What is in the new FCA chief’s in-tray?

In just a few days’ time, there will be a new boss at the UK’ s principal financial regulator. Andrew Bailey is to leave his position as chief executive at the Prudential Regulation Authority and will start work in the equivalent role at the Financial Conduct Authority (FCA) on July 1.

The FCA has been without a permanent chief executive since the Chancellor of the Exchequer removed Martin Wheatley from his position in July 2015. For the past year or so, the role has been carried out on an interim basis by the FCA’s former enforcement director Tracey McDermott, who will now be seeking new opportunities.

So what tasks are facing Mr Bailey when he starts work at Canary Wharf, and what can the industry expect things to be like on his watch?

Some commentators have suggested that Mr Bailey will be a less confrontational regulator, considering that Mr Wheatley once infamously remarked he would “shoot first and ask questions later” when supervising firms.

However, Mr Bailey made some hard hitting comments about the way banks act, and the way they are perceived, when he addressed the City Week conference in May 2016.

“Culture has laid the ground for bad outcomes, for instance where management are so convinced of their rightness that they hurtle for the cliff without questioning the direction of travel”, he said, before adding:

“Today, the public perception of banking, and some other areas of finance, remains too much towards the exploitative ‘greed is good’ end of the spectrum. Major changes have occurred since the crisis which have improved behaviour in firms, but public opinion broadly does not recognise these developments and tends to think that nothing has changed.”

According to previous remarks by FCA chairman John Griffith-Jones, one of Mr Bailey’s key tasks will be to review the regulator’s approach to redress schemes in cases of mis-selling.

Mr Griffith-Jones said:

“One of the crucial things Andrew Bailey and the board will look at when he arrives is how we deal with these redresses. How do we get a scheme to begin and end to the satisfaction of everybody that we’re doing a decent job? If you look at PPI or swaps, or other difficult cases, it’s still a work in progress. It’s very easy to start these things, but it seems very difficult to finish them.”

The new Senior Managers & Certification Regime (SM&CR) is still in its infancy – it was not introduced in the banking sector until March 2016, and it will be 2018 before it is implemented in other sectors of financial services. Some commentators have suggested we should expect a high profile scalp early in Mr Bailey’s tenure, where decisive action is taken against a bank boss in order to set an example.

The recommendations of the recent Financial Advice Market Review also need to be implemented. This Review, jointly commissioned by the FCA and the Treasury, is looking at how access to financial services could be improved.

The exact ‘tone from the top’ that Mr Bailey will set remains to be seen. But for now, the rules firms need to follow remain unchanged.

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.


Data shows FCA fines for individuals increase, but fall for firms

The total amount of fines imposed by the Financial Conduct Authority (FCA) fell by 36% in the 2015/16 financial year when compared to the previous 12 months. However, despite this fall in the overall total, the total amount of fines imposed on individuals rose by 142%, i.e. it more than doubled.

The research by law firm Clyde & Co shows that the regulator handed out total fines of £1.41 billion in 2014/15 and just £898 million in 2015/16. The 2014/15 figures included a number of large fines imposed on banks for LIBOR and foreign exchange manipulation.

The total fines imposed on firms fell from £1.4 billion to £880 million.

The fines imposed on individuals however rose from £7 million in 2014/15 to £17 million in 2015/16. While the total monetary amount of the fines handed to firms is still much larger, the actual number of fines handed to individuals and to firms in 2015/16 was equal, at 17 each.

Clyde & Co partner John Whittaker says:

“Although it is difficult to draw firm conclusions from just three years of statistics, it does suggest that the regulator now appears to be turning its focus towards individuals. This is supported by recent regulatory changes which are aimed at holding individuals to account for any behaviour that strays outside of the regulator’s rule book.

“The senior managers’ regime has sent shockwaves throughout the financial services industry. In the past senior figures at financial services companies have largely managed to avoid punishment for their own and their team’s actions. That has now all changed.

“Companies will be hoping that the new rules help to ensure employees play by the book but are not put off from taking calculated risks in order to boost profits.”

