icm2re logo. icm2:re (I Changed My Mind Reviewing Everything) is an 

ongoing web column edited and published by Brunella Longo

This column deals with some aspects of change management processes experienced almost in any industry impacted by the digital revolution: how to select, create, gather, manage, interpret, share data and information either because of internal and usually incremental scope - such learning, educational and re-engineering processes - or because of external forces, like mergers and acquisitions, restructuring goals, new regulations or disruptive technologies.

The title - I Changed My Mind Reviewing Everything - is a tribute to authors and scientists from different disciplinary fields that have illuminated my understanding of intentional change and decision making processes during the last thirty years, explaining how we think - or how we think about the way we think. The logo is a bit of a divertissement, from the latin divertere that means turn in separate ways.

Chronological Index | Subject Index

Changing minds: can open data deter finance professionals from misleading customers?

About the corruption of and the systematic errors made by approved persons

How to cite this article?
Longo, Brunella (2015). Changing minds: can open data deter finance professionals from misleading customers? About the corruption of and the systematic errors made by approved persons. icm2re [I Changed my Mind Reviewing Everything ISSN 2059-688X (Print)], 4.10 (October).

How to cite this article?
Longo, Brunella (2015). Changing minds: can open data deter finance professionals from misleading customers? About the corruption of and the systematic errors made by approved persons. icm2re [I Changed my Mind Reviewing Everything ISSN 2059-688X (Online)], 4.10 (October).
Full-text accessible at http://www.brunellalongo.co.uk/

London, 28 December 2015 - The amount of data accessible through open sources is immense and yet to support whatever decision making process with information available in the public domain you need time, energy, skills and money. The alternative is, inevitably, to trust people around you and to follow the advice you are given by social workers, legal advisers, experts, consultants in various fields and what the financial authorities call "approved persons".

Who is who and the data trade off

In fact, to search, compare, collate and curate your own data means above all to be able to detect and skip the massive quota of falsehood and misreprentation that is produced and shared for all sorts of reasons, including frauds and cybercrime, in the public domain. In this respect, the identity criteria remains the most important aspect of any credibility assessment in any field.

Possible patterns of negligence, victimisation and suspicious activities can be easily spotted at first through historical archives and chronological lists or logs of events. This is exactly what everybody is not so keen to make easily accessible and it is currently fuelling great expectations from big data software developments. The manual alternatives are costly and time consuming.

When I decided to move my stakeholder pension money from Intesa Previdsystem to a Cater Allen "equivalent" product in 2012 I had no time to search and thoroughly assess anything. I had been made homeless, I was not receiving any benefit, it was impossible to care about myself and my dog, my furniture and belongings and above all I had no 4G internet connection. The very modest smartphone and computing capabilities did not allow me to search extensively any of the numerous resources I knew could provide excellent data.

Instead, I stuck with my plan, still trusting that I could buy my flat from either Mrs Brennan or Freshwater (the freeholder who turned out not to be aware the flat had been let out and even offered on sale) as I had already done before three times in my life, using savings to access a mortgage. I asked the bank I was a customer of, Santander, to advice on the best way to sort out the problem of a pension scheme not accepted as a guarantee on the UK market since it was in EURO. According to its terms and conditions and to the italian law, I could convert it in cash or exchange for a mortgage to buy a home but that would require me first of all to transfer it in an equivalent UK based regulated scheme. The solution I was pointed to was a EURO bank account for self invested private pensions provided by Cater Allen private bank part of Santander.

Missing data and decision making processes

If I had my "normal" access to the internet and various business, news and company information databases, I would have easily discovered some disturbing news about Cater Allen: these had surely influenced and at least delayed in a very savvy and useful way, if not completely halted, my decision to authorise the transfer.

First of all, I would have discovered that since 2001-2002 and intensively again from 2010 on, Cater Allen was aggressively publicising the offering of an account that would "allow to switch money between dollar, euro and sterling accounts free of charge". A bit of critical light would have immediately turned on reading about something offered free of charge in the world of currency exchanges.

Secondly, I would have learned of a scandal investigated since 2005: in 2009 a gang was sentenced at Nottingham Crown Court for bank fraud worthing over 1 million pound perpetrated between 2005 and 2006. The gang accessed Cater Allen bank accounts cracking customers personal codes after a former employee at Cater Allen in Sheffield, a certain Ansir Khan, had stolen customers' information ciphering their data with a rudimental coding system. A corrupt PC from Birmingham, Charles Fletcher, was also part of the gang sharing data with companies available to launder the money, namely RMI Ltd and York Synthetics. Khan was also found guilty to engage with career fraudsters in South London (in Croydon and Bromley) passing them Cater Allen documents.

