FOS upholds £100K Keydata complaint against John Joseph Financial Services

The FOS has upheld a complaint against a high-profile adviser over a Keydata recommendation, despite the client being an experienced Tep investor and it making up a small part of their portfolio.

A final decision by the FOS, published last week, upheld an adjudicator decision against John Joseph Financial Services for advice given in 2005 to invest £100,000 in a Keydata bond.

It ruled the Keydata secure income bond was too risky for the client, whose attitude to risk was assessed as ‘cautiously realistic’.

It found John Joseph’s financial advice “demonstrated a complete disregard for the client’s individual circumstances and interests”.

Ombudsman Roy Milne concluded while John Joseph is not responsible for the misappropriation of the Keydata funds, it “should be held to account for the poor advice it gave”.

The decision states the Keydata investment represented “a substantial proportion of the client’s pension fund”, but makes no reference to the entire portfolio. 

The redress calculation has not yet been finalised, but is understood to be around £100,000 – the maximum the FOS can award for complaints referred to it before January 2012.

John Joseph managing director John Joseph, who won the Protection Review Lifetime Achievement Award in 2010, says: “We understand the Keydata investment was worth less than 10 per cent of the client’s investment portfolio, which included a substantial portfolio of second-hand endowments.

“We recognise the industry has various opinions on the suitability of Keydata products, but in this case the advice was appropriate based on the client’s overall profile.

“As a small firm we regret that we are not in a position to take the case to a judicial review.”

Highclere Financial Services partner Alan Lakey says: “It is both unfair and stupid for the FOS to look at the Keydata investment in isolation.”


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There are 7 comments at the moment, we would love to hear your opinion too.

  1. It was good enough for a member of the CURRENT Financial Services Consumers Panel who was on BBC television this week!!!

    From: Phil Castle
    Sent: 18 March 2010 17:18
    To: ‘’
    Cc: ‘’
    Subject: Keydata
    Follow Up Flag: Follow up
    Flag Status: Red
    Page 1 of 2
    Dear Debbie,
    Before going in to any detail, I would just like to say I am not looking to lay blame at anyone’s door, I am
    simply trying to find some clarity on the Keydata issue and problems now being experienced by both
    client and advisers alike.
    I have very few clients affected by the Keydata problems, the majority were initially those whose plans
    turned out not to be eligible for holding with an ISAs, but with the latest problems with Lifemark, we now
    have clients whose income payments are proving irregular and look like to continue to be so judging by
    report from Luxembourg. My firm were not early users of Keydata’s Secure Income Plans, preffering to
    wait for them to be a known quantity and to have some kind of track record. As a result, I think the first
    ones we used were probably the SIP 9 whose offer closed in July 2007. The fact Keydata were by that
    time a well know name in the structured product market and were Authorised and Regulated by the
    Financial Services Authority (we believed as a product provider, but it now transpires they had changed
    from being a product provider to an Intermediary when the FSA replaced the PIA) gave comfort that the
    FSA would be carrying out an appropriate level of supervision and regulation of a provider authorised to
    handle client monies itself and ensuring that the promised experts (Legal, Life settlement sourcing agent,
    Investment Bank, Tracking Agent and most importantly Luxembourg Custodian were in place and fulfilling
    their duties). Checking these agents is not something you writing your report, nor advisers like myself are
    in a position to do, that is in my opinion what the regulator is there to do.
    Your report, (which is undated, but I assume was completed between 1st September 2005 based on the
    noted sources and spring 2007 when my clients invested) offered comfort to me when recommending
    what is something of a slightly different nature to other asset classes. From both an investors and an
    advisers perspective, it would be interesting to know what an updated report from you would say. I have
    not seen any comment from you in the press either distancing yourself from your original or updating the
    original commissioned report to reflect the current situation.
    In the original report it is stated you are happy to discuss any issues from this research, are you still
    willing and able to comment?
    Many thanks in anticipation of your reply
    Phil Castle

