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Pete Matthew: Gabriel – archangel of misery


Three hours. Three hours I have spent wrestling with Gabriel, archangel of misery, bringer of despair, who demands pointless information just to keep someone in Canary Wharf in a job.

And… breathe.

I have just completed my six-monthly battle with the regulator’s godawful system for reporting regulatory information.  Once again I am left with one major question banging inside my head: why?

Why does the FCA need to know how many new clients I have taken on in the past six months? Why does it need to know the number of new cases of adviser charging paid for via a product provider as distinct from a platform?

I wonder what possible benefit some of this data can provide for the FCA. Long and short: clients are happy, I am getting paid. I see no problem here.

I understand the need to report complaints (I have received none) and to demonstrate the financial health of my business from the balance sheet and profit and loss (very healthy, thank you). But I am required to submit this information using a system with a user experience that feels like I am wallpapering my hallway from outside my front door. And through the letterbox.

Most of the digits are only half-visible once I have entered them in the correct fields. Four sections have to cross-validate each other but you have to save and close one before you can fill in another. Why can one field not automatically populate the corresponding one in the other section? 

And don’t get me started on the fact that the entire system works to the nearest whole number – except for one section which requires figures to two decimal places.

Who among us has not crossed their fingers when clicking the “Validate” button only to have their hopes dashed by the vicious red error messages at the top of the page?

I imagine I would be a little happier if I had any explanation as to what the regulator does with this information. I confess I have not looked to see if this is explained anywhere but I cannot understand why anyone would need to know the kind of information I have to submit in the new Section K.

The regulator must get better at explaining what it does with this information and how it benefits me and, more importantly, the general public. With costs rising each year,
I begrudge the time and mental effort a little more every time Gabriel and I square up for another scrap. There simply must be efficiencies to be gained from simplifying both the amount of data required and the system used for collecting it.

My only comfort is that mine is a smallish business, with five advisers and five staff, and we have honed our management information systems to make the job as easy as possible. I cannot imagine the systems and people that must be needed for the nationals or networks to report this stuff. The thought of doing their returns makes me go all shivery.

Come on, Mr FCA, make an effort to make the financial services world a little more pleasant for all involved. Retire Gabriel and replace him with a better system requiring less time and effort. Then I can get on with filling this advice gap I keep hearing about.

Pete Matthew is managing director of Jacksons Wealth Management



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There are 50 comments at the moment, we would love to hear your opinion too.

  1. Don’t be fooled by the FCA’s propergandaer that this Gabriel reporting is risk based assessment !!

    Its for one purpose and on purpose only, fees !!! (or tax if you will)

    They are allowed to set their own budgets, MAS, FSCS and levies by the information, and by being 6 monthly they are always sure the information is relevant and up to date !!

    I suppose in a way, its good farming by the FCA of the cash cow that is the financial services industry !! milk them dry morning, noon and night, as long as the grass continues to grow and we keep eating it, our udders will be full for the walk to the milking parlour !! or whenever they run short of cash, for a few nights in a cosy hotel. pay for lawyers costs (Clifford Chance), new bit of art work, Oh and not forgetting those “delayed” bonuses !!

  2. …totally agree…

    My last RMAR “issue” – £1 rounding so it would not cross validate. Indeed I once got a call on holiday from FSA about an important discrepancy on my RMAR – a hasty visit to a cyber café revealed it was another £1 rounding.

    Talk about sledgehammer and nuts…trouble is they’re my nuts!

  3. @ Simon

    That £1 is very important !! what if all IFA’s made a -£1 error (well not error, rounding) ? that’s circa £26,000 short across the board !!

    All the more important now’ as if the same was 2/3 years ago they could be looking at £48,000 shortfall

    Round about the figure of some-one’s bonus !!

    Hope you are walking better now by the way ?

