Open Letter - "FCA False & Misleading representations"
Updated: Aug 24
Dear Andy, and all copied Parliamentarians,
I have read the article featuring the interview with The FCA, Head of Enforcement, Mark Steward in the Sunday Times today.
(Please note that the headline has been changed since it was published. It originally read "FCA: Don't blame us for lost millions, blame the Government"
I would like to be able to say that I am astonished by it. Sadly, I am not. It features a litany of false, misleading and entirely disengenous representations, consistent with that which I have come to expect from both Mr Steward personally, and the FCA generally.
Before dissecting Mr Steward’s statements in the article, I would first draw your attention to a recent Press Release by The FCA in respect to Premier FX. It included an ‘apology’ of sorts, but only after the FCA had secured yet another ‘Deal to Conceal’ with a party, firm or persons that fails to amount to any kind of enforcement or deterrent, and is designed to limit the responsibility and therefore liability of those parties involved. In this case allowing Barclays to compensate victims to the tune of just over £10m as a gesture of goodwill, rather than sanction and compensation for catastrophic failures, breach of AML (Anti Money Laundering) legislation and what appears a clear conspiracy to defraud involving Barclays and/or its employees, and multiple failures by The FCA.
That press release featured the statement by the FCA that “We are a very different regulator today than we were [during that period]”. These representations by Mr Steward in today’s article, and various other actions it has taken since Mr Rathi took the helm, rather prove that the FCA is very much the same animal it was, and continues to regulate, investigate and enforce on a “How exposed are we basis?”, rather than an evidential basis.
Mr Rathi bemoaned to the Treasury Select Committee over a year ago, how labour and resource intensive ‘after the event’ investigations are. Indeed. However, if the FCA were to act upon reports, intelligence and evidence it receives and issued substantial sanctions and fines, then this becomes a deterrent, rather than simply a ’slap on the wrist’ cost of doing business for those responsible, and will reduce the number of such investigations going forward.
Turning to the representations made by Mr Steward in the article and the representations and comments made by the FCA for inclusion in the Panorama broadcast.
1. In the first instance if any of my claims or allegations against the FCA and Mr Bailey in the Panorama programme were false, then Mr Bailey and the FCA has the rule of law on their side and could have demanded these claims and allegations were taken out. The FCA and Mr Bailey did not seek to do this, because UK law states that I have freedom of speech. I can say anything that I want, so long as it is true. Both Mr Bailey, Mr Steward and The FCA know everything I said is true.
1.1. And to be clear, I never make an allegation, claim, report or complaint unless a) I know that I am right, AND b) Have the evidence to prove what I say and allege is true.
1.2. Instead the FCA in the broadcast and Mr Steward in this interview have chosen to put forward different representations, in the hope that the public and Parliament believe them over the representations put forward by me, an individual that the FCA has time again sought to smear and discredit. (And yes, I have the evidence to prove this also)
2. Mr Steward in the interview and The FCA in the Panorama programme represented that they had shared intelligence with City of London Police in 2017.
2.1. WHEREAS, I submitted an FOI request to the City of London Police (COLP) in 2021 after discovering countless investors were being fobbed off with false representations by the NFIB (National Fraud Intelligence Bureau) after having made a report of fraud in respect to Blackmore Bond. I asked how many reports of fraud had they received about Blackmore Bond, and did any of them come from The FCA. The following are extracts from their actual FOI response:
(Fig 1. Tables showing number of reports made to COLP/NFIB/ActionFraud) about Blackmore Bond and any associated 'Blackmore' company, and the dates they were received)
And the the FOI response included this:
(Fig 2. COLP/NFIB/ActionFraud) confirming that no reports came from The FCA)
2.2. So, who is lying? COLP or FCA? And to be clear, COLP were forced to admit that none of the reports that they had received dating back to 2016 (earlier than my first reports and the actual year Blackmore Bond launched), had been disseminated to The FCA. Not until 2020 when it was already too late and Blackmore Bond collapsed did COLP disseminate any of the reports they had received to The FCA.
Another agency that dropped the ball and now seeks to bury the ball along with investors just as The FCA is doing.