The FCA introduced the Senior Managers & Certification Regime (SM&CR) in the banking sector in March 2016, and this will be rolled out to all authorised firms from 2018. But the latest fines information shows that, even under the existing Approved Persons Regime, the era of individual accountability has already arrived.

At present, all individuals carrying out ‘approved persons’ roles need to be individually ratified by the FCA before they commence their duties. Under the SM&CR, the firms themselves will need to carry out their own assessment on at least an annual basis. Essentially, this new Regime will replace the Approved Persons Regime.

Anyone who carries out an approved person role must demonstrate that they are a ‘fit and proper’ person, having regard to their honesty, integrity and reputation; competence and capability; and financial soundness.

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.


So it’s Brexit – what will happen to financial services in the UK?

The UK electorate has voted to leave the European Union (EU), and the Prime Minister has announced he will leave office by October.

However, the first important thing to note is that, as of now, nothing has changed. The UK remains a member of the EU, and will not leave until two years after the Government invokes Article 50 of the Lisbon Treaty, at the earliest. The Prime Minister has said this Article will not be invoked until his successor is in place.

‘Business as usual’ was the common theme of a statement issued by the regulator, the Financial Conduct Authority (FCA), within hours of the result becoming known. The FCA said:

“Much financial regulation currently applicable in the UK derives from EU legislation. This regulation will remain applicable until any changes are made, which will be a matter for Government and Parliament.

Firms must continue to abide by their obligations under UK law, including those derived from EU law and continue with implementation plans for legislation that is still to come into effect.”

No authorised firm should be in any doubt that the need to comply with their obligations under EU regulations and directives remains unchanged. The largest piece of EU legislation affecting financial services is Part II of the Markets in Financial Instruments Directive (Mifid II), which is expected to come into force on January 3 2018. The Mortgage Credit Directive is already in force, but additional rules will apply to firms from March 21 2017 and from March 21 2019 as a result of this piece of European legislation. The Market Abuse Regulation comes into force in just a few days’ time, on July 3.

It is unclear at present whether the UK will seek to join the European Economic Area (EEA) (adopting a similar relationship with the EU to that of Norway and Iceland), or become a member of the European Free Trade Association (EFTA) (like Switzerland), or seek to negotiate all of its own trade deals. If the UK joins the EEA or the EFTA, then it is likely to have to continue to follow EU law in many areas.

Even if the UK adopts the ‘independent’ approach, and does not join either of the trading associations, then firms need to note that previous EU Directives have in effect been incorporated into UK law, and that the only way they will be repealed is if the UK Parliament votes to scrap them.

PwC financial services risk and regulation practice partner Laura Cox summarised the situation by saying:

“Firms will have to keep going. It feels like maybe you should put your pen down at this point but that is not the right answer. There are lots of options for where we might end up with an exit. We could go to a Norwegian model where we adopt some pieces of legislation and, in that case, Mifid II would be likely to be one of those [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”][initiatives] that is so embedded in UK law that it would come into the UK virtually wholesale. It is not a time to stop progressing to becoming compliant with that.”

The compensation limits under the Financial Services Compensation Scheme remain unchanged for the present.

Share prices fell significantly following the vote, but the longer term effects are unclear. The FTSE 100 index fell by 11.5% at the start of trading on Friday June 24. It then bounced back by gradually recovering around two thirds of this sudden loss, but when the markets opened on Monday June 27, share prices were tumbling 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.[/fusion_builder_column][/fusion_builder_row][/fusion_builder_container]


The Market Abuse Regulation

The European Union (EU)’s Market Abuse Regulation (MAR) comes into force in the UK on July 3 2016. The result of last Thursday’s referendum will not affect its implementation in any way.

MAR is designed to deliver increased levels of investor protection and to increase market integrity.