All in all, knowing of an extensive net of relationships built by a Cater Allen corrupt employee in Sheffield - and with nodes across the Country, and possibly also internationally, and with accomplices in Scotland Yard and in the business sector all abusing of customers personal data - would have made me very suspicious about the appropriateness for myself to choose the bank for my own operations. In sum I would have not trust their ultimate parent advice straightway.

In fact, I had had my own personal details abused in different contexts in 2009-2010. All my italian ID were stolen in 2010 and I had also reported to the Information commissioner office and to other professional contacts active across England and Wales, including the Sheffield area, such incidents without any particular reassurance or compensation. I knew I had more probabilities to become a target than other people making the same choice.

Thirdly, I would have also learned that in 2004 another embarrassing and arguably legitimate experiment had come to an end when Abbey National, Cater Allen owner since 1997, then bought by Santander in 2004, accepted a last minute settlement for a 30 million pound claim against the bank made from investors in Jersey over a get-rich-quick currency scheme, sold through a sort of sophisticated ponzi scheme network of vendors since 1992/1993 and involving hundreds of investors. This case, with absolutely no particular reason but a simple association to uncertainty matters, would have scared me enough because the freeholder of my promised apartment, Freshwater, had quite opaque offshore activities and links to Jersey. No matter the rational, when you are already suspicious enough about something wrong, whatever reminds you the wrong is inevitably... wrong.

And finally, less emotionally, I would have wished to investigate further the fact that after the launch of an execution-only, telephone account and share-dealing service in 2001 Cater Allen's communication about its interest rates started to make customers, independent journalists and advisers raising an eyebrow because of its deceptive high figures and even more deceptive small prints all around the City and beyond. They had closed down several call centers in the UK and abroad and concentrated in Sheffield and Bradford many operations, disappointing at the same time employees and expatriate clients as well as new affluent and rich immigrants. I would have possibly concluded that a former "independent" 180 years old discount house with an extensive network of relationships in the City, including those with the Treasury, the Bank of England, several stockbrokers and with Lloyd's of London, that had been sold to Santander in 2004 and was operating through Royal Bank of Scotland and attracting attention by gangs of fraudsters around the Country would not be the safe place for me to transfer my thirty years hard work savings managed by a regulated italian self invested private pension scheme provider.

Or, would I have trusted the diligence of Cater Allen "approved persons" all the same?

Approved persons' portfolios can be open data too

"Approved persons" are defined by the Financial Conduct Authority (FCA) according to principles and fitness to operate in controlled functions (executives, directors) that require sound mind and integrity, beside understanding and application of rules, law and codes of conduct.

In a nutshell, as the same FCA states, "an approved person must act with due Skill, Care and Diligence in carrying out his/her controlled function" (https://www.the-fca.org.uk/approved-persons). The principles and Code of Practice for Approved Persons are published at https://www.handbook.fca.org.uk/handbook/APER/. Besides a number of technicalities and distinctions, the ultimate scope of such rules is making sure that customers of financial services are not misled, deliberately or because of negligence.

After I was discharged from the bizarre bankruptcy order in 2014, I discovered that the appointed trustees paid fictitious debts, "automatic" charges (like Secretary of State fees) and fabricated invoices from third parties wiping out my stakeholder pension. A perfect extortive machine. They also presented completely inconsistent and false documents, acting according to a pattern of abuse, mockery and libel that reminds a sort of dilapidating and symbolic ritual.

Have the appointed trustees been served? I asked myself.

The administration of the bankruptcy was initially care of a certain Marina Bray, manager at Smith & Williamson's Winchester office and acting on behalf of one of the joint appointed trustees, Paul McConnell. The other joint appointed trustee, Finbarr O'Connell, was based in London.

We met at Smith & Williamson London office in June 2013. After that meeting, there was almost no question and no interaction at all for the entire year of the bankruptcy but for my detailed disclosure to Mr O'Connell and Ms Bray of all the particulars of the missed conveyance case (and its numerous collaterals) the bankruptcy was the appallingly unjust and disastrous conclusion of.

Any day by day expense related to work and financial matters was also documented with periodic and possibly pedantic updates by my side via post, phone, email.

