FCA announces more details of new credit thematic reviews

In most cases the Financial Conduct Authority (FCA) only releases significant details of its thematic reviews once it has completed them. However, the regulator has already issued details of how it will conduct its two new studies into the consumer credit market. These reviews will focus on remuneration schemes and arrears management.

The remuneration review will assess a wide range of firms, including debt management firms, lenders and brokers. Some firms for whom credit is a secondary activity can also expect to be included.

The FCA’s previous supervisory work has indicated that there is reason to be concerned that some credit firms are operating ‘high risk’ remuneration and incentive schemes. The four areas of concern the FCA mentions are:

• Firms not considering the risks their incentive scheme could pose
• Where risks have been considered, the measures taken to mitigate the risks are insufficient or ineffective
• Schemes being so complex management and staff could not understand them
• Managers receiving bonuses dependent on the sales volumes generated by staff they supervise

The FCA has already requested information on the incentive schemes operated by the firms selected to participate in the review. It will analyse this information during the remainder of 2015. Then in the latter part of the year, and in early 2016, it will visit firms to seek further evidence regarding how their incentive schemes operate. The final report will be published before the end of the second quarter of 2016.

The arrears review will focus on management of ‘early arrears’ – how firms treat their customers when they first show signs of financial difficulty. Only firms that offer unsecured lending products, including personal loans, credit cards and retail finance, will be included in the review. The FCA aims to discover whether firms are exercising forbearance appropriately, whether they are complying with the detailed Handbook rules on arrears management and whether they are treating customers fairly in general.

This month (August 2015), the FCA is collecting information regarding firms’ arrears management policies, and it will analyse this information during the remainder of 2015. Also before the end of the year, it will review a selection of customer files from participating firms, to gather evidence on how arrears management is working in practice. The third stage will take place in the first quarter of 2016, when the participating firms will be visited by the FCA. Again, the final report will be published before the end of the second quarter.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Consumer group survey reveals bank sales staff still under pressure to deliver

A survey by consumer group Which? has revealed that a significant proportion of bank sales staff still feel under pressure to achieve high sales volumes. Promotion of a ‘hard-sell’ culture by firms, remuneration systems that reward sales over good customer service and fears amongst staff of disciplinary action if they fail to meet their targets have all contributed to the banks’ widespread mis-selling of payment protection insurance, interest rate hedging products, investments, mortgages, packaged accounts and card protection insurance.

Which? contacted 383 staff from the five largest UK banking groups: Barclays, HSBC, Lloyds Banking Group, Royal Bank of Scotland, and Santander. The survey shows that 27% of bank staff feel under pressure as a result of a perceived sales culture within their firm. However, this is down from the 43% who felt this way when Which? carried out the survey back in 2012.

28% said they still feel under pressure to effect a sale even if it is not in the customer’s interests. This figure was 45% in 2012.

A more positive sign is that 78% believed their bank was now showing a greater commitment to customer service than was the case previously. 46% say the incentives offered by their employer for achieving high sales volumes have reduced in the past year.

The Daily Telegraph’s report on the survey is accompanied by a survey of its readers, asking whether they have noticed that banks are less keen to sell products to their customers. As of August 24 2015, 63% believe the banks ‘sell products just as hard as ever’.

So the findings indicate that some activities being carried out by banks today could give rise to compensation for mis-selling needing to be paid in the future.

Which? executive director Richard Lloyd commented on the survey results by saying:

“I’ve spoken to the chief executives of all the major banks, and at the top there has clearly been a recognition that it is bad for business to allow the kind of behaviour that has been so systemic in the past to continue.

“But that does not transform the organisation overnight. It is quite easy for middle managers or those further down the bank to simply rebrand sales targets and keep the pressure on staff up, which could result in mis-selling in other ways.”

He also commented that he was troubled by suggestions that regulatory chief Martin Wheatley had been removed from his post at the Financial Conduct Authority (FCA) because he was too tough on the banks for the Government’s liking.

Mr Lloyd added:

“It is a worrying position at the moment, there is still a long way to go and if the FCA takes the pressure off, we could quite easily see the situation slide back to what we found in 2012.

