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How dangerous are the Conservatives?

Following on from a critique of the LibDems on the MM website earlier this week, compliance expert Adam Samuel raises some regulatory concerns should the Conservatives win the general election. A further piece regarding Labour policies will also be appearing on the MM site in the near future.

Following Money Marketing’s article How dangerous are the Liberal Democrats earlier this week, I was asked to pen an article examining the prospects for IFAs of a Conservative victory. Some basic preliminaries are necessary. I am not a member of any political party. I have voted for each of the three main ones in past elections.

The Conservatives are unusual in being able to de-stabilise financial services regulation while in opposition. Their policy of abolishing the Financial Services Authority has damaged morale and made the recruitment of quality staff there just about impossible. While the announcement of Hector Sants’ departure from Docklands was explained by reference to a three-year plan, it is hard to avoid the suspicion that the FSA Chief did not want to run the organisation while it was being politically dismantled. Either way, the organisation cannot now recruit his successor and the handover is supposed to be a few months away.

IFAs who hate the FSA may find this hugely encouraging. Compliant ones should know better. How can an off-balance organisation that is being re-formed by politicians pursue banks for flogging investment bonds instead of independent financial advice. Big enforcement action only comes about when a regulator is self-confident. So, IFAs competing with dodgy neighbours will be operating on an uneven playing surface for as long as the regulator is unable operate dynamically with its future secure.

The Conservative manifesto and website actually says little about its much-vaunted plans for regulatory change. Prudential supervision of banks and large or perhaps all insurers will go to the Bank of England. This is in spite of the fact that the Bank has no interest or relevant expertise in insurance. When banks should be concentrating on improving standards, they will be trying to work out how to liaise with another group of regulators.

It is unclear where the Tories propose to draw the line for the transfer of institutions to the Bank. At one stage, only large depository institutions were going to be considered by the Bank. Now in its “Plan for Sound Banking”, the gravity of Mervyn King will be brought to bear on credit unions! Either way, the regulatory transfer will just involve moving the desks of one group of regulators from Docklands to premises as yet unfound. Removals companies will benefit considerably from this and other Tory proposals!

The Tories conveniently forget why prudential supervision of banks was given to the FSA. Threadneedle Street made such a mess of supervising BCCI that it had to shut the bank amid pools of fraud and financial crime in 1991. The Bingham Report on the subject may not sold millions but it should have been on George Osborne’s reading list. Nothing seems to have changed in the meantime. In 2007, Mervyn King did not call the impending bank crisis any more accurately than the FSA.

One part of the Tory plans makes excellent sense: its proposal to merge the consumer credit side of the Office of Fair Trading with the “rump” of what is currently the FSA. Any criticism of the effectiveness of the FSA always has to be countered by comparison with the mess created by the OFT. However, in order to play political games, George Osborne has to wreck a good idea by changing the name and legal identity of the FSA into the Consumer Protection Agency. This change, accompanied by sometimes justified descriptions of the current regulator’s incompetence, only makes that organisation’s difficulties worse. The CPA’s staff will be the same as that of the FSA minus the bank supervision teams if the Tories win. All that will happen is that we will have a new rulebook to learn and a period of hiatus before the new organisation acquires sufficient confidence to carry out challenging enforcement action. IFAs must understand that a new regulator without its own core will only be able to go after them as the financially weaker targets. Anyone able to put up a fight will be off the enforcement agenda.

The next alarming part of the Tories’ plans relates to the rest of the FSA. Nobody seems to have considered the FSA’s generally successful role in regulating the smoothness of financial markets, its work as the UK listing authority and above all else financial crime. There is a suggestion that this last area should go to a beefed up Serious Fraud Office. Anybody who thinks that we can have clean markets with the SFO monitoring and then prosecuting financial crime, market abuse and the like has conveniently forgotten how that organisation has to juggle its budget just to prosecute the worst fraudsters. It has no regulatory experience or interest at monitoring or supervising.

Actually, the Tories seem to be rowing back from its beefed-up SFO idea, indicating in its “Plan for Sound Banking” that the Consumer Protection Agency could deal with financial crime. They do not appreciate that consumers are not the victims of much market abuse. The same document also seems to suggest moving the market management function of the FSA to yet another new regulator, merging these functions with the Takeover Panel and Financial Reporting Council. That still does not account for the listing authority functions. More to the point, though, the Conservatives are now up to four regulators to perform the FSA’s current role.

