29Feb

FCA issues eight Final Notices for credit firms on the same day

Eight consumer credit firms were informed on the same day that they had lost their authorisation. On February 25 2016, the Financial Conduct Authority (FCA) issued Final Notices to the following firms:

• Simon Wright
• Parvin Oghabi Sadi
• Jonathan Milnes
• John Sanders
• Jawad Khan
• FJ Autos Limited
• AKV Vehicles Limited
• Alan Whittington

Seven of these firms have lost their authorisation for failing to submit the Consumer Credit Return. This must be submitted by all authorised consumer credit firms, other than those holding interim permission, and must be submitted via the FCA’s electronic system quarterly, six-monthly or annually, depending on the nature of the firm’s business and the size of the firm.

The Return contains eight sections, and firms must complete the sections that are relevant to them. As holders of limited permission, i.e. firms considered to pose a lower risk, it would have been sufficient for each of the seven firms to have only completed section 007, which asks for information on:

• Revenue from credit activities
• Total revenue from all activities
• Number of credit transactions
• Number of credit-related complaints
• What the firm’s main credit related activity was during the reporting period
• Total annual income

The FCA regards any failure to submit a regulatory return as a breach of Principle 11 – “A firm must deal with its regulators in an open and co-operative way, and must disclose to the FCA appropriately anything relating to the firm of which the FCA would reasonably expect notice.” Any firm who fails to submit a regulatory return, and continues to ignore the FCA’s requests to do so, should be in no doubt that the eventual outcome will be the loss of its authorisation.

The reasons why Birmingham-based FJ Autos has lost its permission are less clear. The firm was authorised by the FCA in April 2015 to conduct credit broking activities. Again, the FCA cites a breach on the part of the firm to comply with the Principle 11 obligation to co-operate with regulators; and also says that the firm “has failed to ensure its affairs are conducted in a sound and prudent manner.” The Notice goes on to say that the FCA has “significant concerns” about how it has been conducting its business, and that the firm has failed to respond to requests from the regulator to discuss the matter.

Consumer credit firms must comply with the FCA’s 11 Principles for Business, and with all relevant sections of the rulebook such as:

• The Consumer Credit (CONC) sourcebook
• The Complaints Handling (DISP) sourcebook
• The Client Assets (CASS) sourcebook
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.

22Feb

Former FSA chair warns of risks associated with P2P industry

Lord Adair Turner, former chairman of the Financial Services Authority, has sparked controversy by saying that problems lie ahead for the peer-to-peer (P2P) lending sector.

Speaking on BBC Radio 4’s Today programme, Lord Turner said:

“A group of people are going into a lending process on a technical platform without anybody really doing ‘go out and kick the tyres’ credit analysis.

“You cannot lend money to small and medium enterprises without somebody going and doing good credit underwriting, which is understanding where are these premises that the guy says he’s got?

“The losses which will emerge from peer-to-peer lending over the next five to 10 years will make the bankers look like lending geniuses.”

Christine Farnish, chairman of the trade association, the Peer-to-Peer Finance Association, rejected Lord Turner’s suggestions by saying:

“Anyone who has followed our industry closely will see that this morning’s comments fly in the face of the evidence. Since the industry began, defaults on loans are low, measuring between 2% and 3%.”

“We only lend to creditworthy consumers and established small and medium sized enterprises. Strict credit underwriting rules apply to all our members and this should not be confused with higher risk forms of crowdfunding or lending to sub-prime customers.

“All members of the P2PFA operate with high standards of transparency and business conduct. This includes publishing their full loan books on their websites and providing clear information on all fees and charges to both investors and borrowers. I would challenge anyone to find this level of transparency in any other part of the financial services market.”

The Association expects the sector to double in size every six months, especially as April 2016 will see the launch of the new Intelligent Finance ISA, where P2P loans can form part of a tax-efficient savings portfolio.

Despite Lord Turner’s predictions, the four largest P2P firms: Zopa, RateSetter, Funding Circle and Market Invoice, have so far been able to pay compensation from their ‘reserve funds’ to any customer affected by a default. P2P customers do not have recourse to the Financial Services Compensation Scheme.