2.3. In a letter I received from The FCA in December 2021 in response to my complaint of September 2019 alleging that The FCA had failed to act upon my intelligence presented to them in March 2017 and that this lack of action had lead to significant avoidable losses, they did give a different version of events to that which The FCA had put in a previous letter to me. In December 2021 The FCA wrote:
In April 2017, UBD [Unauthorised Business Department] opened an investigation related to Amyma. In June 2017, the Amyma enquiry, which included your March 2017 intelligence, was escalated into this investigation. Subsequent to this, the FCA became aware of a pre-existing investigation by another law enforcement agency [That I understand to be the SFO who were investigating Capita Oak] which included activity which was purportedly being undertaken by Amyma. In order to avoid the risk of prejudice to that investigation, the FCA’s investigation into Amyma was subsequently closed in July 2017.
Following the closure of the investigation, there is evidence that UBD continued to receive and consider appropriate action regarding intelligence reports, including about Blackmore Bonds, on their merits. I note that UBD already had an enquiry open into Blackmore at the time of your contact with the FCA. UBD took account of their thresholds and processes at the time for assessing incoming reports, noting the extensive number of reports received by this area of the FCA.
In addition, regarding Blackmore, I have reviewed evidence that shows the FCA shared intelligence about this entity with other law enforcement agencies in July 2017. The underlying details of this intelligence, which would have included your March 2017 communications were, however, unfortunately not shared due to human error.
2.4. To be very clear here. Whatever it was that The FCA shared with whatever law enforcement agency in 2017, it did NOT include my significant and substantial intelligence, or that of any other party that made a report to The FCA due to 'Human Error'.
To be further clear if The FCA had failed to share any of the significant intelligence that they had from me and others with the relevant law enforcement agency, this will have compromised any investigation being undertaken by said agency. If they believe there is a lack of evidence, then they are going to adopt a different view than they would have done and potentially drop the investigation altogether.
It is disingenuous at best, but in reality incredibly misleading, for The FCA and Mr Steward, to purport that The FCA had shared intelligence with a law enforcement agency in 2017 as some kind of demonstration that it acted appropriately, when The FCA and Steward knows that they failed to share the most significant intelligence, and therefore compromised and prejudiced any law enforcement investigation.
2.5. For the record and avoidance of doubt, I must refer you to a previous version of events that The FCA produced in writing to me, and in respect to what they did following my March 2017 reports. In this document dated 6th July 2020 in response to an FOI request (Ref: FOI7314), they wrote:
In May 2017, the FCA formed the view that Blackmore was not carrying on regulated activities without FCA authorisation because its activities fell within the exclusion in Article 18 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 permitting small companies to issue equity and debt securities without being authorised. Further, from March 2017, NCM Fund Services Ltd, an authorised firm, approved the content of Blackmore’s financial promotions.
In this earlier response, The FCA claim that they ended their 'investigation' having made a determination that there was nothing to see here. A very different story than they gave me in December 2021.
In the same FOI response The FCA also confirm the following:
Thank you for your email of 20 May 2020 addressed to Mark Steward, the FCA’s Executive Director of Enforcement and Market Oversight, relating to Blackmore Bond PLC (Blackmore). Your email has been passed to the FCA’s Information Disclosure Team to be processed in line with the provisions of the Freedom of Information Act 2000 (FOIA). We apologise for the delay in responding to you. You have asked why the FCA did not inform members of the public, who reported concerns to the FCA about Blackmore in March 2017, that it did not regulate the minibonds issued by Blackmore. As you may be aware, FOIA covers any ‘recorded’ information held by a public authority. This includes printed documents, computer files, letters, emails, photographs, and sound or video recordings. We have approached the business areas within the FCA most likely to hold the information you have requested and, following a search of these records, we can confirm that they do not hold a record of the FCA mentioning or explaining to any member of the public in March 2017 that Blackmore and the minibonds they sold are not regulated by the FCA.
So, The FCA lied to me in 2020 when making this statement, giving an entirely different reason as to why they shut down their investigation.
2.5. So, let's be very clear here. The FCA as of May 2017 had my significant reports and intelligence and were also aware that a criminal investigation was in train. And the FCA's only action was....... to shut down their own investigation and fail to exercise any of the powers they had. And also fail to publish any warning to the public. Oh, and forget to share the significant intelligence with any other agency, prejudicing any investigation.
3. In the article and in the Panorama programme The FCA say that in 2017 they shared intelligence with COLP, and also shut down the marketing website. Disingenuous and with intent to mislead. They way those statements are constructed are intended to represent that The FCA did both of these things in 2017. FALSE.