On regulation, a desire to put one over the current Prime Minister threatens to create regulatory chaos with multiple institutions being created, each with their own addresses, staff, rulebooks and problems. If for political reasons, Osborne had to argue for transferring bank prudential supervision back to the Bank of England, that would have been silly but harmless. It might have been cancelled out by the OFT consumer credit merger with the FSA. For what looks like childishness, we face a nightmare scenario of regulatory all change. It is not clever.

The Tory tax proposals are generally too vague to be subject to scrutiny. They want to start to reverse the effect of the abolition of the dividend tax credits for pensions but cannot fund it. There are two proposals shared by the Liberals: ending the obligation to buy an annuity (neither explain how the death charge will work) and a proper Equitable compensation scheme. The last point raises questions about customers of other closed with-profit funds who probably suffered the same fate for the same reason. Payments to child trust funds will go for all but the poorest third or the disabled (the Liberals would scrap them altogether; Labour proposes to increase payments for the disabled). The raising of the IHT threshold to £1 million will be popular in the South. It will, though, reduce the demand for IFA skills in this area not to mention the overall tax take.

The Tories’ proposals on financial regulation have had them laughed out of their natural constituency, the insurance and banking industries. Only the addition of consumer credit to the FSA’s portfolio seems a good idea which the other parties do not oppose and will probably happen in the fullness of time. The rest will rightly wither in the event of a hung Parliament or Tory defeat. Vote but, compliant firms, be “very afraid” of a Tory outright win.

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Comments

There are 29 comments at the moment, we would love to hear your opinion too.

  1. The fact that the writer admits to having voted for all three parties adequately expresses the weight which one ought to give to his forecasts.

  2. Better a devil you know that one that is to be charitable embryonic in thought.

    Nothing will change the staff will just move form one office to another and the most important thing is Cost, yet more cost. No thanks to the tory plan.

    RDR will not change.

    I have been around since FIMBRA day’s and we seem to go through periods of heavy regulation then that ease’s as the regulator realises that we should all work together, I have now seen this 3 times, do we want a 4th term of all the same again.

  3. Is the writer after a job at the FSA?

  4. Given we’ve had most of the media (particularly the right wing press) screaming ‘down with labour, vote conservative’ for the last 2 weeks and no doubt more to come, a modicum of balance is welcome. Regarding the FSA, for all its faults there is a danger of voting for fires over frying pans.

  5. So Mr Samuel is a ‘compliance expert’ is he?

    And he says ‘Nobody seems to have considered the FSA’s generally successful role in regulating the smoothness of financial markets,’?

    I guess this article, if nothing else, gives us an real insight into what life must be like on ‘planet compliance’!

  6. It’s interesting to note that only people that have poor record-keeping and go out to screw clients have to worry about FSA.

    I don’t care if you call it the FSA, Bank of England or indeed FSO. What we need in financial services is a regulator that is both strong and cracks down on those who behave badly.

    It is clear that both the Bank of England and the FSA have done an extremely bad job in regulating banks over the last 30 years.

    So my fellow colleagues stop whingeing about regulation and come up with some sensible ideas on how we can prevent future financial crisis like we have had over the last two years.

    I’m personally in favour of a very strong regulator has some real teeth to crack down on banking practices.

    I would also like to see a ban on all banks providing financial advice and if they do, these should operation and be stripped out as a separate company that is not held with in their branching network. These advisers should also be called salespeople and not advisors or consultants.

    All banks should be banned from having independent arms to their business as a bank can never offer independent financial advice as it is always biased towards its own products.

  7. This article sounds as condescending to IFAs as any sound bite from a labour party spin Doctor is to the electorate at large. We’ve had 13 years of a socialist government in charge of Regulators and little has changed, other than the increased burden of regulation. Labour has introduced 5000 new criminal offences in 13 years covering crimes already punishable though existing legislation; sound familiar? TCF anyone? The IFA industry as a whole is and will be “competing with dodgy neighbours……and …… operating on an uneven playing surface”. This has nothing to do with the inability of the FSA to “operate dynamically” whilst its future is unsecure. When has it ever operated dynamically? As a firm who embrace all facets of regulation as good business practice, we do not fear our Regulator or its bosses. But when financial services regulatory policy seems only to apply to the IFA industry and the Regulator remains in awe (and fear) of the Banks, our playing surface will remain more rocky than uneven.
    Regulation should be above party politics and fair to all practioners. It is as I understand, supposed to be a risk based model approach. Sadly we endure a policy of screwing the least-risk sector of the industry for a disproportionate amount of the fees and an over burdening of rules and regulations.
    Let’s make the next Regulator either fully independent of Government or a cross-party body. To bring fair and workable regulation to an industry that clearly needs it.