Although Ms Farnish has dismissed the former FCA chair’s warnings, Neil Faulkner of 4thWay, a risk rating agency, noted that of the major players in the industry, only Zopa was around during the last economic crisis, and that the P2P industry could encounter difficulties if it started taking on riskier and riskier borrowers as economic conditions worsen.

Funding Circle co-founder James Meekings has predicted that his firm could manage an economic crisis in which bad debts increase by 65%. He remarked that his firm was a lower risk operation as it did not accept start-up companies as customers, and that the average Funding Circle firm had been trading for eight years.

Mr Meekings invited Lord Turner to attend his firm’s offices, where he would “see a world where we do look at every loan. We have better people looking at small business lending than banks do.”

Whether P2P firms agree with Lord Turner or not, they need to be aware of the need for responsible lending at all times. They are required to comply with most of the Financial Conduct Authority’s rules that apply to lenders – such as assessing the affordability and creditworthiness of all applications – even though P2P firms do not themselves lend 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.

18Feb

Year-long extension to MiFID II deadline announced

The European Commission has proposed a one year delay in implementation of the European Union (EU)’s Markets in Financial Instruments Directive II (MiFID II), which is designed to further harmonise the regulatory regime across member states. The legislation is now expected to come into force in all EU member states on January 3 2018.

This follows concerns that national regulators and participants in trading markets would both experience severe difficulties in completing their preparations for MiFID II by early 2017.

Jonathan Hill, the EU’s Commissioner for Financial Services, Financial Stability and Capital Markets Union said:

“Given the complexity of the technical challenges highlighted by ESMA, it makes sense to extend the deadline for MiFID II. We will therefore give people another year to prepare properly and make the necessary changes to their systems. Meanwhile, we are pressing ahead with the level II legislation to implement MiFID II and expect to announce those measures shortly.”

Prior to the announcement, Steven Maijoor, chairman of the EU’s European Securities and Markets Authority (ESMA), had suggested that a 12 month delay may not be sufficient, so it remains to be seen whether the new January 2018 deadline will be moved back in due course.

MiFID II will introduce a requirement to disclose all product and other charges to investors upfront; a different definition of independent financial advice; an increased emphasis on assessing clients’ capacity for loss before giving investment advice; and new rules on the receipt of inducements. Its implications for advisory firms could be far reaching, and could have an impact in areas such as:

• Resolution of conflicts of interest
• Complaints resolution
• Handling of client assets
• Inducements and payments to third parties
• Suitability of advice
• Provision of information to clients

Earlier suggestions that the legislation would require all financial advisory firms to tape face-to-face conversations with clients have now been dismissed. The UK regulator, the Financial Conduct Authority (FCA), has said that the MiFID II rules on recording of telephone conversations with clients are similar to its existing rules, although the Directive dictates that recordings are retained for as long as five years.

The head of the trade association the Association of Professional Financial Advisers, Chris Hannant has said that, in spite of the delay “the timetable is likely to still be challenging”, but the FCA has urged firms to “press ahead with their implementation work.”

The FCA’s December 2015 consultation paper focussed on the implications of MiFID II for investment banks, interdealer brokers, algorithmic and high-frequency traders, trading venues, data reporting service providers and investment managers. But all advisory firms must understand that the legislation will have an impact on their practices and procedures. The FCA will publish further consultation papers on the subject during 2016.

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.

17Feb

FCA updates credit authorisation process in latest data bulletin

In its first Data Bulletin of 2016, the Financial Conduct Authority (FCA) has provided an update on the process of authorising the many consumer credit firms in the UK. All figures in the bulletin are correct as of September 30 2015.

At this time, there were 39,926 firms in the UK – excluding appointed representatives – who were legally able to carry out some form of credit activity. 21,438 of these have been fully authorised by the FCA and a further 18,488 still hold interim permission, and hence are either yet to apply for full authorisation, or else are waiting for an FCA decision on their application. The FCA is also considering 1,359 applications from new credit firms.