    From: Phil Castle
    Sent: 23 March 2010 08:33
    To: ‘Dr Debbie Harrison’
    Subject: RE: Keydata
    Follow Up Flag: Follow up
    Flag Status: Red
    Dear Debbie,
    Thank you very much for replying, it is greatly appreciated.
    Has anyone asked you for any of the research you undertook and to find out what access
    was given to you by Keydata, particularly information on their model for the life
    settlement portfolios which now appear to be failing to meet mortality expectations and
    hence provide the cash required to maintain income levels?
    There is a Keydata victims group at and I wonder if
    anyone has contacted you for your opinion or input yet? If not whilst I would not suggest
    you log in to it and get to involved as there are some very bitter investors making rash
    comments on it, if you wish to or are able and willing to supply any background
    information or thoughts from your original research and your impressions now on what has
    happened, that might be helpful.
    I may take you up on the offer of “further questions” in due course as although I only
    have a very limited number of clients with Keydata plans, getting to the bottom of what
    actually happened (or didn’t happen) to ensure my clients are protected is very important
    to me.
    Phil Castle

    —–Original Message—–
    From: Dr Debbie Harrison []
    Sent: 19 March 2010 10:24
    To: Phil Castle
    Subject: Re: Keydata
    Dear Phil
    What happened with Keydata shocked me then and shocks me still. I had an impartial
    academic interest in the underlying asset class – and indeed wrote a report about this
    with a colleague at the pensions institute (you can find the report at http://www.pensionsinstitute.
    I was introduced to Keydata by a reputable financial PR company and for the record I have
    to say they were as stunned as I was when the proverbial hit the fan. I haven’t been paid
    for a lot of my work for Keydata, needless to say, and I doubt I ever will.
    I do feel very upset that my report has influenced advisers and investors with such
    terrible results. This experience was one of several events which led me to change
    career. I haven’t quite got there yet but I have a PhD in English Literature and am
    looking for a teaching job. Birkbeck is my current home but this is an honorary rather
    than salaried position.
    So, in answer to your very just questions, I was taken in by Keydata and the ease with
    which this happened made me feel that I couldn’t do this sort of work in future.
    Do feel free to contact me if you have any further questions.
    Best wishes