The FCA only shut down the marketing website in April 2019, two years AFTER my reports and their awareness of the criminal investigation. The horse had not only bolted from the stable, it had crossed the Channel and was half way across Europe.
4. In the article Steward claims there was "an absence of fraud". He knows this to be false. (I have reason to believe, and evidence to support it, that explains why The FCA, COLP and the Insolvency Service are keen to suppress all mention of fraud and conceal any evidence of it. I will gladly share.)
FOR THE RECORD AND AVOIDANCE OF DOUBT:
a) In my emails to The FCA in March 2017 I specifically wrote:
"They are pushing all manner of these bonds to pensioners citing them as "guaranteed by one of the world's largest banks".
Having worked for many of the world's largest banks I can confirm that no bank, small or large, is EVER going to offer such a guarantee. The FCA and Mr Steward were also well aware of this.
THEREFORE it was, and remains, a false representation made with intent to make financial gain (the 20% commissions the firm would generate from the investment, and the further commission that Nunn & McCreesh would also take from the investment) and cause loss or risk of loss to others.
The very definition of Fraud within the Fraud Act 2006.
Or did Mr Steward believe that such representations being made to sell these products could be true?
Again, if Steward or The FCA failed to share this with the law enforcement agency in 2017, then of course no action was taken because The FCA concealed the evidence proving fraud!
b) £48m invested. All of it gone. Where did it go Mark? It certainly did not go on what the investors were told it would go on.
Indeed, what Steward and The FCA fail to mention is that the fraudsters took the investor money and then leveraged it to borrow money, taking out various mortgages and credit facilities. This enabled them to siphon off the investor money, and seek to rely upon the borrowed funds.
Not only fraud against the investors, but I am rather sure that you will find that also represents mortgage or other fraud.
c) What Mr Steward and The FCA also fail to mention is that many investors in Blackmore Bond, did not actually invest in Blackmore Bond. Indeed, John Robbins, the military veteran who you saw in the Panorama programme, had originally invested in a earlier McCreesh and Nunn 'investment vehicle' called Blackmore Estates, as did others.
HOWEVER, upon the maturity of their investment in Blackmore Estates they were both persuaded ( or forced in John's case) to 'invest' their original investment, plus the accrued interest Blackmore Estates said they had earned, in this incredible new investment product called 'Blackmore Bond', that offered greater returns and was guaranteed by insurance.
I asked both John and another investor if their original investment plus the interest was returned to them first, and that they then invested the cash themselves in Blackmore Bond. Both informed me that this did not happen and instead Blackmore Estates arranged for the 'transfer' of their investment plus accrued interest and bonuses to Blackmore Bond.
When I wrote to Kroll, Blackmore Bond liquidators, asking if there was a transfer on or around the dates their investments were supposed to have been transferred, Kroll confirmed that "Company records do show a transfer to Blackmore Bond to the value of your principal investment plus the accrued interest".
However, when we asked if there was a corresponding transfer of equivalent value in cash to any bank account in the name of Blackmore Bond on or around those dates, Kroll confirmed that there was no such transfer.
Classic Ponzi scheme flag.
Records show a transfer took place, but no actual transfer of cash or assets took place.
Again, false representations to investors, with intent to make financial gain and cause loss or risk of loss to others.
Again, that equals fraud.
d) This is not to mention the history of McCreesh and Nunn, and their various others connections, including their involvement in the Capita Oak pension scam. I understand they received circa £600,000 in commissions for introducing investors to that scheme.
e) This is also not to mention the 'chequered history' of multiple other 'connected' parties to McCreesh and Nunn, Blackmore, Amyma et al, and prior to even my reports.
f) And furthermore, The FCA and even as far back as the FSA, has been aware of 'Investment Insurance' fraud. Since the programme was aired last week I have had numerous individuals and professionals share information and reports with me dating back to pre-2010, and in respect to 'Investment Insurance' such as that used to convince Blackmore Bond investors, all of it a scam or fraud. It is clear that The FCA is aware of the scale of this insurance fraud, and have been for more than a decade, but a) Have failed to outlaw it, and b) failed to warn consumers about it.
I could go on.......'Absence of fraud Mark?' You know this to be a false representation. Or you are not qualified to hold the position you do, if you believe that. Either way, you should resign immediately.
