somebody else’s money to trade on your own account for the benefit of the Banks who employed you and more importantly yourself.

If it all went wrong, the bank carried the losses until, as we saw with the spectacular 2007 banking collapse, the taxpayer did if nobody else seemed interested.

So when the indigestion disappeared from this bout of Mr. Creosote like fiscal gluttony, was Big Bang a success, was big beautiful?

Sir Robert Armstrong had the correct vision and Gordon Gekko I think has proved to be the master philosopher. The banks, post big bang, did take our money and were not responsible for what they did with it.

The largest banking fine in history levied this year has shown only too clearly that for rogue traders, in Gekko speak, “there is a very big difference between rehabilitation and repentance” and as far as casino banking and regulation is concerned, there is some way to go on both counts.

This would never have happened in the world of ‘Gentlemen and Players’?

Just a thought.