For most interim permission firms, the application period has closed. Some 15,372 firms have lapsed or cancelled their authorisation, which could be for a variety of reasons, including:

• The firm decides it does not require credit authorisation
• The firm will be, or has been, consolidated into another firm within the same business group
• The firm has ceased trading

1,187 firms withdrew their application for authorisation, and at the time of writing, only 28 firms had seen their applications refused.

Firms who have seen their applications refused include:

• Money Clinic Debt Management Limited, who previously carried out debt counselling, debt adjusting and credit broking activities under interim permission. Concerns were identified regarding the level of fees it charged, the quality of its debt advice and its ability to meet the prudential resources requirement
• Big T Media Limited (trading as New Start Debt Solutions), another debt management firm. The firm’s advisers were not considering all debt solutions that may be suitable for a particular customer, and customers were being placed into repayment plans regardless of their circumstances. The FCA also had serious concerns over the competence and lack of relevant experience of the firm’s sole director; the firm’s fee structure was confusing; and the procedures the firm provided in its application for areas such as compliance monitoring, staff training and assessment of suitability of advice did not provide the level of detail the FCA expects to see

Processing times for authorisation applications continue to increase. In the third quarter of 2015, the FCA took on average 25.6 weeks to reach a decision on a full permission application, 11.2 weeks on a limited permission application and 11.7 weeks on a variation of permission application.

The bulletin also contains data on the FCA’s ongoing reviews of authorised firms’ financial promotions. Although the regulator only identified 34 promotions that needed to be amended or withdrawn, from the 1,108 it reviewed during the third quarter, 22 (65%) of these 34 were in the consumer credit sector. Credit firms are thus advised to re-read the Financial Promotions rules in the FCA Handbook, and make any required changes to their promotional material.

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.

15Feb

Personal insolvencies fall, but household defaults expected to soar

Individual insolvencies in the UK have fallen to their lowest level in a decade, but only days later, a debt purchasing agency predicted a significant rise in household debt.

According to the Insolvency Service, there were 79,965 individual insolvencies in 2015, a reduction of 19% compared to 2014. These insolvencies included 39,993 Individual Voluntary Arrangements (down 23% on the previous year), 24,175 debt relief orders (down 9%) and 15,797 bankruptcies (down 22%). 2015 is the fifth year in succession in which insolvencies have fallen, with lending criteria having been tightened and the general economic climate having improved.

Phillip Sykes, president of insolvency trade association R3, commented:

“It’s welcome that insolvency numbers fell so far from their 2010 peak in 2015. Continuing low inflation and a growing economy have helped people pay down or service debts. The return of real wage growth has put a big debt in insolvency numbers.”

Corporate insolvencies in 2015 totalled 14,629, a fall of 10% from 2014, and the lowest figure since 1989.

However, the good news was tempered by a prediction from debt purchaser Arrow Global that consumer defaults will increase by 17% over the next five years, and that by 2020, 4.7 million households will be in arrears, 700,000 more than at present. If the base rate was 0.5% higher than predicted, then this number would rise by 24% to five million.

The debt to income ratio – a comparison of individual debt repayments against overall household income – has fallen from 145% in 2008 to 120% in 2015, but Arrow Global predicts this will rise to 160% by 2020.

Tom Drury, Chief Executive Officer of Arrow Global, said:

“Low interest rates and reduced lending have led to a fall in the consumer debt burden since the financial crisis. However, the recent upturn in consumer confidence means this trend is ending as overall lending increases and as interest rates rise, defaults will start to increase from their current low levels.

“The rise in the number of individuals in default will make professional debt management all the more important for both lenders and the borrowers in difficulty. The consumer debt industry needs to work closely with advisory consumer bodies now to plan for this rise, so borrowers in difficulty are given the best advice and help in managing their finances.”

Separate figures from the Government’s Office for Budget Responsibility have suggested a 49% increase in unsecured debt levels, equivalent to £8,000 per household, by the end of 2020.

Arrow Global also expects mortgage re-possessions to rise by 9% from 10,400 in 2016 to 11,300 in 2020. Personal insolvencies are predicted to rise 3% by 2020.

Matthew Chadwick, head of personal insolvency (England & Wales) at accountants BDO, said:

“With household debt now at its highest level in four years and real earnings having grown by just 0.7% between January and November 2015, it is unsurprising that debt as a percentage of net household income has risen to over 55%.”
“This situation is unlikely to change in the short term and there is every possibility that real earning increases could fall back into the negative this year. The outlook for many remains difficult.”