  4. one cannot but notice the harsh comments made by IFAs towards the FCA as someone who has suffered at the hands of an Authorised IFA and whose pension fund is now half of what it might have been due to the mis selling of UCIS productsI refer to EEA Life Settlements and Axiom Legal Financing I find the attitude somewhat cavalier.I have recently undergone a double triple heart bypass and instead of having a peaceful and stress free recovery i am having to to deal with the FSCS and the FCA in connection with the mis selling by your members.I would point out that the company who sold the products has recently gone into administration leaving the FSCS to pick up the pieces,but don’t worry before entering Adminisration the two Directors paid themselvesin excess of £200000 and then moved on .I would point out that both Directors are available for investment advise indeed one is still authorised by the FCA.Therefore before attacking the FCA give a thought for the people like me who have suffered losses due to mis selling at least the FCA offers some form of comfort against what appears to be acowboy industry

  5. @ Peter Barnett

    I happen to totally agree with you and you have my full support ! and may your recovery from surgery be swift.

    However UCIS are what they are “unregulated” and I feel, like a lot of other IFA’s that the regulator, be it the FSA or now FCA have done nothing to prevent the wrong people being “advised” (if that’s the right word) to invest in these. I take it you are not a sophisticated investor (not wishing to dumb you down) so you were not perhaps fully aware of the very real danger of these investments and more seduced by the headline growth you thought may get or told you may get.

    warning !! unregulated products and / or advice, is; unregulated and termed for a reason, approach with extreme caution !!

    We need good, common sense regulation, who promote both, regulated advice from regulated advisers, what we have at the moment is a regulator who is constantly behind the gain line, who is more interested in money raising for themselves and the treasury and fill their days with dreaming up new box ticking exercises for the industry to do.

    The regulator needs to lead by example, with good parenting and I’m sorry but with the current and previous we get neither, so the result is you will get some petulant brats (or cowboys as your refer) to look after, and the good will always have to clean up after them.

  6. @ Peter Barnett

    Your story is I agree very disappointing but please do not “tar” all advisers with the same brush. By far the majority are honest people doing an excellent job for their clients and not selling their clients inappropriate investment products.

    The FSCS may well be the organisation that deals with your claim but you need to be aware it is paid for by the very independent financial advisers who you criticise in your post. It is not the polluter who pays I am afraid

    Pete Matthews article seeks to point out that despite all the data that is requested by the FCA via the Gabriel returns consumers like you are still not fully protected from the unscrupulous adviser (again please note they are very much in the minority) Professional advisers are right to criticise excessive data capture when that exercise does little to enhance consumer protection.

  7. I can’t disagree with the comments and feelings expressed here, but frankly if your back office system/ accounting software cannot produce GABRIEL figures at the click of a button then you need to look elsewhere for a new system! Try for a pre-launch view of just such a system.

  8. This is a very sad story indeed. I have every sympathy with Peter Barnett and sincerely wish him a speedy recovery and a much happier retirement once the compensatory issues have been successfully resolved.

    As a “one man band” with a wife and children to support, I am acutely aware that my actions may endanger my livelihood, so I endeavour to undertake each task with all of my clients’ best interests uppermost in my mind.

    I have spent over 24 years in this industry, yet I still feel after all this time, that I am continuing to pay for the many misdemeanours that have gone on before.

    One point I would like to make regarding Pete Matthew’s excellent article is that the larger organisations, to which Peter Barnett refers, are able to delegate Gabriel reporting to a member of staff without it having much of an impact on the productive side of that business. I often have to spend much of the working week deciphering exactly which information this senseless system is requiring of me, and for what? The time cost is considerable. Time which I should be spending looking after my clients.

    My PI premium is up 35% this year and my FOS & FSCS levy is up a staggering 125%.

    Believe me when I say that honest, hard-working IFAs up and down the country should be included in the “victims” pile. I’m still here because I genuinely want to make a difference.

  9. Ken our does sort of – but not brilliant – what do you recommend?

  10. @ken Hayden
    That’s all well and good Ken, if they stuck to the same data items and didn’t keeping changing them on a whim. God knows how many man hours I have spent trying to structure our MI data to fit Gabriel, but every time I think I’ve cracked it, what happens, yes they change the data required and we are back to square one.
    Ken if your systems are so perfect, why don’t you give up regulated advice and sell your system to the rest of us, we would all pay a small fortune for this.
    But can I give you one word of advice, do not believe everything that your back office system spits out, I suggest you check it against the actual raw data in your NBR and recurring income register and you maybe surprised at what you find. If this is the case you may need some amendments to your previous returns – just a thought.