  2. Overview
    The demand from private investors for medium-term products that offer attractive prospects for income and growth
    within a strong risk-management framework continues unabated. For the professional adviser concerned about the
    opacity and unrealistic claims of products as ancient and modern as with profits and precipice bonds, transparency is the
    number one priority.
    Keydata has for many years followed with interest the growth of the institutional market in traded US life settlement
    (life assurance) policies. Since the mid-1990s, the market has attracted investment from global asset managers and
    investment banks and has been thoroughly researched by independent academic institutions, including theWharton
    Business School, Sanford C. Bernstein, and A. M. Best.1
    In Germany and the US there already exists a thriving traded life settlement policy market, similar in many respects to
    the traded endowment policy (TEP) market in the UK.The Secure Income Plan offers private investors in the UK an
    investment in traded settlement policies via a transparent and well-regulated medium-term product.
    With target headline yields of 7.7% over seven years and 7.5% over five, the Secure Income Plan has an obvious appeal
    for investors seeking an attractive income over the medium term. For investors seeking growth, the target returns over the
    product term are 68% and 43.5% respectively.The Plan aims (but does not guarantee) to provide a full return of the
    initial capital invested and it may also be possible to roll over the initial capital into further issues.
    The purpose of this review is fourfold. First, I consider the product structure and the underlying portfolio of securities
    used to generate the target income. Secondly, I examine the construction of the portfolio in terms of the spread of risk
    across different policyholder profiles and insurance companies.Thirdly, I set out the third-party expertise harnessed by
    Keydata to ensure the highest standards of care. Fourthly, I comment on the role of this product in an income and
    growth portfolio and the risks that the adviser and client should understand before investing.
    The Keydata product literature sets out clearly how the Plan can be used within tax-efficient investment structures, such
    as individual savings accounts (ISAs), personal equity plans (PEPs), and in pension arrangements, including self invested
    personal pensions (SIPPs) and small self administered schemes (SSASs). It also models the anticipated income and
    growth options.Therefore I do not cover these points, which will be very familiar to professional advisers.
    1 Neil A. Doherty and Hal J. Singer, ‘The Benefits of a Secondary Market for Life Insurance Policies,Wharton School, 2002 14 October 2002
    (; Suneet Kamath andTimothy Sledge, ‘Life Insurance LongView: Life Settlements Need Not Be Unsettling’ Bernstein
    Research Call, 4 March 2005 (; Emmanuel Modu, ‘Life Settlement Securitzation’, A. M. Best, 1 September 2005
    Product review by Debbie Harrison, SeniorVisiting Fellow of the Pensions Institute at Cass
    Business School and contributor to the FinancialTimes
    The Secure Income Plan offers private investors attractive income and growth prospects via a
    relatively new asset class – the secondary market in US life assurance products – hitherto only
    available to institutional investors.
    1. Product structure and the underlying instruments
    The Secure Income Plan is a Sterling-denominated bond listed on the Luxembourg Stock Exchange. It invests in cash
    and a portfolio of traded US life assurance policies.The cash is used to maintain premium payments on the acquired
    policies and to pay income to investors, where this option is requested. In addition, the insurance companies that issue
    the traded life settlement policies pay out a lump sum at maturity – that is, when the original life assured dies.
    US life settlement policies are quite different from their UK counterpart. In most cases these are effectively lifetime
    policies (US universal life contracts are written to age 100) and, therefore, there is a guaranteed payout on death. In the
    UK life assurance is generally a fixed term product, with the exception of whole of life policies.
    The secondary market in US policies developed when it became apparent that many policyholders experienced a trigger
    event – retirement, for example, or a change in estate planning requirements – that made the protection policy redundant
    and a cash lump sum preferable. Before the development of the secondary market the policyholder in this position had
    no alternative than to accept a surrender value from the issuer.
    The creation of a secondary market in the US in the mid-1990s introduced a welcome element of competition and
    liquidity for life settlement policyholders. Individuals now have the opportunity to secure a better return on the policy
    that reflects more closely its embedded value. Generally this compares favourably with the relatively low surrender values
    offered by the issuer. Importantly, the secondary market created a new asset class for institutional investors that offers a
    low correlation with traditional equity and bond markets. According to the Bernstein study, the traded life settlement
    policy market grew from zero in the mid-1990s to around $13bn in early 2005 and is expected to grow to $165bn over
    the next few decades.
    It is essential to appreciate that the life settlement secondary market is distinct from the earlier viatical settlement
    market, in which policies of the terminally ill (AIDS victims, for example) were purchased, based on what proved to be
    flawed mortality assumptions. Life settlement policies are generally purchased where the lives assured have an expected
    mortality of between about two and 12 years and where the original policyholder is aged at least 65.
    The source of many of the policies held in the Keydata Plan are US business owners, who purchased commercial keyman
    insurance and where the life assured has retired or left. Importantly, Keydata allocates about 80% of the portfolio
    to policies where the life assured is aged 75 or over.This significantly increases the prospect of policies maturing within
    the term of the Plan, and hence the prospect of a higher yield or growth than is associated with standard portfolios
    The comparison with theTEP market in the UK is relevant. In the case of endowments, the market maker and the
    subsequent investor aim to purchase policies that have a significantly higher embedded value than the surrender lump
    sum offered by the issuer, taking account of the cost of maintaining premiums to maturity and the potential for future
    bonus prospects.
    There are important differences between these two secondary markets.The US life assurance policies generally mature
    on the death of the life assured and so there is an element of uncertainty over mortality assumptions, although Keydata
    mitigates this risk through its high weighting towards older policyholders in the Plan portfolio (see below). Endowment
    policies, in contrast, have a known maturity date, although the capital is paid earlier if the policyholder dies before this
    Traded life settlement policies, however, have a distinct advantage over traded endowments because they have a known
    value at maturity.The final payout on an endowment policy depends on a range of factors, some of which are difficult if
    not impossible to model.These include guarantees on conventional endowments, the financial strength of the life office,
    and the asset allocation of the fund. Such factors are becoming increasingly unpredictable as the endowment market
    evolves. Since the bear market of 2000-2002 many funds have closed to new business due to falling profits and the more
    onerous solvency demands on the part of the regulators.The prognosis for a policy in a fund that is closed, which may
    also be purchased by a consolidator, is uncertain.
    2.The portfolio construction process
    The success of the Secure Income Plan will depend on the expertise of Keydata and the third parties it appoints to
    construct, monitor and administer the portfolio of policies.The underlying portfolio aims to contain an appropriate
    number of policies to create a robust risk pool.The selection of policies, therefore, is based on:
    • Diversification across policyholders. Risk is spread by diversifying across policyholders by age, health, and by
    region. US government mortality tables, updated regularly, are used to model life expectancy.
    • A minimum policyholder life expectancy of two years.This enhances transparency in several important ways, for
    example it avoids the distressed sales associated with the viatical market. It also avoids ‘contestability’ issues on early
    death, which in the US can arise if the death occurs within two years of the policy being taken out.This might occur