  8. FSA and Mervyn King didnt see the crisis coming? They should both be got rid of as the incompetence defies all belief. I was at an Invesco Perpetual seminar in Feb 2007 and their fund managers were screaming about the then forthcoming catastrophe. If the fund mangers could forsee it then how in the name of all that is merciful could the FSA and King not see it. Crime of any type should be left to the professionals – the police. The FSA should be disbanded (as should FSCS). All they have done since inception is totally ruin an industry. The cost to all providers and especially IFA’s is a total disgrace. Some of this in turn gets passed to clients in one way or another and for the vast, vast majority of clients the advice and sales process is no different now than it was in the 60’s, 70’s or 80’s excpet it costs them and us a lot more. The writer says the Tories policy has damaged morale and is making the recruitment of quality staff impossible. If he thinks the FSA has quality now then he is a mentally unstable a mentally unstable thing and needs some urgent treatment. I say go Davy boy, go. They are like any other big organisation. They are full of jobs worth tosspots who know very little about the real world and what ordinar decent people want. They sit in their Ivory tower in Canary wharf on big salaries with expenses that they exploite and break rules with (to me that is stealing from your employer – oh thats financial crime but the “old boy” network or or school tie brigade stick together) and final salary pension making life more and more difficult for IFA’s to a great job for our clients, which as the huge majority of us do. (They target us because we are an easy source of income for them). The FSA are not interested in those of us who are in the business 20+ years and so far complaint free. If they were then the regulation would be based on how “risky you are” and not just have a one size fits all approach. Sack the lot of them and put a brand new organisation together with new staff who have common sense and can be trained how to regulate in a proper manner that has relevant rules for each sector of the industry. Its not rocket science you know. The advert should contain the phrase “candidates with previous experience in the FSA (except cleaners) need not apply as you WILL be unsuccessful”. Let the treasury take the whole lot, I believe there are going to be a lot of civil servants looking fo a job soon, so give them the jobs and pass the whole burden of funding to the tax payer. For once in our lives give us a break.

  9. if we agree everything has to be regulated/supervised it should also be subject to the law of the land – and the regulation/supervion should be accountable – if retrospective legislation is good for the IFA community I consider it is good for Members of Parliment – so any one that has been an MP that has claimed expenses what so ever should have to prove what they have claimed on – if they cannot prove the same they should be forced to pay back any claims + 8.5% interest – this applies to any MP that is alive – because the FSA have indicated that they will follow me to the grave if a claim is made against me – THIS ALSO APPLIES TO CLAIMS MADE BY EMPLOYEES OF THE FSA WHO CURRENTLY APPEAR TO ABUSE THE SYSTEM WHEN CLAIMING EXPENSES – EVEN THOUGH THEY ARE GIVEN GUIDLINES TO FOLLOW – THE RICH GET RICHER AND THE POOR GET POORER- I have only ever voted for one party – but they are not totally whiter than white – in fact a bit yellow-

  10. The writer seems to have forgotten that the FSA has apologised for not regulating the banks properly. I see little problem with separating the roles of supervising banks from consumer protection. If you look closely you will note that we are regularly told that a fine was reduced because of the “co-operation” of the gulity party. That is as a result of an unfair advantage the regulators have been given in law. Remember how much difficulty the Serious Fraud Office has had in pursuing criminals in the past. Role on a fairer approach for all. Finally, I was highly amused to hear an American fund manager bemoaning President Obaman’s latest proposals, because that might result in the best talent moving to for example the UK!