  11. Firstly many thanks for the kind words re my health,I do sympathise with some of the comments made however it doesn’t detract from the fact that one cannot help but notice the recurring incidents of financial mis selling and other financial misdemeanour s within your industry.Why is this?has it anything to do with the financial rewards that seem to be available?I do appreciate that the majority of IFAs are genuine and honest but why does there appear to be this recurring theme of moral and financial dis honesty?

  12. @ Peter

    Unfortunately this is a fact of life, and in all types of business be it, builder, plumber, IFA, mechanic, shop owner I could go on and on, however its one of the regulators main objectives to ensure fair and honest practice in the financial services sector again a driver for RDR, they do talk a lot about this but do very little by way of prevention, horse and stable door if you will.

    Its not fair for you as a honest investor and its not fair for us honest advisers, you will have to fight to get your money returned (which you probably will) and we will have to pay for it !!

    What’s the saying ? “wise after the event” but the regulators should be doing a hell of a lot more to prevent this !! not just rocking up after the event and saying all the right things in all the right places and passing themselves off as some kind of peoples champion

  13. @Peter Barnett

    Sadly there are rogues in every walk of life and in every profession: politicians, journalists, police, used car salesmen etc . none are immune. I really don’t think financial services is in any way unique or that it attracts more than its fair share of crooks.

    As a 30 year practitioner I see two issues. The existence of a regulator and compensation scheme seems to lull people into a false sense of security. People expect that because financial services is regulated they will always be protected. But all the UK’s various regulators have been conspicuous failures NB we only have FCA now because the FSA screwed up monumentally. But they still knighted its outgoing CEO Hector Sants who lasted less than a year in the private sector environment he created – before existing due to “stress”.

    As one example I personally wrote to the FSA about PPI 12 years ago and was told to mind my own business. Further as many now find just because a compensation scheme exists it does not follow that all investors will automatically be compensated.

    But there is another issue and I would submit, a rather more important one. Common sense and caveat emptor seem to have disappeared from the market – possibly because people rely too heavily on the aforementioned regulator and compensation scheme and possibly because they are, dare I say it, incredibly naïve. If anyone asked me to invest a significant sum and I knew nothing about such things I would first ask how I get my money out, how secure is my capital, in what circumstances could it fluctuate in value, how am I protected if this goes wrong and do I have full recourse to a govt. backed compensation scheme. I would get the answers in writing and I would check them. I would also want to know how long the investment had been in existence and what its track was over several years etc etc.

    We run a very compliant advisory firm here but I am constantly amazed at how readily clients part with money. I know what we are doing is honest, eligible for FSCS protection and has a decent track record, but I am rarely asked to prove it…

    Lastly your point about financial rewards. Last time I looked the average financial adviser’s remuneration was around £60,000 per annum, which for a qualified professional is not a huge income when compared to the other professions.

  14. @Dave Cathcart

    Funny you should say that! We are just about to launch the software! The link got cut by the moderator!
    Your points are well made, particularly the last paragraph but we are confident that our figures are very accurate.
    As for the FCA changing things, we just amend our code and everything works OK. The core issue here is the basic information that systems need to store. Contact me if you want more info!


  15. Contractually anon 27th August 2014 at 2:52 pm

    I hate Gabriel as much as the next man and shudder at the memory of filling this in… though a small voice in my brain is squeaking ‘How much would it cost to replace’. It’s difficult to see how Gabriel helps the FCA find the bad guys, but given the dishonesty (in some quarters) I can’t think of a better way of finding them. There have been various calls for better/more detailed regulation but the industry moves fast to side step the rules so principles based/outcome based would seem appropriate though it does mean accepting that dome ne’er do wells will only be identified after the event and having in place the systems to look after those that have been mistreated.

    @Simon Webster. Despite the many failures in many quarters on PPI (including regulator led), can’t blame the FSA for not touching it 12 years ago… they started regulating it in 2005.

  16. @contractually anon
    I did write to the FSA – it must have been 10! Never was any good at history!

  17. @Dave Cathcart
    The figures for the GABRIEL report will match those from the NBR and Commission Statements and Fees Invoiced/Banked
    for one simple reason: that’s where the figures actually come from!

    An integrated system, especially tailored for IFAs with Commission Statements etc. and designed with RDR in mind, allows you to do this with accuracy and consistency because, as @Ken Hayden says, as long as you have the basic info available, you can report it however you want.
    You can produce a ‘live’ GABRIEL report if you so wish.