Trading in all of the following is covered by the terms of the Regulation:

• Financial instruments that trade on a regulated market, or where a request has been made to allow them to trade on a regulated market
• Financial instruments that trade on a multilateral trading facility (MTF), or where a request has been made to allow them to trade on an MTF
• Financial instruments that trade on an organised trading facility (OTF)
• Other financial instruments whose price or value is dependent on, or could affect, the price or value of another instrument which trades on a regulated market, an MTF or an OTF. Examples here would include credit default swaps and contracts for difference
• Emission allowance market participants
• Certain spot commodities

Some of the key changes that MAR will bring about include:

• The definition of inside information will be widened to include information about emission allowances and spot commodities
• The definition of insider dealing will encompass the use of inside information to amend or cancel an existing order
• It will be illegal to persuade another party to enter into a transaction on the basis of inside information
• Attempts at market manipulation will be treated in the same way as actual market manipulation
• Issuers of financial instruments must maintain a list of which of their employees have access to inside information
• Inside information must be disclosed as soon as possible. Public disclosure of information can only be delayed if all of the following conditions are met: immediate disclosure would prejudice the issuer’s interests, the delay would be unlikely to mislead the public, and the issuer can ensure the information remains confidential. Once the information has been made public, the issuer must notify the UK’s MAR ‘designated competent authority’ of the delay, and if requested, should then provide a written explanation of the delay. The designated competent authority is the Financial Conduct Authority. Firms must keep records of the time and date the decision was made, the persons responsible for making the decision to delay and evidence of the circumstances that permit the delay under the MAR
• ‘Persons discharging managerial responsibilities’ must notify both the issuer of the financial instrument and the FCA of transactions conducted on their own account of more than EUR 5,000 in value. The notifications must be made within three business days after the date of the transaction.

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.


Three Manchester claims companies disciplined by ICO over marketing practices

Three companies, all in the Manchester area, were disciplined by the Information Commissioner’s Office (ICO) over their marketing practices in early June 2016. In all cases the marketing activity concerned potential consumer claims of one form or another.

The most startling case was that of Altrincham-based Advanced VOIP Solutions Ltd, who were fined £180,000. The company made large numbers of automated calls regarding insurance, packaged bank accounts (PBAs) and flight delays. Even if customers followed the instructions in the call to opt out of receiving future calls, the calls continued, with some households reporting as many as 50 calls a day.

Steve Eckersley, head of enforcement at the ICO, said of Advanced VOIP’s behaviour:

“The number of complaints in this case is just a drop in the ocean compared to the millions of calls we think this company has made.

“We have sent out a clear message to companies who behave in this way – however much you try and dodge the law, it won’t work, and we will act.”

Central Manchester-based Quigley & Carter Limited was fined £80,000 for sending thousands of unsolicited texts regarding PBA claims. This company relied on third party firms to send its texts, however one of the third party firms it used, Help Direct UK Limited, has itself been fined by the ICO in the past.

Mr Eckersley said of this company:

“People were left annoyed, angered and upset by these texts. The rules around electronic marketing messages are simple and there for a very good reason – to protect people’s privacy rights and stop unwanted phone calls, texts and emails.

“We committed to target organisations that broke the rules. Quigley and Carter should have known the rules and obeyed them. They failed to follow the law and so we’ve acted – to show them and others that organisations cannot ignore their obligations.”

Bury-based Central Compensation Office Ltd has not been fined, but has been issued with a Stop Now order by the ICO after making live marketing calls to individuals registered with the Telephone Preference Service (TPS). If the order is breached, a criminal prosecution could follow. The company trades as Industrial Workers Office and National Advice Clinic.

Andy Curry, ICO Enforcement Group Manager, said of Central Compensation Office’s actions:

“When people sign up to the TPS it’s because they do not want to be bothered by companies phoning up and selling them things.

“People are right to complain when firms are not mindful of the rules.”

The ICO has taken numerous similar actions, and has repeatedly warned claims management companies and other firms that marketing calls cannot be made to people who are TPS registered, and that automated calls and texts can only be made to people who have explicitly consented in advance to receiving these types of communications.

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.