  11. Having read your article I have to wonder if you have ever really thought about whether or not the FSA have helped anybody other than themselves. They are demanding millions in fees from the IFA sector to cover their increasing costs which continue to spiral and paying themselves millions in bonuses which for a civil service body ( it is, whether it admits it or not is irrelevant) which is an affront to everyone that is struggling to survive in the present climate. They are obsessed with creating trails on advice and at present have no concern whether or not the clients funds are invested to grow having stated that they are not concerned with whether or not the clients make a profit which is the usual reason for investing. They forced people to attend pension seminars at which they would not answer questions and would not confirm whether or not the people giving the seminars were qualified which can only mean that they were not otherwise why the secrecy!
    They insult us by buying art to support new artists paid from our fees although they would not pay more than £20,000 for an individual piece and one wonders what happens when the piece is sold and who purchases it or for what price? No answers on that point that I have heard! They destroyed millions of with profits endowments and pensions when they forced the change of investment (equities from 75% to around 25%) in the early years of this century which poured billions of pounds worth of equities into the market when it was already crashing after the tech bubble burst and the 911 disaster although they did a very good job for the government by telling the investment companies that government bonds were acceptable as they were a more suitable risk (war coffers must have burst) unfortunately no-one told the FSA that endowments and pensions which had been invested in the traditional form of investment in the past, with profits, were traditionally a more balanced to adventurous growth as they needed to produce a higher return and had always done so. One always thought that they knew the difference between bonds and endowments or pensions but perhaps that assumes too much. However, they did a very good job covering it up with the help of the media who as usual were blaming commission hungry salesman without seeming to be aware of the investment change. They are allowing an increase in equities now but for millions it is too little too late, myself included as I had set up an endowment in 1977 which was for 38 years and to that point was doing very well but they destroyed it.
    On that thought I realise that we obviously cannot be talking about the same FSA who are obviously blameless and their appreciation of all the wonderful service that the banks give the public goes without being mentioned.

  12. I freely admit to hating all the main parties at the moment. However there is only one party that will do real damage if they get a clear majority. The Conservative Party! I’m not just talking about economic recovery that would be in danger the whole of the financial services industry would be.

    Don’t be fooled RDR is a coming no matter what.

    The banking crisis and other financial mismanagement was not the fault of the government or regulator, it was the banks fault, they had pleaded for the freedom from regulation – when they got it then blind arrogance took over.

    If you think about it its how our industry has been for a while as well, commission bias has been allowed to cloud judgement and now when they do stuff about it we start complaining.

    Back to the main point….why pull down the whole system, give back credibility to FSA, make it accountable to the public for failings and give credible appeals system. Let the England get the banks into line or hand over all powers to the FSA.

    The regulator is far from perfect, it needs to employ better staff and more staff at regional hubs, i.e. not just in London. It also needs to get the arrogance and public school old boy network shaken out of it. It needs competence and it needs to hire top people from both our industry and the product providers.

    I fully believe a hung parliament is the only thing that can save the country and the moment, torys in power will devastate us all

  13. Incompetent Regulators Awards Team 23rd April 2010 at 11:14 am

    Well what an article, sways from one side to another this guy’s opinion. Sorry mate you also know nothing about financial regulations. You mention the SFO not being qualified to handle FSA type stuff, but the FSA is also full of unqualified people. So what’s different? And to add to insult to the free market workers such as IFAs most FSA top knobs are X-Bankers. So they can abuse is as much as they like, hence the RDR!

    And as for consumer protection, it’s failed. The FOS circumvents the law and makes it’s own law. As an example the endowment claims are tantamount to fraud. Most are try ons as quoted by Howard Davies in the Telegraph. The FOS has proved to be the biggest assistance to fraud claims ever as they ignore attempts of fraud from consumers. Yet no MP does anything because it’s a vote loser. So the endowment review was carried out under our noses by pretending there were lots of complaints helped and whipped up by FSA re-prejection letters to clients showing potential shortfalls and calling them red letters. Most FOS adudicators have no qualifications at all and are making major financial decisions on behalf of others whilst being unaccountable.

    We have such a sh*tty broken system there is absolutely no argument to keep the same wunch of bankers.

    I agree that we may and up with the CPA with the same useless people, but I can assure you there is such a strong feeling amonst some of us we are constantly pushing the Tories to make them see the correct way if they were to win. What other choice do we have? Do we just sit back and accept it all? Not on your nelly, if we were all like Adam Samuel, e.g. changing views with no firm beliefs on how to sort things, we would definitely end up with what we’ve got! e.g. More cr*p.

    Is this guy looking for a job within regulations?

  14. What!! ……..Bank of England has no interest or relevant experience in insurance?? (2nd paragraph). Now I AM worried!! (Not).

    If the writer has voted for all three parties perhaps this shows how fickle his attitude is to politics, hence this laughable article!!

  15. compliance “experts” have a lot to lose if the fsa is abolished.