    where the insurer suspects that important medical conditions were not disclosed or where the policyholder’s family
    suspect that unprofessional sales techniques were used to the detriment of the deceased’s estate. Policies bought on
    behalf of Keydata require that the policyholder’s life expectancy is a minimum of two years and that the spouse or
    closest relative is a signatory to the sale.This is considered best practice, as it might be in the case of an equity
    release product in the UK.
    • A high portfolio weighting to older policyholders: About 80% of policyholders in the Keydata Plan are age 75 or
    over.The actuarial modelling indicates that this confers a better chance that the policies will mature during the term
    of the Plan, as policies are purchased at the 85th percentile, compared with a standard portfolio, where policies are
    purchased at the 50th percentile.
    • Diversification across issuing insurance companies: Issuers are limited to a small maximum weighting in the
    portfolio, while the selection process also achieves a spread of credit ratings. Keydata has appointed a US
    investment bank (minimum AA-rated by Standard & Poor’s), which ensures that the issuing insurers of policies
    purchased are rated at least ‘A’ or higher by Standard & Poor’s or an equivalent rating agency.The portfolio typically
    starts with about 30 issuing insurers, including top national and global names.
    3.The experts behind the Secure Income Plan
    Keydata, which is authorised and regulated by the Financial Services Authority, is the promoter of the Plan, the
    administrator, and the PEP and ISA manager. In this role Keydata has overall control and management of the Plan and
    receives regular reports from third parties.The most important third parties to the Plan include:
    • Legal advisers, who establish the contracts between the parties and provide legal opinion so that the arrangements in
    place are best practice.
    • The US-based life settlements sourcing agent, which is responsible for the selection and purchase of policies in
    accordance with the formal investment criteria agreement.
    • The US investment bank, which holds the policies as trustee to the Secure Income Plan.The bank is also responsible
    for ensuring the premiums are paid and claims are processed when a policy matures.
    • The US tracking agent, which maintains contact with the original policyholders and informs the bank when the
    policyholder has died and therefore when the bank can process the claim.
    • The Luxembourg custodian, which oversees the issue of the bond.The custodian has a minimum ‘A’ rating by
    Standard & Poor’s.The application of double tax treaties avoids taxation on funds remitted from the US bank to the
    Luxembourg custodian.
    Following regulatory best practice guidelines, Keydata’s product literature does not disclose the names of the third
    parties involved, as to do so might be construed as an endorsement on the part of these organisations. Nor does it
    describe the portfolio construction explicitly due to the sensitivity of the intellectual capital. However, these details are
    available should advisers wish to arrange a one-to-one meeting with Keydata.
    4.The role of the Plan in an income or growth portfolio
    With the Secure Income Plan, Keydata has redesigned an institutional product for the retail market.The secondary
    market in life settlement contracts provides a new asset class for UK private investors, which has a low correlation with
    traditional income-yielding assets such as bonds, gilts and deposits, and also a low correlation with growth assets, such as
    equities and property. Although the name of the product suggests the Plan is aimed at investors seeking income, the
    growth prospects have also attracted a very positive response.
    For investors, the product would seem to confer several advantages. First, it offers an appealing regular income or
    compound growth over five and seven year terms. Secondly, and most importantly, it enables the investor to diversify
    their portfolio objectives by incorporating an asset class that has a low correlation with other income or growth
    holdings.This point is as applicable to the more adventurous investors with private equity and commodities in the
    portfolio mix, as it is to those with a more traditional spread of equity and bond funds. Clearly, the financial adviser will
    play an important role in assessing what proportion of the client’s portfolio should be allocated to this new asset class
    but in the institutional market the rule of thumb is that a 15% weighting is required for genuine diversification.
    The benefits of the Secure Income Plan are enhanced where they are held in a tax-efficient investment wrapper, such as
    an ISA, PEP, or pension plan, as the tax breaks boost the returns.The minimum ISA investment is £4,000 (£7,000 for a
    Maxi-ISA). Pension investors have considerable scope for tax-efficient annual contributions following pensions tax
    simplification in April 2006. In the case of direct investments there is no maximum but it will be necessary to declare
    the income on the annual self-assessment tax return. Currently income is taxed at 20% for basic rate taxpayers and 40%
    for higher rate taxpayers.The growth element is taxed in exactly the same way.
    It is vital for advisers and their clients to appreciate that this product does not offer guaranteed income or growth.The
    target rates are based on Keydata’s actuarial modelling of the profile of the policies purchased. In terms of risk, for
    income investors the Plan is less secure than deposits but would compare favourably with the more aggressive bond
    funds, which can only achieve target yields by including sub-investment grade bonds in the portfolio mix.
    For growth investors Keydata’s carefully constructed portfolio would seem to be far less volatile than stockmarket
    investments. Of course, for both groups there is the inherent risk that medical advances, as yet unknown, could prolong
    the lives of the original policyholders, while a change in US legislation and regulation could also affect the value of the
    policies. However, the Keydata five- and seven-year bonds, weighted towards the traded policies of the 75-year-old+
    market, seems to be well immunised against any unforeseen change.
    Finally, while the Secure Income Plan offers private investors a transparent vehicle and the opportunity to diversify risk
    through an asset class that has a low correlation with traditional markets, it is important to appreciate that the Plan is
    designed to be held to maturity – that is, either five or seven years. Investors who encash their holding before maturity
    may get back less than the original investment.
    About the author
    Debbie Harrison is a SeniorVisiting Fellow at the Pensions Institute, Cass Business School, where she is a researcher and
    the co-author of four landmark pensions reports. Elsewhere she has published a wide range of UK and global retail and
    institutional finance books and research reports and has been a contributor to the FinancialTimes on pensions,
    investment, alternatives and expatriate issues for 20 years. In addition Debbie is a consultant to major financial
    institutions and also runs financial training courses for institutions and government departments, including the
    Department forWork and Pensions, HM Revenue & Customs, and the Office for National Statistics. She is a trustee of
    the Financial Inclusion Centre, a financial research charity, and she is an adviser to the DWP on pension reform.
    Keydata commissioned Debbie to write this product review.The firm provided technical assistance but she retained
    editorial control throughout. She is happy to discuss any issues arising from this research and can be contacted at
    Issued by: Keydata Investment Services Limited. Registered no. 3714989, Registered Office: Floor 8, Fountain House, 2 QueensWalk, Reading RG1 7QF. England andWales. Keydata
    Investment Services Limited is authorised and regulated by the Financial Services Authority. Keydata Investment Services Limited does not offer investment advice or make any recommendation
    regarding investments.
    All of the insurance contracts within the plan are issued by financial institutions rated at least ‘A’ by Standard & Poor’s or equivalent. Returns from the insurance contracts are at risk in the
    event of any of the institutions defaulting on their financial obligations, if the insurance companies issuing the insurance contracts default on their obligations or if factors change which affect
    the rate at which insurance contracts mature.This material is for professional financial advisers only and persons of any other description should not rely or act upon it. Any investment inThe
    Secure Income Plan should be made only after the investor has read and understood the Brochure, Key Features andTerms & Conditions.