5. My greatest concern, however, is the FCA's position put forward in May 2020 immediately after Blackmore Bond collapsed. The FCA stated "Everything about Blackmore Bond was beyond its perimeter, authority and powers."
That is as false a representation today when Mark Steward said it, as it was in May 2020 when The FCA first put this false position forward. It is my opinion that The FCA panicked into making this false representation and have been forced to try and stand by it ever since, just deepening the dishonesty.
To be very clear:
a) It is a breach of FSMA (Financial Services and Markets Act) and a breach of FCA COBS (Conduct Of Business Sourcebook) to market, promote or sell non-regulated investment products to non-sophisticated consumers.
b) The purpose of the FSMA, the relevant law, is to prevent non-regulated parties from conducting these activities and force them to become regulated.
c) THEREFORE, the law, and therefore FCA powers, applies to a greater extent to non-regulated parties than it does even to regulated parties, given that it is these cowboys, scammers and non-regulated firms that the law seeks to prevent from conducting this business.
d) And furthermore, and I refer you here to representations made by The FCA in the Panorama programme and by Steward in this interview, where they said:
"the FCA will not be able to act if an investor had ticked a box saying that they were sophisticated."
FALSE REPRESENTATION. In 2016 The FCA prohibited any firms from accepting 'self certification' by 'tick box' by a consumer as to their 'sophistication'. The FCA from 2016 had demanded that all firms must undertake due diligence and take steps to establish and validate that each and every investor was sophisticated.
To be very clear therefore, Steward and The FCA is relying upon a tick box self certification as a reason that it could not act. A process that The FCA itself had prohibited and deemed entirely unacceptable six years ago!!!!!
I would say that you really couldn't make this crap up, but Steward and The FCA really do.
e) I must further refer you to a letter sent directly to Mark Steward in March 2018 by an FCA authorised professional.
This person highlights significant concerns and reports significant intelligence directly to Steward, including:
Dear Mark I am writing to draw the FCA’s attention to a serious and ongoing breach of FCA regulations which is creating a material risk to consumers. 1) Blackmore Bond plc is an unregulated company issuing corporate loan notes paying up to 8.5% per annum. As a security issued by a special purpose vehicle, their bonds are Non-Mainstream Pooled Investments, and in the absence of regulated advice should only be promoted to high net worth or sophisticated investors (COBS 4.12). 2) Blackmore Bond plc issues financial promotions via social media which do not mention anywhere the risk of 100% losses in its bonds. The promotion uses the term “Income Certainty”, and with phrases like “Knowing how and where to invest your savings doesn’t have to be difficult” and “Simple, fixed-rate returns” is clearly aimed at investors who do not qualify as high net worth or sophisticated. I have enclosed an example, which appeared in my Facebook feed on 7 March 2018.
4) Blackmore Bond plc is run by Phillip Nunn and Patrick McCreesh. Nunn and McCreesh are also the controllers of Blackmore Global, an offshore investment fund. A number of UK investors were encouraged to invest significant sums of their pension funds in Blackmore Global, and this was recently covered by the BBC’s You and Yours – see https://www.bbc.co.uk/programmes/b09pjgdn. Blackmore Global has refused to release audited accounts of its investments, and investors have been told they cannot withdraw their investment.
With no independently audited valuation of Blackmore Global available, no ability to withdraw, and no secondary market for the shares, Blackmore Global must be considered worthless until evidence to the contrary emerges. 5) Patrick McCreesh and Philip Nunn, via the now-dissolved company It’s Your Pension Limited, also provided leads to Jackson Francis who arranged transfers into the fraudulent Capita Oak pension scheme. (See http://pension-life.com/phillip-nunn-scam-year-blackmore-global/ - pension-life.com is less than 100% reliable, however the fact that McCreesh and Nunn provided leads to Jackson Francis comes from the Insolvency Service, and is to my knowledge not in dispute.)
The FCA authorised professional even goes so far as to explain to Steward personally, the powers he and The FCA have and urges them to use them:
However, even if the NMPI issuer was whiter-than-white, it would still be unacceptable for non-HNW and unsophisticated investors to be systematically induced via misleading financial promotions to invest in NMPIs with potential for 100% loss. Points 4) and 5) and the previous involvement of the Blackmore Bond directors in unregulated investments which have caused heavy losses to retail investors merely emphasise the urgency of taking action.