    If the FCA changes the report format, we simply change the GABRIEL template we have (think Word template with Fields);
    If the FCA changes the rounding requirements or adds/removes fields, we change the code to match too;
    If they come up with some future dotty requirement involving non-calculable data, then we have the facility to store any type of data against any item in the system – we will use that and still automate the GABRIEL report.
    And I guarantee that we can release updates even faster than they can think of changes!

  18. Interesting posts there seems to more concern about whether it was 10 or 12 years rather than the fact that you have rogue IFA’s selling products that can if sold incorrectly ruin someones retirement plans and indeed bring financial disaster to a family at a time when they least need it. A somewhat more serious outcome than buying a dodgy 2nd hand car or dealing with a rogue plumber as mentioned previously .Perhaps these recurring incidents of rogue IFA,s ripping are acceptable and as previously stated part of life.I would have thought there would of been more support for getting rid of these people and tightening up the requirements to practice and more stringent exams on the same lines as Chartered Accountancy or solicitors exams.One is acutely aware of buyer beware,however but it does appear that some sophisticated investors are also duped surely there is some element of trust involved when dealing with an IFA.I would point out that my ex IFAs blamed me for the allowing them to buy the investments in the first place.Funny old world

  19. @Peter Barnett no one is suggesting that this is not a problem.

    I think you can ask us to try and solve the problem of the “rogue IFAs” that is perfectly reasonable and many will certainly report poor behaviour to the regulators but a more important question is why after 26 years of regulation we still have this problem?

    I suspect it is because (as this thread demonstrated) it is about form over substance. The massive FCA demand for data does nothing to protect you and others from the “rogue adviser” The IFA community is not a self regulatory world. You perhaps should be addressing your concerns to the regulatory authorities because the commentators on this forum I am confident would not treat their clients as you have been treated

    Seriously your “IFA” blamed you for allowing them to buy the investments?!!

    You could do us all a favour and name and shame them

  20. @Peter B – I would be interested to know who this adviser was too.

  21. I have forwarded a large number of documents to the FCA hopefully they will read them and act accordingly.If anyone is interested I can post the code to the Administrators report which is in the public domain.The report makes interesting reading but what happened a couple of days before the Administration and just after is even more interesting .The Administrator reckons that the potential liability for the mis selling is possibly £8000000 +interest yes I did say £8MILLION Does anyone want to read the Report I’m assuming the FSCS will pick up the tab I would point out that the figure quoted is the Administrators not mine

  22. @Peter Barnett

    The FSCS may well administer the payment of compensation- if so advisers (as ever) will pick up the tab!

  23. Just a point of clarification I should point out it was not a large firm it had 2 employees who were both directors and held all shares between them,

  24. @ Peter – as others have said, much regret at your loss. In relation to your feeling about such advisers, you’re pushing the stone downhill with the overwhelming majority of us – especially as it’s the rest of us who end up picking up the tab. Bit like most motorists regard the “crash for cash” merchants!

    The issue is more around how the provision of such minutae helps prevent the problem. If firms were confident that it did, the pain would be more bearable. Unfortunately it’s difficult to see the connection, and the regulator is perhaps less than forthcoming in educating us…..they may have their reasons, but some sort of explanation would help (even if it were of the “we’d love to tell you, but then we’d have to shoot you” kind!)

  25. @Peter Yes, interested to see the docs in public domain. Which County was this firm in as a matter of interest?

  26. For me, the answer is quite simple. If the FCA is serious about Treating Customers Fairly, then it must look to the larger organisations and especially those which have shareholders and are publicly listed. These companies are there first and foremost to make a profit. Without profits, the shareholders don’t get a dividend and the directors don’t get a bonus.

    With this is mind, is the TCF framework compatible with such a set-up? Should it not be the interests of customers which are served first and not those of the shareholders and directors?

    Profit making organisations usually have in place some kind of target-driven productivity model, and therein lies much of the problem.