“We are realistic about the ability to stamp out mis-selling completely – there will never be a day when a middle manager will not put anyone under pressure to sell – but we need to see more changes to keep the culture improving and more pressure from the regulator to keep up the work they have already been doing.”

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Co-op Bank makes additional provision for mis-selling of PBAs and other conduct issues

The Co-operative Bank has announced that it has allocated a further £49 million to cover conduct and mis-selling issues. The sum is to cover compensation payments for mis-sold packaged bank accounts (PBAs), for mis-calculated mortgage interest payments and for interest refunds on unsecured loans that did not comply with the Consumer Credit Act. A specific sum of £16.8 million has been allocated for PBA compensation.

Co-operative Bank’s provision for mis-sold payment protection insurance (PPI) stands at £347 million.

So it can be seen that the so-called ‘ethical bank’ has not been immune from mis-treating its customers in the past.

Nor does it seem especially keen to pay redress where it is due. The latest figures from independent complaints adjudicator the Financial Ombudsman Service (FOS) for the first six months of 2015 show that 57% of all complaints it received about the bank were upheld, and 76% of the PPI complaints were resolved in the customer’s favour. The FOS only gets involved once the firm has issued its response to the complaint, so this means that the bank is unfairly rejecting a large proportion of its complaints. The Co-operative was also fined £113.3 million in 2013 for delays in paying PPI compensation.

The bank has announced a pre-tax loss of £204.2 million for the first half of 2015, up from a loss of £77 million for the equivalent period in 2014. It does not now expect to make a profit until 2017, and has shelved plans for a stock market listing as a result. Instead, the possibility of a merger with another challenger bank has been mooted.

Chief executive Niall Booker said:

“Of course, we have always said that addressing legacy issues will continue to dominate financial performance for some time and there is considerable work ahead towards a full recovery.”

Co-operative Bank was bailed out in 2013 as a result of losses on commercial real estate lending, since when 80% of the bank has been owned by bondholders and hedge funds. The long-time owner, Co-operative Group, now only holds a 20% stake.

Earlier in August 2014, the regulators, the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA), publicly censured the bank for breaching listing rules, and for failing to be open in their dealings with the FCA. The FCA/PRA reported that the Co-operative made misleading statements regarding its capital resources; failed to notify it of two new senior appointments and the reasons for the change in personnel; and had a flawed risk management model. Regarding the senior staff changes, in one instance the FCA was not informed of the appointment until after the individual had left the bank.

Had it not been for the bank’s financial difficulties, it would have received ‘a substantial financial penalty.’

The FCA says it is continuing to investigate the conduct of senior officials at the bank.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Payday lender fined by ICO over security failings

Payday lender The Money Shop has been fined £180,000 by data protection watchdog the Information Commissioner’s Office (ICO) after the loss of two computer servers, each containing a great deal of customers’ personal information.

The firm first had a server stolen from its branch in Lurgan, Northern Ireland in April 2014. The second incident occurred in May 2014 when a courier firm lost a further server in Swindon. In neither case was there sufficiently rigorous encryption of the data in place. At Lurgan, the server was not stored in a locked room, separate from all the other servers, in spite of this being company policy. Unencrypted servers were also transported between Head Office and The Money Shop’s branches on a regular basis.

In each case the personal data of several thousand customers, and some of the firm’s employees, went missing. The two servers have still not been recovered, as of mid August 2015.

The Money Shop is entitled to appeal against the fine to the First-Tier Tribunal (Information Rights), but has not indicated whether it will do so.

The ICO’s Head of Enforcement, Steve Eckersley said:

“Customers of The Money Shop entrusted the company with their personal and financial details with the expectation that the information would be kept safely and securely. Our investigations discovered that this wasn’t the case and that this information was regularly left exposed when equipment was moved around the country. There was potential for fraud and financial loss to customers which is unacceptable and in both cases, had the data been properly encrypted the damage and distress to customers and the monetary penalty could have been avoided.

“Hopefully it’s an example to other organisations, whatever business they may be in, that the safety of personal information must be taken seriously. Policies and procedures must be put in place or we will take action.”