It is clear to me that the FCA needs to act as a matter of urgency by: 1) Ordering Blackmore Bond plc to immediately close to new investment until it can show that it has put in place robust processes to ensure that all of its investors qualify as high-net-worth or sophisticated, or are otherwise exempt from COBS 4.12.3. For example, by only accepting investors via regulated financial advisers, or asking investors to provide bank statements or tax returns as evidence that their assets or income qualify them as HNW. If the FCA lacks the power to do so itself (Blackmore Bond plc being unregulated), it should apply to the courts for an injunction as per section 380.
As per COBS 4.12, “self-certification” is not enough and an NMPI issuer must take reasonable steps to verify that investors are in fact HNW or sophisticated (COBS 4.12.9). Only accepting investors via regulated advisers or asking for bank statements or tax returns is a more than reasonable step to comply with COBS 4.12.9. This is what the SEC explicitly directs firms to do in the US if they are relying on the equivalent exemption in US securities law (see https://www.sec.gov/fast-answers/answers-rule506htm.html), so there is precedent of good practice.
2) Ordering Blackmore Bond plc to pro-actively contact all investors who did not invest via a regulated intermediary or provide documentary evidence of being HNW or sophisticated, remind them of the risk of permanent loss they are subject to in a clear and non-misleading fashion, and offer to immediately return their original investment minus any payments made to date. If Blackmore does not have sufficient liquid funds to do so, administrators should be immediately appointed to wind the company up in an orderly fashion and minimise the risk of loss by retail investors.
The report is concise, clear and spells out the breaches of FSMA and COBS, that puts this squarely in The FCA perimeter, authority and powers, and he even spells out to Steward the very actions The FCA can and should be taking.
Enclosed with this letter was this Facebook ad that the reporter had discovered:
The report to Steward closes with:
If Blackmore Bond does default on its bonds in the future......there is potential for significant damage to the FCA’s reputation should it emerge that it was aware of the systematic promotion of these bonds to retail investors, and took no action that would have prevented further retail investors from investing their money.
f) In my series of reports to The FCA in March 2017 I said the following:
6th March 2017
Their sales spiel is something to behold. "Our Applixation for FCA authorisation is being processed". They are not FCA authorised and laugh between each other when anyone uses that line on a call. "Everything is guaranteed" "I'll put you down as a sophisticated investor"
IMPORTANT: I quite clearly inform The FCA that they are manipulating the sophistication of the consumers that they are pushing this to.
To manipulate the sophistication is a significant offence under FSMA and FCA COBS, and particularly because it has but one intent, and that is to circumvent FSMA and FCA COBS, and the prohibition to market and sell to non-sophisticated consumers.
7th March 2017
John, Please stress to whomever you pass the Amyma info to that pensioners are clearly being targeted. It's not just a Boiler shop issue but activity related to misleading pensioners, vulnerable under the new rules.
g) I escalated all of these reports to Mark Steward and Andrew Bailey personally in August 2018, and included the following:
Myself and my team all personally witnessed and heard each of their phone calls with ‘clients’. The majority were clearly cold calls, and the majority clearly persons that were not sophisticated and they were clearly targetting pensioners and their pensions, all contrary to their website and FCA codes and applicable regulations.
Again, all evidence to prove that Blackmore Bond was being marketed and sold to non-sophisticated consumers, pensioners and that their sophistication was being manipulated .
All of which is firmly within The FCA perimeter, authority and powers and Steward, Bailey and The FCA did ..... nothing.
This brings on to the other evidence proving that Steward and The FCA are making false representations.
5. I submitted an FOI (Freedom of Information) request to The FCA in 2022. I received The FCA response and it was authored by Steward himself.
I had asked:
Please explain the FCA's protocol when it receives reports and/or evidence from victims and/or consumers, and/or witnesses and/or experts, and/or FCA authorised persons or firms, in respect to any alleged 'wrongdoing', that The FCA determines is beyond its perimeter, authority and/or powers.
Steward writes that they would
"signpost the provider to the relevant appropriate agency"
FOR THE RECORD AND AVOIDANCE OF DOUBT, The FCA never 'signposted' me to any other agency in either March 2017, August 2018 or august 2019 in response to any of my reports. Had they done so and told me it was beyond their perimeter, authority and powers, I would have reported it to the relevant agency.