  27. the company was and still is based in surrey in the same offices with the same telephone numbers,its a long story which i have managed to work out what actions the directors took before and after the appointmen t of the Administrator to access their report go to Code kb78yu74dk the name of the companu is Key Benefits Ltd based in Carshalton surrey any observations would be appreciated

  28. the Administrators Initial report can be found at Access Code kb78yu74dk The company name is Key Benefits ltd based in Carshalton all comments greatly appreciated

  29. @ Peter Barnett

    The administrators report makes for very distressing reading (for you the other creditors and IFAs who are going to have to fund the compensation payments)

    I imagine you are pretty miffed with the statement on their website that;

    XXXX is delighted to announce it has merged with XXXXX The merger will enable us to continue providing our small company brand of personal hands-on independent financial advice and management services, but with the backing, resources and security of a major and growing force in financial services.

    So they provide unsuitable advice to 92 UCIS clients and then dump their liabilities on the rest of us. And the FCA does what exactly?

  30. At last somebody,s understands what has gone on I was impressed with reduction in the bank just before the administration but everythings alright because they weren,t awareof the rules relating to the sale of UCIS.

  31. At last someone appreciates what,s gone on but everythings alright because they weren’t aware of the rules relating to sale of UCIS ignorance of the rules would appear to the Adminisrator to be an excuse for ripping people off


  33. How is it right that these people are allowed to continue as authorised individuals? If the FCA started striking people off, surely less people would end up complaining and then our annual FOS & FSCS levies would start to decrease. Does the person dealing with the complaint at the FSCS not flag this up to a senior official so that the appropriate measures can be put in place? Is the new company to which these b@st@rds are transferring completely oblivious to what has gone on before? Not great for their image, so I’m guessing the information has been withheld. I’m angry. Very angry.

  34. I think is good that Peter Barnett has put his point across from (lets say) a clients perspective ! and having read the administrators report I have to agree with Nick Bamford above.

    But Peter do you not see how and why we get so angry at the regulator past and present (re read your first post ) how the hell (with all the information and resource available) do they let things like this happen and I mean the morphing aspect and dumping their liabilities on us ? I’m with Russell; angry very angry as you obviously are !

  35. Just for your information the day before the directors put the company into Administration I received an envelope containing a letter from xxxxxx ad vising me of the merger with yyyyyyy and how the change over would be seamless and how they were looking forward to reviewing our portfolios and what a bright future it would be.Also in the same envelope was a letter from xxxx on their headed note paper “we are delighted that xxxx and xxxofxxx have decided to join forces with xxx.we are confident many complementary benefits will attach to both our firms and xxxxclients alike”

  36. “Enclosed you will find a document for your signature and return comprising you request and authority to transfer the servicing of your account to xxxxx,the umbrella organisation of which xxx is a part.when we have received and processed this xxxand xxx will be able to continue servicing your account and requirements,introducing-and incorporating as appropriate-access to all the bene fits their joining us will bring to to you”Extracts from the merging companys letter.The following day the Directors placed the company into Administration having dumped their liabilities with the FSCS and made a future for themselves due toa “merger” are you telling me the other firm was not aware of the plan? more later

  37. @Peter Barnett there is no getting away from the fact that the stress you have had and are continuing to experience from this is awful (and totally unacceptable) practice is at least likely to witness a positive outcome for you (albeit no time soon) from the FSCS.

    For the rest of us (the professional IFAs who post here) there are two negative consequences;

    We will have to pay more to the FSCS to fund your (and the other 91 consumers) compensation payments.

    Reputational damage will apply to the intermediary sector.

    The whole point of Pete Matthew’s original article (and I have apologised to him for this being hi-jacked!) was to challenge the data that the FCA was asking for in the twice yearly returns, none of which appears in any way to protect you from what you have experienced.

    We have had 26 years of steadily more intensive financial regulation and still the consumer is being ripped off. If your story is not an example of abject regulatory failure I am not sure what is

  38. Surely Independent status as an FCA-approved adviser should be adjusted to ‘being authorised to advise in all areas of REGULATED products and services’. Leave unregulated products where they should rightly be, in the domain of unregulated salespeople (if they are allowed to come into the retail market at all) or for DIY investors who understand the risks and fancy a ‘punt’.

    Until such distinctions are made and clearly understood by all, the public will always be at risk.

    Would I miss not having these products available to me and my clients? Not at all. Would I benefit financially from not having these products available to me and my clients? Well yes, as my FSCS Levy would be quite a bit lower!