“The impact of October’s seven-fold increase in the bankruptcy threshold level has yet to be felt, though could prompt a notable fall in insolvencies this coming year as the threshold alteration is dealt with in the courts.”

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.

12Feb

MoJ issues details of fourth quarter enforcement action

The Claims Management Regulator at the Ministry of Justice (MoJ) has released details of the enforcement action it took between October and December 2015.

During this period, 273 claims management companies (CMCs) were visited and 82 were formally audited. This resulted in 51 warnings being issued and 33 investigations commencing. Eight companies were stripped of their authorisation for regulatory failings, and four were fined.

The bulletin then breaks down details of the regulator’s actions into three categories: financial claims, nuisance calls and texts and personal injury.

Regarding financial claims, an area that includes mis-selling of payment protection insurance (PPI) and packaged bank accounts, 33 audits were carried out. 11 warnings were issued, three new investigations commenced and three investigations are continuing.

During the quarter, PPI claims company Rock Law Ltd was fined £570,000 and had the terms of its authorisation amended as a result of irregularities in its contracts with clients, and its conduct in pressurising customers to enter into contracts with the company.

In the area of nuisance calls and texts, 30 audits took place, 11 companies were warned and six investigations are ongoing. Breaches of the rules in this area resulted in a number of significant enforcement actions, which included:

• Cancelling the authorisation of Falcon & Pointer Ltd, who made 40 million nuisance calls
• Issuing the MoJ’s highest ever fine (£850,000) to The National Advice Clinic for its six million unsolicited calls
• Fining Complete Claim Solutions £91,845 for making marketing calls to individuals registered with the Telephone Preference Service

Falcon & Pointer’s conduct was described as “the worst excesses of the industry” by Kevin Rousell, head of the Claims Management Regulator. The company also pressured clients into signing contracts, and took payments, without allowing the clients time to understand the contract terms, and was in fact in breach of as many as six sections of the Conduct of Authorised Persons Rules.
The bulletin says the MoJ continues to share information with Ofcom and the Information Commissioner’s Office, and that it works closely with these organisations in its efforts to tackle malpractice regarding nuisance calls.

Regarding personal injury, the MoJ audited 45 companies during the three month period and issued 12 warnings. Two investigations are continuing. The regulator also shared information to assist with criminal investigations being carried out by West Midlands Police and the Insurance Fraud Enforcement Department of the City of London Police. The MoJ also works closely with the Government Agency Intelligence Network and the Insurance Fraud Bureau regarding personal injury claims issues.

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.

10Feb

Wide ranging claims management regulation bulletin issued by MoJ

The February 2016 bulletin from the Claims Management Regulator at the Ministry of Justice (MoJ) is extremely wide ranging, and claims management companies (CMCs) need to read it carefully.

Firstly, reference is made to three major enforcement actions taken by the MoJ recently:

• Falcon & Pointer Ltd had their authorisation cancelled after making 40 million nuisance calls
• The National Advice Clinic received a record fine of £850,000 for its six million unsolicited calls
• It has executed a warrant on a CMC suspected to be operating without authorisation

Next, companies are warned that under General Rule 2(a) and Client Specific Rule 1(b) of the Conduct of Authorised Persons Rules, they are required to conduct a comprehensive fact find on their customers before submitting a claim. This requirement applies to the original claim made to the firm involved, as well as to referrals to the Financial Ombudsman Service (FOS).

CMCs are reminded of the new complaints rules introduced under the Alternative Dispute Resolution, and that firms are required to give their consent to the FOS handling complaints that are referred to them outside the usual timescales.

Companies are then asked to note a number of issues relating to the Financial Services Compensation Scheme (FSCS). These include:

• Claims are not actually made against the FSCS – instead the Scheme settles claims against firms that are insolvent
• Unless the firm actually is insolvent, customers should follow the usual process of complaining to the firm and then to the FOS if necessary
• Limits apply to FOS compensation, and customers may not receive compensation for the full value of their loss

CMCs must provide customers with the required pre-contractual information “in good time before the conclusion of the contract”. The bulletin suggests that 24 hours would be a reasonable period for a customer to consider the information. The bulletin also highlights that not allowing customers sufficient time to consider the information was one of the reasons enforcement action was taken against Falcon & Pointer (see above) and against Rock Law Ltd.