The reason they did not signpost me elsewhere was because they knew it was within their perimeter, authority and powers and were investigating.
Instead, in March 2017, The FCA told me in writing they were escalating it to the relevant department.
In September 2018 Steward personally writes to me saying:
"We have received reports about Amyma’s activities, and are making enquiries"
And in August 2019 Steward personally writes to me saying:
"We are aware of these matters which are the subject of ongoing work on our part.
5.1 Steward personally writes to me twice, a full year apart, confirming on both occasions that they are investigating Blackmore Bond and Amyma. They spent at least a year investigating something that they later claimed was beyond their perimeter and powers? Come on. It's as embarrassing as it it false.
5.2. I also have hundreds of internal FCA documents proving that The FCA was investigating Blackmore Bond. Further proving the they knew this was within their perimeter and powers.
6. Let's look at the FCA's explanation as to why there were 'crossed out' conclusions within the draft copy of The FCA complaint response to me. A letter dated October 2020, and that was the result of a 13 months investigation by The FCA expert that produced these conclusions.
I have substantial internal FCA records showing the extent of his investigation.
The FCA expert investigator concluded that not once but twice:
"I consider there was a missed opportunity to reconsider, and act on, the intelligence you provided"
I include an extract from the hard copy of this letter below.
6.1 However, this letter with these final conclusions was never sent to me.
Instead, this investigator was hauled off of the complaint and replaced with someone else, and these conclusions were whitewashed out of the final response this new person would produce a year later.
The FCA seek to justify this by claiming that they they received 'new information' AFTER these conclusions were produced, and that's why they were changed.
IMPOSSIBLE and false! There is no new information that could possibly alter those findings.
What possible information could they have received almost four years after my initial reports and more than two years into their own investigation that would mean they did not drop the ball by failing to act on my reports and intelligence?
7. And finally I refer you to the following:
a) The FCA took action in respect to a non-regulated investment scheme being run by non-regulated parties and firms
FCA is currently in Court suing solicitors that were involved.
b) 2018 FCA Fraud prosecutions
I refer you to the fraud convictions secued by the FCA in 2018. Details of this can be found here:
None of the individuals or companies that these individuals setup or worked for were ‘authorised or regulated’, and they sold non-regulated investment products.
And clearly The FCA HAD the powers and authority to act and did.
Indeed, Steward even says in that press release:
Commenting on the case, Mark Steward, Executive Director of Enforcement and Market Oversight at the FCA, said:
“These fraudsters callously targeted investors who were often elderly and vulnerable, lying to them to get them to part with significant sums of money. Despite efforts to conceal and destroy evidence, the FCA, in one of its largest ever investigations, was able to ensure that these criminals faced justice and ended up behind bars.
Applications under Proceeds of Crime legislation remain on foot and the FCA is determined to recover as much money from these defendants as possible for the benefit of investors.”
In a separate press release on another case where The FCA took action against non-regulated parties selling non-regulated investments to non-sophisticated customers, Steward himself says this:
“The FCA again reminds consumers not to invest in schemes being offered by firms that are not authorised by the FCA and that look too good to be true, like these ones.”
And referred to the FCA taking action… ‘
…….before it inevitably collapsed’
Importantly, Steward, like me and any other financial professional, knew that ‘too good to be true = inevitable collapse’ and says so in that press release.
This PROVES beyond question that he and The FCA knew the Blackmore Bond was a scam or fraud in 2017 because it was clearly 'too good to be true'.
Or is Steward claiming that he and The FCA believed Blackmore Bond to be the exception to the rule? Of course he's not.
The Bottom line is quite clear. The FCA knew everything about this was within their perimeter, authority and powers and spent at least two years investigating it prior to the collapse.
Upon the collapse, The FCA dishonestly sought to claim otherwise so as to conceal their failures in 2017 and their subsequent dishonesty since, and with intent to save their reputations, and avoid having to pay compensation for their catastrophic failures and subsequent dishonesty.
Dishonesty that Steward and The FCA has sought to further this week by way of false and misleading representations in the Panorama programme and by Steward in this interview with the Times.
It is time for the Government to act, to compensate victims and investigate The FCA, Mark Steward, Nikhil Rathi and Andrew Bailey, and the role, failures and 'integrity' of the COLP and Insolvency Service in this and other cases.