Firms offering debt consolidation mortgage advice warned they may need credit permissions

The Financial Conduct Authority (FCA) has warned firms giving mortgage advice that they may also need consumer credit permissions. The issue arises where an adviser recommends or suggests that a client consolidates one or more unsecured debts into their mortgage. This could be regarded as debt counselling, an activity that requires consumer credit permissions.

Even if the adviser simply mentions debt consolidation as one of a number of options available to the client, then the guidance provided by the adviser could still be classed as debt counselling. Here, the FCA’s guidance says that:

“In general terms, simply giving balanced and neutral information without making any comment or value judgement on its relevance to decisions which a debtor may make is not advice. The provision of purely factual information does not become regulated advice merely because it feeds into the debtor’s own decision-making process and is taken into account by him.

“In the FCA’s opinion, however, such information is likely to take on the nature of advice if the circumstances in which it is provided give it, expressly or by implication, the force of a recommendation.

“For example the adviser may provide information on a selected, rather than balanced and neutral, basis that would tend to influence the decision of the debtor. This may arise where the adviser offers to provide information about certain ways of liquidating the debtor’s debts that contain features specified by the debtor. The adviser may then exercise discretion as to which course of action to highlight.”

The regulator has previously highlighted the need for financial advisers that give investment advice to hold debt counselling permissions. Advisers may frequently recommend that clients pay off certain debts before committing capital to an investment.

The FCA defines debt counselling as:

“Advice given to a borrower (or hirer) about the liquidation of a debt due under a credit agreement (or consumer hire agreement).”

For the purposes of the above definition, “liquidation” includes:

• Paying off the debt in full as scheduled
• Agreeing a suspension in repayment of the debt
• Agreeing a re-scheduled payment plan
• Writing off the debt
• Agreeing reduced repayments
• A third party taking on another party’s debt obligations
• Incorporating the debt into a bankruptcy order, a voluntary arrangement or a debt relief order

The activity is only regarded as debt counselling if the advice given relates to a specific individual and to a specific debt.

Existing authorised firms can apply to add permissions by submitting a Variation of Permission application via the Connect system on the FCA website.
Firms that are in any doubt as to what permissions they need are urged to seek expert advice.

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.


Two advisers banned over lack of integrity

Two financial advisers have been banned from working in financial services for placing clients’ funds in potentially unsuitable investments without these clients’ knowledge or consent. The pair also concealed from their clients the fees they were receiving.

The Financial Conduct Authority (FCA) took action against Mark Kelly and Patrick Gray after discovering a litany of different issues that cast doubt on their integrity. Mr Kelly traded as PCD Wealth and Pensions Management, based in Wilmslow, Cheshire, and Mr Gray was one of his employees.

The regulator was unable to impose any fines alongside the bans as neither Mr Kelly or Mr Gray held an approved person role at the time of the misconduct.

The issues concerning Mr Kelly included:

• Investing clients’ pension funds in high risk areas without their knowledge or consent
• Failing to ensure that the selected investments were suitable for the clients’ circumstances
• Taking steps to try and prevent clients discovering where their monies had been invested
• Receiving payments from product providers, taken out of the investments themselves, without clients’ knowledge or consent
• Certifying clients’ passports as true copies of the originals, and true likenesses of his clients, when in fact he had not met the clients and was not in a position to do so

In one case the FCA found that Mr Kelly had invested a client’s entire pension fund in an unregulated collective investment scheme (UCIS), before selling 50% of this investment just six months later and re-investing the monies in a structured product, all without the knowledge or consent of the client concerned. Many of the clients were nearing retirement, and the high risk and illiquid nature of UCIS made his recommendations particularly unsuitable.

In his Final Notice, the FCA is in no doubt that a prohibition is the appropriate sanction for Mr Kelly. The regulator says:

“Mr Kelly’s failings and actions were designed to enable him to profit at the expense of consumers. They were calculated, prolonged and dishonest and he would have been aware of the clear risk that consumers would suffer a loss that their age would prevent them from recovering. Mr Kelly’s failings are very serious and a prohibition order is essential in order to protect consumers.”