The bulletin once again reminds customers that they cannot make unsolicited marketing calls to individuals registered with the Telephone Preference Service (TPS), and cannot make any automated calls or send any marketing texts unless the recipients have consented in advance to receiving them. If customers did previously give consent for a CMC to over-ride the TPS requirements, or consented to receiving automated calls or texts, then the bulletin says that companies should only rely on this consent if it was given in the last six months. Companies authorised by the MoJ are also required to keep comprehensive records to evidence who has given consent.

The regulator has confirmed that annual regulation fee and application fees for CMCs will remain unchanged for the 2016/17 financial year.

Finally, companies are invited to attend two training courses on complaints handling being organised by the Legal Ombudsman. The bulletin on the MoJ’s claims management regulation website contains links to allow companies to book their places.

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.

09Feb

Entire credit sector to pay levy to tackle loan sharks

After earlier indications that the UK’s payday lenders would need to bear the entire burden of a new levy to fund the fight against illegal lending, the Government has now announced that the new levy will be paid by all 50,000 consumer credit firms in the UK.

The levy will commence in the 2017/18 financial year, although it is unclear what level it will be charged at, or whether firms that have credit authorisation but primarily conduct other activities will need to pay it.

The Illegal Money Lending Teams in England and Wales have helped borrowers throughout the UK recover funds from loan sharks since it was launched in 2004. They have helped 24,000 loan shark victims to get £63 million of illegal debts written off, and some 300 illegal lenders have been prosecuted so far. However their funding has been slashed by the Government, which is now turning to the credit industry to plug the funding shortfall.

In December 2015, it seemed that the burden of funding the Illegal Money Lending Teams would fall entirely on the payday loan sector. A backbench MP raised the issue of cuts to the team’s funding at Prime Minister’s Questions, and Chancellor of the Exchequer George Osborne MP, who was standing in for the Prime Minister on the day in question, mentioned a payday levy as a possible solution in reply.

On the announcement of a levy across the credit industry in February 2016, Mr Osborne said:

“I am absolutely determined to protect customers from abuse and sharp practice in the consumer credit market.

“That is why I capped the total cost of a payday loan, it’s why we’re taking further action today to tackle illegal loan sharks by ensuring that enforcement teams have the funding, from the industry, they need to protect consumers from those that would do them harm.”

“Illegal money lenders prey on some of the most vulnerable people in society, causing their victims immense misery,” said Economic Secretary to the Treasury Harriett Baldwin MP

“That is why we act now to ensure that illegal money lending teams have the funding they need to continue to protect consumers and prosecute loan sharks.”

Russell Hamblin-Boone, chief executive of the Consumer Finance Association (CFA), a trade association that represents a number of payday lenders, appeared to welcome the move.

“The CFA and our members have long been supporters of the Illegal Money Lending Team,” said Mr Hamblin-Boone.

“All firms operating in the financial services sector have a responsibility to protect consumers and ensure that the Illegal Money Lending Team is funded long into the future. A levy administered by the Financial Conduct Authority funded from across the financial sector is the correct way to go.”

Mr Hamblin-Boone had earlier commented on the unfairness of forcing payday lenders to bear the entire burden of funding the fight against illegal lending.

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.

08Feb

FCA withdraws permission from debt management firm over multiple regulatory issues

In January 2016, the Financial Conduct Authority (FCA)announced it had refused an application from Edgware, Middlesex-based firm Money Clinic Debt Management Limited, who carried out debt counselling, debt adjusting and credit broking activities. The firm previously held interim permission from the FCA following the transfer of regulation from the Office of Fair Trading.

The firm failed to make any representations in reply to the FCA’s Warning Notice of October 2015, when the regulator said it was minded to refuse the application.