In a statement, The Money Shop’s parent firm Dollar UK said:

“Dollar UK reiterates its apologies to any customers who have been affected by these incidents.

“Since these events took place, Dollar UK has come under new ownership and management, implementing a complete review of IT and systems security including the replacement of those responsible for managing this essential element of business infrastructure and consumer confidence.”

The incidents serve as a warning to firms in all business sectors of the importance of having the very best IT security arrangements in place.

Measures a firm can take in this area include:

• Installing a firewall and virus checking software
• Ensuring staff only have access to the information required to perform their role
• Taking back-ups of information on a regular basis and keeping these in a separate place
• Not disposing of old computers until all the personal data on them has been securely removed
• Installing anti-spyware
• Instructing staff to use ‘strong’ passwords – passwords that have a combination of upper and lower case letters, numbers and other keyboard symbols
• Installing spam filtering software
• Ensuring staff are trained not to respond to emails or other communications asking for information such as PINs and passwords

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Credit application refused by FCA over multiple competence issues

On August 5 2015, the Financial Conduct Authority (FCA) announced that it had refused an application made by Belfast-based M8 Rates Loans Limited to act as a consumer credit lender. The FCA had previously issued a Warning Notice expressing its concerns about the application, and inviting the firm to make representations. When no representations were received, it published a Final Notice regarding the refusal of the application. The deadline for appealing the FCA’s judgement to the Upper Tribunal has also passed.

M8 had held interim permission from the FCA from April 1 2014. The application for full permission has been refused due to issues regarding the documentation supplied with the firm’s application, and concerns over the competence of its sole director, Neil Green.

Issues the FCA has with M8’s application include:

• The example credit agreement provided did not contain all the information required under the Consumer Credit (Agreements) Regulations 2010
• No procedure for dealing with customers in arrears was provided
• No clear indication of how vulnerable customers would be identified was provided
• No application was made for any individual to carry out the post of Money Laundering Reporting Officer. This role is a requirement for all authorised firms
• Mr Green has no previous financial services experience, and other than conducting reading and research in his own time, has not committed to any formal training
• The application indicates that the firm has failed to understand the meaning of ‘approved persons’, confusing this term with potential customers
• The application incorrectly stated that the firm intended to engage an appointed representative, indicating that it had misunderstood the meaning of this term
• Examples of promotional material stated that the firm was authorised by both the FCA and Office of Fair Trading (OFT), did not contain a representative APR and only described the benefits of the relevant products and not the risks and downsides. The OFT in fact ceased to exist in April 2014, so it is not possible to be authorised by both bodies

Firms still preparing their consumer credit applications should take note of the reasons why this application was refused, and ensure that their applications fully address all of these issues.

According to FCA figures summarising the authorisations process, up until March 31 2015 only 18 firms saw their applications refused. 775 firms initially made an application but then withdrew it. However, over 90% of applicant firms applying within each authorisation period ended up becoming authorised.

All consumer credit firms who are yet to submit their authorisation application need to make sure they know when their allocated application period is. They also need to ensure that they are totally clear as to whether they can apply for limited permission, or whether full permission will be required. An important consideration here is to carefully study the specific criteria lenders and brokers must meet in order to qualify for limited permission.

Then firms need to ensure they start preparing the required financial and non-financial information well in advance of the time they need to apply.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Clydesdale expects hike in PPI and interest rate hedging compensation reserve

National Australia Bank has announced that it may need to set aside up to £500 million more to pay mis-selling claims at its UK subsidiary, Clydesdale Bank plc. Up to an additional £420 million may need to be set aside for payment protection insurance (PPI) claims, and up to £80 million more for mis-selling of interest rate hedging products (IRHPs).

The parent company says there are a “wide range of uncertain factors relevant to determining the total costs associated with conduct-related matters.”

Both the Clydesdale Bank and Yorkshire Bank brands are operated by the listed entity, Clydesdale Bank plc. Back in October 2014, the bank’s PPI compensation reserve was increased by £420 million and the IRHP provision by £250 million.