  3. Debbie seems to have “got over” her reluctance to “do this sort fo work” and remains in financial services and remains on the FSCP. One has to ask WHY she hasn’t ever spoken out publicly and how in not doing so, she can be allowed to continue to sit on the FSCP.
    Condemn or Condone Dr Harrison, DO NOT expect to be able to continue to sit in the sidlines any longer.

  4. BA (Nottingham), MA (Birkbeck), PhD (Birkbeck)
    Honorary Research Fellow, Birkbeck
    I completed my doctoral thesis in 2008 and am now working on
    the monograph, which is under consideration at Cambridge
    University Press. A Victorian Hangover: Narratives of Addiction
    1820-1900 explores the interface between literature, the history
    of medicine and social science. Here I examine depictions of
    addiction to alcohol, gambling and narcotics in a Victorian texts
    and employ the literary model established by Thomas de
    Quincey in Confessions of an English Opium Eater (1821) to
    explore the connections and disparities between the Romantic
    and Victorian modes of representation. Separately I am editing
    new critical editions of George Gissing’s early urban
    degeneration novels, and working as contributing editor to a
    medical humanities project, ‘The pathology of the missionary-doctor’s journey: theorising the
    relationship between body, mind, place, and text in Livingstone’s unpublished final field
    diaries’. I have taught English and Film at Birkbeck and Greenwich and will be working with
    Birkbeck staff to help with the design and delivery of the MA in Medical Humanities in 2010. I
    have published articles in The Gissing Journal, Gothic Studies, and Nineteenth-Century Gender
    In my previous incarnation I was a Senior Visiting Fellow of Cass Business School (City
    University), and an author and journalist working in the interdisciplinary field of demographics,
    economics and welfare. In this guise I have written extensively for the Financial Times and also
    for the Guardian, Telegraph and Times.
    Printed from:
    Date printed: 18/03/2010