The issues concerning Mr Gray included:

• Providing investment advice without appropriate qualifications or training
• Giving advice to invest in high risk UCIS that were not suitable for the clients
• Misleading clients as to the fees and charges payable
• Asking clients to sign incomplete application forms
• Misleading the FCA in a compelled interview. Here he made two misleading statements, firstly saying that he did not give advice to clients, and then stating that the application forms he asked clients to sign included information about fees payable to PCD

The failings affected more than 350 clients, who collectively invested almost £24 million.

Mark Steward, director of enforcement and market oversight at the FCA said:

“These two individuals misused pension funds, endangering the retirement incomes of hundreds of people. While further investigations continue, the FCA considers it necessary to prohibit them to help protect consumers.”

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.


Citizens Advice warns consumers about paying off household credit ahead of mortgages and bills

National advice charity Citizens Advice (CitA) has expressed concern after its research suggested many consumers were choosing to prioritise repayment of debts such as credit card bills, personal loans and overdrafts, in preference to mortgages and essential household bills.

CitA surveyed 2,109 people and found that 15% of people would choose to pay off a credit card in preference to making their rent or mortgage payments. Taking this course of action could put people at increased risk of being evicted from their homes, or from receiving a visit from a bailiff seeking to collect unpaid rent.

27% would choose to pay off a credit card over paying a council tax bill, leaving them vulnerable to prosecution, which can lead to prison sentences of up to three months.

5% would prioritise their gas bill over a credit card repayment, thus risking having their gas supply disconnected.

CitA suggests two possible reasons as to why consumers might give credit card and other consumer credit debts this level of priority. Firstly, people might not realise the consequences of failing to fulfil other commitments; and secondly consumer credit firms might pressurise them into repaying their debt, or ‘shouting the loudest’ as the CitA press release put it.

Gillian Guy, Chief Executive of Citizens Advice, said:

“Falling behind on household bills can have serious consequences.

“From getting the power cut off to bailiffs knocking at your door, to losing your home or even prison – failing to pay household bills can put people in vulnerable situations.

“Huge numbers of people are unsure of what debts they should prioritise when they get into difficulties which underlines how important it is for people to be able to access free, independent help to manage their finances.

“Similarly being offered money advice at key moments in life could also help people make the most of their money, avoid debt and plan for the future.”

Consumer credit firms are subject to detailed rules regarding debt collection under the Financial Conduct Authority (FCA) regime.

Firms should have documented procedures for dealing with customers in arrears. These procedures should include specific arrangements for dealing with customers in arrears who might meet the definition of a ‘vulnerable customer’. The procedures should be written with the need to treat customers fairly in mind.

Firms must ensure they consider the needs of customers in arrears, and try and reach an amicable solution to the customer’s difficulties wherever possible. Forbearance, when applied to a customer in default or arrears, might mean:

• Suspending, waiving, reducing or cancelling interest and charges
• Allowing payments to be deferred, provided this will not make the repayments unsustainable or make the term of the agreement unduly long
• Accepting reduced payments for a period of time

Customers who have been in arrears for more than a short period of time, or who show real signs of financial difficulty, should be made aware of organisations who can supply free debt advice. Note that this rule requires them to be made aware of sources of ‘free’ advice, so it is not acceptable to refer them to another commercial organisation.

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.


Claims trade association highlights store card PPI mis-selling

The Professional Financial Claims Association (PFCA), a trade body founded by five financial claims management companies, has highlighted the possible extent of mis-selling of payment protection insurance (PPI) linked to store cards.

PPI linked to store cards was often sold at the till by retail assistants without financial services experience. Firms also used the often seen tactic with PPI of pre-ticking a box, or some other method that required the customer to actively opt out of taking the insurance.

Store card finance was often provided by banks, with Santander and GE Capital Bank especially active in this market.

The Association believes that mis-selling of this type of insurance could date back as far as the 1980s, and that large numbers of customers are unaware they ever had the insurance.