In total, the bank has set aside £806 million for PPI mis-selling to date, so the worst case scenario, based on the latest announcement, would take their total PPI reserve to more than £1.2 billion.

In April 2015, financial regulator the Financial Conduct Authority (FCA), fined Clydesdale Bank £20,768,300 for failings in its handling of PPI complaints. The FCA criticised the bank for:

• Not conducting any searches for relevant documentation where the associated loan or mortgage had been repaid more than seven years prior to the PPI complaint, even though it was aware that documentation may still be available
• Submitting false information to the Financial Ombudsman Service (FOS) regarding the documentation it supplied regarding these searches
• Failing to provide adequate training to complaint handlers – many employees were unaware of all the issues to consider when reviewing a PPI complaint

PPI has been mis-sold on a massive scale over a number of years. Large numbers of complaints are still being made by consumers who allege that the insurance was unsuitable, that they were incorrectly informed it was compulsory or that the insurance was added to their loan without their knowledge or consent. The FOS is also reporting increasing numbers of complaints from consumers who believe that their provider has offered insufficient compensation.

An FCA statement on PPI is expected to be made later in summer 2015. This is expected to include details of the latest findings regarding how firms are handling complaints, as well as giving the FCA’s reaction to a recent court ruling, which could lead to a new wave of PPI complaints being brought on the basis that the commission was not disclosed. According to press speculation, the statement also may or may not give details of a time limit on when a PPI complaint can be made.

IRHPs are designed to protect against rises in interest rates on business loans, however interest rates have been at a historic low for many years, meaning that the products have been of little value recently. Many businesses have been hit with significant fees and exit costs as a result, and many have said that they have experienced significant financial problems or even gone bust as a result.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Landmark court ruling could lead to new wave of PPI claims

The payment protection insurance (PPI) mis-selling saga appeared to be winding down, but firms that sold the insurance are now anxiously waiting to see if a new wave of claims lies ahead following a recent court ruling.

Banks and other providers have already allocated around £26 billion in redress for mis-sold PPI, but research agency Autonomous is now suggesting that a further £33.5 billion – as a worst case scenario – could be payable as a result of providers’ failure to disclose commission payments. Barclays, Lloyds and Royal Bank of Scotland have already warned their shareholders about the possible implications of the ruling.

In November 2014, the Supreme Court issued a ruling in the case of Plevin v Paragon Personal Finance Ltd to the effect that the commission payment on a PPI plan created an unfair relationship.

Susan Plevin took out a secured loan with Paragon in March 2006, via credit broker LLP Processing (UK) Ltd (now in liquidation), and also purchased a single premium PPI plan with Norwich Union. Of the £5,780 single premium, some £4,150 (72%) was taken up by commission payments. £1,870 was paid to LLP Processing and £2,280 to Paragon. £1,630 of Paragon’s commission was then remitted to Norwich Union.

She only learnt of the existence of the commission payment, and details of which parties had received the commission, when she commenced legal proceedings alleging that the PPI was mis-sold. On learning of the existence of the commission payment, Mrs Plevin then filed a new suit alleging that an unfair relationship between lender and borrower had been created.

The Court (with Lady Hale, Lord Clarke, Lord Sumption, Lord Carnwath and Lord Hodge giving judgement) ruled that the lender’s failure to disclose the existence of such a large commission payment had indeed created an unfair relationship under section 140A of the Consumer Credit Act 1974.

The industry is now anxiously awaiting a statement from the regulator, the Financial Conduct Authority (FCA), which has been considering the implications of the Plevin case. This statement is expected before the end of the summer, when the FCA also intends to publish its latest report into trends in PPI complaint handling. Media speculation in early August 2015 also suggests that the FCA will announce a time limit for making a PPI claim at the same time.

Common reasons for needing to pay PPI compensation on cases considered so far include:

• PPI policies not covering the full loan term
• Firms failing to take into account existing insurance and sickness benefits when assessing suitability of the cover
• Firms not notifying customers of key policy exclusions, such as pre-existing medical conditions
• Customers being told PPI was compulsory, or that it would improve their chances of being accepted for the loan
• Customers being sold PPI without their knowledge or consent
• PPI being sold to self-employed customers who were ineligible to claim under the unemployment section of the policy

The first two issues listed above were amongst the reasons why Mrs Plevin originally made her claim for mis-selling.