  5. Available on Amazon
    Personal Financial Planning: Theory and Practice [Paperback] Debbie Harrison (Author)

  6. Debbie Harrison
    Senior Visiting Fellow, The Pensions Institute
    6 Palmers Hill, Epping, Essex CM16 6SG
    Tel: 01992 577420 / 07742 552 807
    In brief

    Consultant to the OECD, the Department for Work and Pensions, and the Financial Services Consumer Panel

    Co-author of pensions reports for the Pensions Institute at Cass Business School (see below)

    Regular contributor to the Financial Times and FTfm. Occasional contributor to The Times, Investment & Pensions Europe, Financial News, Money Management, Pensions Management, Pensions World, Pensions: An International Journal, Economic Affairs

    Design and delivery of pensions training courses to the government and financial institutions

    Consultant to financial institutions on the design and delivery of pension schemes, pensions research, and media relations. Clients include Alexander Forbes, Allianz Global Investors, AXA, Bank of New York, Goldman Sachs, Lane Clark & Peacock, Norwich Union, PricewaterhouseCoopers, RS Consulting, SEI, State Street, and Xafinity.

    Trustee of the Financial Inclusion Centre, a research charity.
    Co-author of the following Pensions Institute reports

    ‘And death shall have no dominion: Life settlements and the ethics of profiting from mortality’, July 2008

    ‘Are customers in closed life funds being treated fairly? Raising the bar for advice, administration, communications, and governance’, September 2007

    ‘Dealing with the reluctant pensions investor: Innovation and governance in DC investment’, April 2007

    ‘Accessible Annuities: How the industry can empower consumers to make rational choices’, March 2006.

    ‘Pyrrhic Victory? The unintended consequences of the Pensions Act 2004’, October 2005

    ‘DC Design and Delivery’, published October 2004
    Financial books

    Personal Financial Planning Theory & Practice, Financial Times Pearson Education, November 2004

    Wealth after Work Financial Times Prentice Hall, 2002

    How to Make it in The City, Virgin Publishing, 2001

    First Time Investor Financial Times Prentice Hall, 2nd edition, 2001

    Personal Financial Planner Financial Times Prentice Hall, 2nd edition, 2001

    The Money Zone, Financial Times Prentice Hall, 2000

    Pension Power Financial Times Prentice Hall, 3rd edition, 2000

  7. I can’t find a copy of the interview Dr Harrison gave to the BBC earlier this week, but these links are still on BBC website

    One minute we are expected to take notice of this lady, she is feited by the Times, BBC, FSA Givt and so on.

    Next minute Keydata shit hits the fan. so she keeps her head down for a while and then…..

    Bad timing her head raises on TV on Tuesday this week talking about pensions, so she appears to be back on the gravy train. Good for her, unlucky for John Joseph and all those consumers.

    Why should anyone trust her judgment when he judgement appears to have been flawed, but she has failed to say one single word publicly about the whole Keydata debacle.

    17 March 2005
    Pensions Panic: All Worked Up
    Business / 17 March 2005
    … to divulge their take-up figures. Debbie Harrison, a senior pensions analyst at the City University’s Pensions Institute believes most employers…

    30 September 2004
    Bosses obstruct pensions uptake
    Business / 30 September 2004
    … for workers to be automatically enrolled in a company pension scheme unless they opt out. Co-author of the report Debbie Harrison said such…

    17 November 2000
    Pensions factsheet
    Fact Files / 17 November 2000
    … number 0800 252100. Pension Power: Understand and Control Your Most Valuable Financial Asset second edition/Feb 97 £13.99 Debbie Harrison, published

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