  39. Hi Peter. It’s pure supposition on my part, but if you were Managing Director of the company receiving these individuals, would you want them and their baggage dragging your good name (if it is a good name) through the mud? I’m struggling to rationalise the grounds upon which I would want to employ them if I was fully aware of the history.

  40. I did speak to their compliance Director and expressed my concerns however he didn’t seem too concerned about the arrangement he did say that they would not accept me as a client which has somewhat left me high and dry with my investments I have also spoken to the Administrator all to no avail it would appear to be a planned course of action with several parties being part of the scrip I would think the MD would be delighted to have them on board as he has increased his client base at no cost isnt there something called treating the customer fairly funny old world financial services

  41. @Russell @4.47

    Surely every financial adviser is “in it to make a profit” – I know I am.

    My business makes an excellent profit by always putting client interests first. As a result 85% of our business comes from existing clients and referrals. It is pretty much the same for most professional IFA businesses and I suspect those posting here. The banks’ could and should have cleaned up in this space but the complete failure of their management to get to grips with selling advice rather than product did them in at just about every level. This was really nothing to do with profit per se but everything to do with not having had the moral fortitude to do the job properly. Had they done it right they would have made reasonable money and kept it (and the trust of their clients) rather than have to pay it all out again in compensation.

  42. @Peter Barnett -Thanks for that.
    @Nick Bamford- Note that the potential claims immediately caused capital adequacy problems and any firm who then did not resolve with the FSA immediately would be in breach which shows a flaw in the FSCS handling of Keydata as their claim immediately put all firms in breach, which meant either settle or cease trading.

  43. I think SteveDs suggestion above is a potential solution. That way the onus is on the adviser to ensure the consumer knows there is NO regulated protection on unregulated products and if he cannot prove it, it is one strike and you are out of FCA regulation and possibly of being a director of a Ltd Co.
    This has no relevance the Peter B’s adviser, nor I am afraid to the original article other than to reinforce how useless Gabriel is to consumer and adviser needs!

  44. Forgive me for generalising, but as far as I see it, the Financial Conduct Authority has 2 main functions, namely:
    a) Protect consumers
    b) Ensure authorised entities are fit and proper (act with integrity)

    It is clear from this thread that the FCA has failed and continues to fail on both counts. Instead of treating the symptoms (FSCS & FOS), it would be far more cost-effective for them to eliminate the causes.

    The most excellent original article by Pete Matthew (sorry for hijacking it Pete) depicts very appropriately the painful experience of completing a half yearly GABRIEL submission for no discernible reason.

    @Simon. Yes, I agree. I was trying to get across the point that there was (at the time Peter Barnett’s investments were set up) a conflict between TCF and how these people were remunerated. All my business comes from referrals and satisfied existing clients. I won’t get rich doing this, but GABRIEL aside, I’m happy.

  45. Gentlemen thank you for all your kind comments i was beginning to think that what has happened to me was very much the norm within your industry obviously you are all very angry with these Authorized IFA’s but it would appear that whilst you are aware of their misdemeanors there is nothing you can do to bring them to book.Don’t you have lines of communication with the FCA where you can advise them of these people I have sent the FCA documentation relating to the events whether they will bother to look at it is a suspect pot luck..They do have a copy of the Administrators Report which hopefully they will read and arrive at the same conclusions as some of you have.However it does look as if they will probably get away with which is somewhat galling and does the integrity and image of your business no favours at all

  46. Could the mis -selling of UCIS be the next big financial scandal as i suspect I’m only the tip of the iceburg.

  47. I would be interested to see how they calculated the trail to be worth £40,000. On a turnover of circa £500,000, this seems a little low.

    Old Directors get a new lease of life, the new firm get a nice cheap tranche of trail and the clients get their money back from the FSCS.

    Everyones a winner, apart from the rest of the industry that foots the bill of course. This has got to stop.

  48. what about the reduction in the bank account a month before Administration it was a very large payment made to the Directors confirmed by the Administrator to be salaries

  49. Spoke to the FCA today about my little problem very sympathetic hopefully they will take matters further they were very interested in the acquiring company, good point about the valuation of the trail income,very odd given it was a merger and not an acquisition they did seem to think that the FSCS would pay out at some stage.I do believe that not always clear cut summed up the position in their post i would ask that all you other IFA s read the Administrators Report at least you will be able see where your hard earned money paid to FSCS is going, legislation without representation springs to mind

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