Complaints about PPI on the grounds of mis-selling are now falling after having peaked at 2,232,294 in the first six months of 2012. In the second half of 2014, the latest period for which the FCA has released figures, there were 1,058,918 PPI complaints, but this latest development raises the possibility of complaint numbers rising significantly once again.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


MoJ issues bulletin summarising actions taken against CMCs in last quarter

The Claims Management Regulator at the Ministry of Justice (MoJ) has published details of the enforcement action it took against claims management companies (CMCs) between April and June 2015.

One company had their licence suspended during the period, one had the conditions of their licence altered and 69 more were warned. 21 new investigations also commenced during the quarter.

The bulletin then summarises the actions the regulator has taken under three headings: financial services claims, nuisance calls and personal injury.

The MoJ continues to have particular concerns about the compliance standards being displayed by financial services CMCs, including those that handle payment protection insurance and packaged bank account (PBA) claims. 12 warnings were issued to companies operating in this area, and one, Money Made Simple (UK) Ltd, had conditions imposed on their licence. This company is now subject to a large number of additional requirements regarding use of clients’ Letters of Authority. Four more companies in the financial services arena remain under investigation.

The MoJ issued specific guidance on PBA claims during the period. Issues covered in this guidance include:

• The need to understand the rules that applied at the time of the sale
• Obligations to investigate the benefits available under the PBA, and whether these benefits would have been of use to the client
• The need to submit client-specific claims, rather than generic claim letters
• A requirement to consider previous judgements from the Financial Ombudsman Service when assessing whether claims have a reasonable chance of succeeding

10 warnings were issued regarding the sending of nuisance calls and texts. It was during this three month period – even though the fact has just been made public – that the MoJ imposed its first ever fine on a claims management practitioner. Aurangzeb Iqbal, who traded as The Hearing Clinic, amongst other trading names, was fined £220,000 after making millions of unsolicited marketing calls to consumers – some of whom were registered with the Telephone Preference Service – advertising his company’s hearing loss claims services.

Another CMC had their licence varied on July 2 2015, just after the end of the reporting period. EMC Advisory Services Ltd is now subject to a series of additional requirements regarding its marketing calls, including the need to train staff as to their obligations, and to keep records of calls made.

Nine more companies remain under investigation over their conduct regarding marketing communications.

The bulletin also reveals that the MoJ has identified six direct marketing companies who may be conducting claims management business without authorisation.

26 CMCs offering personal injury claims services were warned during the quarter, and as many as 15 companies were identified who may be operating in this area without authorisation. The MoJ continues to co-operate with the Insurance Fraud Bureau and the Insurance Fraud Enforcement Department of the City of London Police to tackle personal injury fraud.

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


Mortgage broker sentenced for fraud

A London-based mortgage broker has received a two year suspended jail sentence and been ordered to carry out 240 hours of community service for trying to evade corporation tax and for falsifying information on applications.

Asim Hussain, director of Lifestyle Mortgages, moved income payments from the firm’s accounts to other accounts, and in doing so managed to make the firm’s profits appear lower and thus avoid paying £115,000 in corporation tax. The sums gained as a result of the fraud were then used by Mr Hussain to make overpayments on his mortgage and to effect property and land investments.

He pleaded guilty at Southwark Crown Court to the tax evasion charges, and has also been found guilty of falsifying clients’ income and employment details on mortgage applications.

HM Revenue & Customs (HMRC) is now seeking to recover the unpaid tax.

The case was referred to the police by the former financial watchdog the Financial Services Authority (FSA) when it banned Mr Hussain from working in financial services back in 2008. The FSA was initially informed by a mortgage lender that it had concerns about the accuracy of information on applications he submitted.