Compensation payments for this form of insurance could be significant, as although the initial amount paid in premiums may be smaller than for other types of PPI, there could be significant sums in interest added to the payments, owing to the length of time that has elapsed since the plan was sold.

However, even if customers are alerted to the fact they may have had store card PPI, the claims process could be difficult. Insurance was not regulated by the Financial Conduct Authority (FCA) until 2005, and there is no automatic right for consumers to appeal rejected bank complaints from before this date to the Financial Ombudsman Service (FOS).

Nick Baxter, chairman of the PFCA, commented:

“Store cards are worse than the banks. There’s a perception that the PPI issue is largely done but the reality is we are nowhere near the end.”

It has been suggested that a claim dating back to before 2005 may have more chance of success if it is made to the PPI insurance provider, rather than to the finance provider. Insurance providers were still subject to a code of conduct – that of the General Insurance Standards Council (GISC) – prior to coming under statutory regulation, and the FOS will assess pre-2005 insurance complaints according to the GISC code. Commenting on this, Mr Baxter added:

“If financial services firms know a route where customers could pursue their claim, then it’s wrong morally to not make consumers aware of it. There is a route for people to get redress if they were sold before 2005, they just don’t know about it.”

Press reports suggest the FCA will make an announcement in the next few weeks regarding whether to impose a deadline on when a PPI claim can be made. This deadline is expected to be in 2018, set at two years after the date on which the FCA confirms the procedure to be followed. Despite some parties branding the deadline as ‘anti-consumer’, there is a widely held belief that it is time to draw a line under the long running PPI mis-selling saga that has forced banks and other financial firms to set aside £30 billion to pay compensation payments.

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.


CMC hit by ICO fine for nuisance calls, having already lost their authorisation with the MoJ

One month after it was stripped of its authorisation by the Claims Management Regulator at the Ministry of Justice (MoJ), a claims management company was fined £250,000 by the Information Commissioner’s Office.

Chorley-based Check Point Claims Limited was said to have made 17,565,690 automated calls marketing its hearing loss claims services between March and September 2015, and the ICO, the data protection watchdog, received 248 complaints about their activities. The calls were often made repeatedly to the same number, and in many cases, falsely claimed that the recipient had worked in a noisy environment.

The calls breached two fundamental requirements regarding automated calls. Firstly, these must only be made to customers who have actively agreed to receive them – including an opt-out disclaimer within the call is not sufficient – and secondly, the company making the calls must be identifiable from the recorded message. Check Point Claims told the ICO it was unaware of these legal requirements.

Head of Enforcement at the ICO, Stephen Eckersley said:
“Nuisance calls are bad enough, but picking up the phone to a recorded message can be the most frustrating and intrusive thing of all.

“That’s why the law is so strict – it’s there to protect consumers and in practice it’s very difficult to make a legal automated marketing call.

“If you get one, report it. If you’re making one, beware. We will take action.”

The company is now in liquidation, but Mr Eckersley said his organisation would still do everything possible to recover the fine. He added:

“We will do everything within our power to recover fines on behalf of taxpayers and those millions of people who have been hounded by unwanted calls.

“Even companies that have stopped trading or try to get themselves struck off cannot escape because we will use all means available to chase the debt.”

Details of the ICO’s action were announced on the same day as a new law came into force, which prevents companies making cold calls from hiding their number on the recipient’s caller display.

When Check Point Claims was banned by the MoJ, it was said to have been in breach of the following sections of the regulator’s rulebook:

• General Rule 2d – which requires companies to maintain appropriate records and audit trails
• General Rule 2e – which stipulates that referrals, leads and data obtained from third parties have been sourced in line with relevant regulations and laws
• General Rule 5 – which simply asks companies to observe all relevant laws and regulations
• Client Specific Rule 4 – which prevents cold calling in person and requires that all telephone, email, fax or text marketing complies with the Direct Marketing Association’s Code and related guidance

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.

Posts navigation