  16. Blue to the core 23rd April 2010 at 11:42 am

    This whole tv debate has been a massive blow to our (tory) election chances. The conservative party has been sitting on it laurels not rocking the boat expecting just to cruise into power with the poll lead we held. We have not been proactive about any of our policies, it seems to me Cameron has been shown up, he is not a credible leader, for goodness sake ken Clarke is still in the shadow cabinet – there’s a credibility crusher.

    And now even the brown bomber is landing cheap shots on Cameron, Mr doom and gloom was almost funny – unheard of.

    If Cameron doesn’t pull his socks up and do something we are going to lose, if the lib dems are seen as other choice we are done for

  17. in response lol if fsa is replaced rather than reform the whole industry is friar tucked not just compliance experts

  18. How dangerous is Adam Samuel?

  19. If the lib dems get in you have to remember that the cabinet will consist of Lembit Opik a man who has literally shagged himself cross eyed

  20. in response to worried; in your own words I think it is Friar tucked already

  21. re lol yes good point well made!

  22. Marty Young’s comment is most interesting. If all the fund managers in 2007 saw the credit crunch coming then why they didn’t they all drastically change their positions to avoid their funds dropping spectactularly and why did so many investment managers purchase a hughe quantity of crappy super-sub-prime bonds.

    Those who did say ‘there may be a correction’ rarely specify the exact timing or drop or the extent of a correction and either keep stating this until of course one happens eventually or change opinion every other month – I mean market is onlygoing to go up or down so 50/50 chance of being right!

  23. Well, these comments are very interesting. A few little clarifications, though, might be in order.

    I have never applied for an FSA position and there have been plenty advertised. I don’t have any plans to apply for one now.

    Anyone who reads the article carefully will note that the only praise given to the FSA concerns their management of the market process (which is not insider trading, market abuse or financial crime, just the processing of transactions, notably after the Lehman failure).

    There is much to criticise about the FSA. However, anyone who thinks that changing the regulator’s names, legally restructuring them and moving some groups and some groups out will improve the regulator, is, I think misguided.

  24. Interesting stuff. My impression of this campaign is that everyone’s views is coloured by the party for which they vote. T’was ever thus.

    Anyway, current polls point strongly to a coalition. Should MM do a piece on what’s likely to happen in the inevitable horse trading which will follow?

  25. If memory serves me correctly it was the Conservatives who started us on the road to Regulation and ruin with the Gower Report. Norman Tebbit was a big fan of the whole idea. Then came Maggie and Geoffrey Howe abolishing the bank reserve requirements.

    How dangerous are the conservatives ? Unbelievably so in my view – the party of unintended consequences.

  26. The Supreme has just granted two pedophiles a right of appeal and review. An IFA under the FOS does not get the same human rights as a pedophile! That is what I call damaging to morale!

    MR SAMUEL SAYS : “Their policy of abolishing the Financial Services Authority has damaged morale and made the recruitment of quality staff there just about impossible.”

    I SAY: Try maintaining morale when working a 60 hour plus week, 500 hours of first year degree level study, the threat of termination post 2012 and being stitched up by the FSCS Key Data FSA fiasco and all at a time when the UK goes bankrupt partly due to the FSA failure of banking regulation. At the same time the FSA sees fit to apply RDR to the IFA when he/she is responsible for less than 3% FOS complaints compared with 59% FOS compliants via the bank!

    So I won’t be crying over the FSA whom I consider an abomination and a travesty of human rights. I have no doubt that most of them will be phoenixed into FSA version 2 in any case!

    YOU SAY: IFAs who hate the FSA may find this hugely encouraging. Compliant ones should know better.

    I SAY: What astonishing arrogance! If you are compliant you should know better than to challenge this quasi judicial regulator. Well Mr Samuel perhaps there are some compliant IFA’s that know the difference between what is right and what is wrong. This is not anti regulation and a desire to be treated as if you had basic human rights should not be seen as non compliance!

    Signed Ann Onymous (for fear of the Stasi FSA knock at my door)

  27. As I have written before, merely partitioning the FSA will be nothing but a costly non-solution to the fundamental problems and corruption with which that organisation is beset.

    If, as Hector Sants has predicted, the CPA is going to be staffed by all the same people with the same prejudices and biases, principally against the IFA sector, then nothing is going to change.

    What is really needed is far reaching reform of the FSA’s accountability for its actions. A Statutory Code of Practice for Regulators exists but the FSA ignores it and no one holds it to account. What this tells me is that the most urgently needed new regulatory body is one to regulate the FSA. The list of items on the agenda of such a regulator would be long indeed, but no less relevant or justifiable for all that.