Gary Forbes, assistant director of criminal investigation at HMRC, said:

“Hussain seemed to believe he could act above the law and that by simply moving money between bank accounts he would stay off HMRC’s radar. Instead, he has learned the hard way that crime does not pay – he now has a criminal record and his reputation and career are in tatters. What Hussain did was illegal and immoral – he used the money that should have gone back into funding some of the UK’s most vital public services to invest in his property and enjoy a lifestyle most honest taxpayers can only dream of.”

Detective Constable Philip Palmer of the Metropolitan Police said:

“This sentencing is the result of a coordinated approach by the MPS, HMRC and FCA and should send a strong message to the financial and banking community that mortgage fraud and tax cheating will not go unpunished. Every penny that Hussain evaded increased the tax burden on law-abiding citizens and deprived government [fusion_builder_container hundred_percent=”yes” overflow=”visible”][fusion_builder_row][fusion_builder_column type=”1_1″ background_position=”left top” background_color=”” border_size=”” border_color=”” border_style=”solid” spacing=”yes” background_image=”” background_repeat=”no-repeat” padding=”” margin_top=”0px” margin_bottom=”0px” class=”” id=”” animation_type=”” animation_speed=”0.3″ animation_direction=”left” hide_on_mobile=”no” center_content=”no” min_height=”none”][of] revenue.”

Georgina Philippou, acting director of enforcement and market oversight at the Financial Conduct Authority, said:

“This is a very serious offence and this sentencing demonstrates that any attempt to abuse the system will not be taken lightly. It is an excellent example of the authorities working together to tackle an individual who put lenders and consumers at risk.”

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.


FCA and Treasury launch review of whether financial advice is working in the interests of consumers

The Treasury and the Financial Conduct Authority (FCA) have jointly launched the Financial Advice Market Review. This will look at whether the financial advice market is working in the interests of consumers. According to the Treasury’s press release, it aims to “radically improve access to financial advice.” It will cover all product areas, including pensions, investments, insurance, mortgages and consumer credit.

A consultation will be conducted in autumn 2015, and the Review will be published ahead of the spring 2016 Budget.

The key elements of the review will include:

• Examining the apparent ‘advice gap’ that exists where some consumers wish to receive financial advice but have limited wealth
• The regulatory barriers and other restrictions advisory firms face
• The advantages and disadvantages of using new technologies when giving advice
• Encouraging demand for financial advice, and examining what puts people off receiving advice

It will also look at the relationship between the regulator and the Financial Ombudsman Service and the Financial Services Compensation Scheme.

The so-called ‘advice gap’ is one of the biggest issues in financial services today. Since the introduction of the Retail Distribution Review, all investment and pension advisers have had to be remunerated via fees, with commission payments banned. The need to stay profitable has led many advisers to turn away clients who do not enjoy a certain level of income and/or assets. High street banks and product providers, who have traditionally serviced the mass market, have in many cases ceased to offer advice. All efforts to date to introduce some form of simplified advice regime have failed. Nevertheless, the terms of reference of the Review promise to “facilitate the establishment of a broad based market for the provision of financial advice to all consumers.”

Tracey McDermott, who will shortly become Acting CEO of the FCA, will co-chair the review with Charles Roxburgh, Director General of Financial Services at HM Treasury. An advisory panel of up to 15 representatives of consumer groups, product providers and financial advisers will be headed by Nick Prettejohn, the Chairman of Scottish Widows Group.

Ms McDermott commented:

“Ensuring that people have the appropriate information and advice in order to make important financial decisions is a priority for the FCA. Changes in the rules around mortgages and the introduction of the new pension freedoms mean that more people than ever before are looking for or are in need of financial advice. The review is an opportunity to look at how the market is working right across the piece and has the potential to radically change the advice landscape to the benefit of both firms and consumers.”

The Economic Secretary to the Treasury, Harriett Baldwin MP, said:

“Making sure that our financial services sector supports working people at every stage of their lives is a key part of our long term plan. That’s why we’ve launched a major new review to explore what more can be done to make sure consumers can access high quality and affordable advice so they can make informed decisions with their hard-earned money.”

The information shown in this article was correct at the time of publication. Articles are not routinely reviewed and as such are not updated. Please be aware the facts, circumstances or legal position may change after publication of the article.

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