The reasons why the application was refused include:

• The fact that for 76% of its customers, the firm charges fees of more than 50% of the monthly repayment, thus increasing customers’ debt burden by up to 15%. One customer was paying 81% of their repayments in fees. The firm did not act as a debt manager in the traditional sense, in that it did not set up debt management plans. Instead, customers made payments direct to creditors under revised terms that Money Clinic had negotiated on their behalf. This means the firm was not subject to the same specific rules as debt managers are, i.e. the requirement in CONC 8.7.2 to ensure the fees are not so large that they affect the customer’s ability to make repayments, yet the FCA still concluded that Money Clinic’s fee structure was not in the interests of their customers.
• The firm’s failure to respond to requests for information from the FCA
• Its failure to put in place locum arrangements should the sole director and 100% shareholder, Ronald Golding, be absent
• Its failure to inform the FCA that it ceased trading in July 2015. This came to light when Mr Golding wrote to the FCA in December 2015, informing them that the firm had ceased trading and asking to withdraw the application. The FCA did not accede to the withdrawal request as it had already commenced the enforcement process.
• The fact that the firm could not satisfy the FCA’s prudential resources requirement. For the last three complete financial years before the authorisation application was made, the firm declared annual profits of £71, £161, and £81 and the FCA was not satisfied that it could meet the requirement to hold resources of £5,000. The firm’s application did not evidence that they had considered this issue
• The firm not being able to supply copies of pre-contractual information provided to customers
• Concerns over the quality of the firm’s debt advice. The FCA reviewed three customer files, all of which were for customers whose disposable income was negative. If a client does not have sufficient disposable income to pay the firm’s fees, then they should be referred to a not-for-profit debt advice agency instead. The regulator also found a number of customers who would have taken hundreds of years to become debt free under the repayment strategies that Money Clinic had arranged for them

The firm thus failed to satisfy as many as four of the FCA’s Threshold Conditions.

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.

05Feb

FCA refuses CEO application

The Financial Conduct Authority (FCA) has announced that it has refused an application from Veena Bhandari to act as chief executive of Bedford-based stockbroker and investment adviser William Albert Securities Limited.

The application for her to carry out this function was made in April 2014. In July 2015, the FCA issued a Warning Notice stating that it was minded to refuse the application, and invited the firm and Mrs Bhandari to make representations. In October 2015, the FCA issued a Decision Notice proposing to refuse the application, and when the firm failed to appeal against this decision, then the regulator issued its Final Notice.

The FCA says it received only limited information to allow it to determine Mrs Bhandari’s competence and capability, in the form of a brief CV. The firm and Mrs Bhandari refused the FCA’s invitations to an interview to discuss the matter of the missing information.

Mrs Bhandari was a director of William Albert Securities from 2007 to 2014 (i.e. a CF1 function in the FCA’s Approved Persons Regime), and briefly carried out the Apportionment and Oversight function (CF8) after this time.

The firm says it declined the invitations to interview as it believed the FCA should have had sufficient information from the previous competency assessment to be able to reach a decision. The FCA says however that it never carried out an assessment of her fitness to carry out the chief executive role (CF3), and that it cannot be assumed that because she was deemed competent to carry out other roles, that she would automatically have been considered competent to be the chief executive.

This case illustrates that just because an individual has been deemed competent to carry out one senior role, it does not automatically follow that they are competent to carry out another. It also illustrates how co-operation with the FCA is vitally important, and as the regulator pointed out in its Final Notice, it is entitled to request that applicants supply information in the way that it desires. The FCA did not take kindly to the firm’s suggestion that it should email its queries rather than conduct a formal interview with Mrs Bhandari.

Under the forthcoming Senior Managers & Certification Regime, the decision as to whether to appoint someone to a senior position would fall to the firm and not to the FCA. This regime will be introduced in the banking industry in March 2016, and in the rest of the financial services industry in 2018. Under the new Regime, it would have been William Albert Securities that decided whether to appoint Mrs Bhandari as its CEO, not the FCA. But for now, the regulator must approve all appointments of directors, senior managers, heads of compliance, anti-money laundering officers etc.

As of February 1 2016, the William Albert Securities website shows Mrs Bhandari as the ‘Director and Chairperson’.

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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