    I am struck by Adam Samuel’s suggestion that the CPA will continue to persecute the IFA sector because we don’t have the muscle to raise legal challenges against manifest injustices and that the banks therefore will continue to enjoy an easy ride. What this tells us is that there are indeed legal challenges to be mounted (that from L&G in respect of the FSA’s hindsight review of endowment sales was at least partially successful) but that the FSA deliberately steers clear of the risks running into them. Ergo, we have an uneven regulatory playing field and the principal victims of such a skewed regulatory agenda are those least able to challenge it.

    Just one of the principal responsibilities of any regulator of the regulator would surely be to impose on the FSA or CPA a requirement to wield its powers in a just and equitable manner. For example, the cost:benefit analysis on which the FSA has based its decision to steam ahead with the RDR has now been comprehensively and resoundingly invalidated. A new regulator of the regulator should have the power to direct the FSA to scrap it and go back to the drawing board. Instead, all the FSA has done is merely to shrug its institutional shoulders and effectively say oh well, so what, the RDR will be proceeding anyway, regardless of whether or not any of you out there charged with implementing it consider it justifiable, let alone likely to achieve any workable benefits for Middle England.

    The FSA’s cost:benefit analysis of the RDR has been nothing but a hollow sham, not least because its benefits are unquantifiable and its costs are unknowable. Plus, of course, the FSA doesn’t give a hoot about the costs. The costs of implementation will be borne by the industry, as will be the additional costs of policing that implementation. So the FSA just bulldozes ahead, regardless of what anyone else might think. And, as with the issue of the directors’ overclaiming hugely on their expenses for overnight accommodation, no one holds it to account.

    Still, what do I know? Mine is just one small voice out here in the wilderness.

    One other thing. Despite Hector Sants’ claim that the FSA (fsa.gov.uk) is entirely independent of government and thus not driven by a political agenda, all the evidence points strongly to this being patently untrue. As a public sector body funded by the industry, the levies extorted from those of us forced to pay for it constitute effectively an additional tax burden, made all the worse by the FSA’s chronic profligacy and inability to manage its own finances competently and responsibly. How can it possibly be acceptable for the FSA to have been £14m overdrawn last year with two of the very banks it is supposed to have been regulating but which it did not, due to having been instructed by the Treasury to look the other way? And this year we learn the FSA’s budget is to increase by a staggering 18.3%!

    How much worse can it be allowed to get? The FSA is not merely a thoroughly discredited and disreputable instituion. It’s a national scandal.

  28. Des Wigglesworth 26th April 2010 at 10:49 pm

    Julian Stevens presses lots of buttons but in
    1 Sept 2003 the late Sheila McKechnie was
    onBBC Moneybox and was incensed over
    the Equitable Life situation and called for
    the disbandment of the then FSA

    2 Howard Davies ex BOE Nat West
    Calum Mc Carthy ex Barclays
    Hector Sants ex HSBC
    Are we really surprised of the conflict of
    interest and bias towards the banks

    3 Equitable life claimed not to pay
    commission and there was none
    in the trading section of their a/cs but
    in the P & L section thousands in
    salaries and bonuses

    4 banks fin serv employees are paid
    salaries not fees or commission
    but the banks collect commission
    from the providers …so much for
    transparency .. not so for IFAs

    5 The only people qualified to check on
    the banks are qualified accountants
    as the Nthn Rock FSA checkers
    proved

    6 On High Street bank check on their
    liquidity Ratios each year

    On Merchant banks AKA investment
    Banks ..monitor their credit position
    and where they subvent loans they
    should produce a list of banks to
    whom loans have been subvented
    The Accountants (big 4 ) have
    associaates worldwide to check at
    the other banks that the loans are
    covered by assets at the other
    locations

    7 To check on the sale of products
    use check lists and so away with
    voluminous pages of gobbled gook
    that no one can understand.

    8 Any auditor refers to “third party
    evidence ” when checking on the
    validity of accounts.

    The FOS clearly shows that
    IFAs are NOT the problem

    9 I have no particular party bias
    they are all in it for what they can
    get out of for themselves
    and most come out of school
    boys debating experience not
    the real world.

    Well I;ve said enough
    But Tabulate to Communicate less of
    the long rambling sentences please.

  29. If the conservative party were to announce that the fsa would be forced to treat IFAs fairly, with all that would entail and restore their human rights (even though the fsa and present government deny they have breached our rights) I for one would vote for them tomorrow.

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