Since the first day of their appointment, I confirmed all the data related to my self invested personal pension already passed to the Insolvency Service: I had transferred it from an italian regulated scheme to an UK pension scheme provider, in order to access a mortgage in GBP to buy the same flat that the bankruptcy petitioner, a Ms Suzanne Brennan, was not legally entitled to sell. The terms and conditions of the italian scheme allowed me to do that. I had been assured by Santander first and then by their private bank Cater Allen soon after that I could use a EURO savings account explicitly provided by Cater Allen for self invested private pensions in an equivalent manner.

The transfer of the money had to pass through an intermediary product in order to be converted from EURO into GBP. So far, so clear for everybody but I had not been able to sign up any further deal with a UK based regulated scheme because meanwhile Ms Brennan had filed a petition for bankruptcy, with very syncronised timing.

Smith & Williamson stated in writings in a couple of occasions that my Cater Allen account was not considered "linked" to a pension scheme (and also the provenience of the money from an italian regulated pension scheme provider was possibly considered suspiciously because the money came into Cater Allen bank account just few weeks before the bankruptcy order was made in the CLCC from where, by court officers mistakes in handling documents templates, it was at first gazetted as made in the High Court so that it appeared as a case involving a major business insolvency case and not the disgraceful end of a libelled single individual attempt to buy a home).

Both Bray and McConnell left Smith & Williamson and the Winchester office was closed during the summer of 2014, after the bankruptcy discharge. Any residual activity related to my bankruptcy was transferred to their Bristol office where I was told I could liaise to a certain Luke Williams for any question.

But there was no answer: as soon as I asked to move my stakeholder pension money into the regulated UK pension scheme I was eventually able to sign up and should have been "linked" to the Cater Allen account following the discharge, Mr O'Connell wrote me they needed more time before deciding to bring the bankruptcy administration to a closure, because they had to investigate the fact that a property linked to myself and my bankruptcy case was showing up in the Land Registry (hence my rectification claim I wrote about in another occasion).

They also confirmed that they had accessed my self invested private pension.

Mr Williams was said to have left the office soon after, the remaining appointed trustee Finbarr O'Connell refused to put the administration to an end, I applied to the Court for having my personal details rectified in the Land Registry and few months later for the annulment of the same bankruptcy.

A solicitor appointed by Smith & Williamson to represent the firm at the hearing of my annulment application, became the new substitute appointed trustee.

Eventually, Smith & Williamson released a final account of the bankruptcy, closing at zero, that is the most ridiculously false piece of accounting documentation I have ever seen, providing a number of inventive ways to justify the fact that all my money had been simply wiped out (see the Receipts and Payments Account p. 1 of the Appendices of the final progress report dated 15 April 2015).


If these are approved persons, I thought, I should be a nobel prize.

But they did not act alone. On the contrary, the role of the Insolvency Service and above all the responsibility of Cater Allen private bank part of Santander in wiping out my stakeholder pension were pivotal.

According to the Financial Services Register (provided by the Bank of England's Prudential Regulation Authority at https://register.fca.org.uk/) Cater Allen has been operating through different companies since 1991 and other two groups, Barclays and Santander. You have to search Wikipedia or other general and specialistic sources, including newspapers articles, to learn that the story of the bank goes back two hundred years and its management has been deeply intertwined with all the City and Country institutions since then.

The same Financial Services Register shows you that it has had various lines of business, national and international, professional and consumer from 1991 on. Two configurations are no longer authorized whereas an authorization to operate as a consumer brand (not just for intermediaries) has come up - fancy coincidence - after my bankruptcy case.

These are the data you find in the FCA Register as of today, 28 December 2015:

  1. Firm reference number 148467 no longer authorised - Cater Allen International Limited NW1 3AN
    • regulated by the FSA between 01/12/2001 and 14/02/2011 
    • regulated by the Securities And Futures Authority between 03/05/1991 and 30/11/2001 
  2. Firm reference number 178737 authorised Cater Allen Limited NW1 3AN, previous names / trading with names Cater Allen Bank, Cater Allen Private Bank, Cater Allen Professional, Sheppards Moneybrokers, IVOP issued in 2014-2015
    • regulated by the Financial Conduct Authority  from 01/04/2013 
    • regulated by the Financial Services Authority  from 01/12/2001  to 31/03/2013  
    • regulated by the Prudential Regulation Authority from 01/04/2013  
    • regulated by the Securities And Futures Authority from 01/01/1996 to 30/11/2001  
    • firm reference number 204886 NW1 6XL - Cater Allen Syndicate Management Ltd, regulated by the Financial Services Authority from 01/12/2001 to 03/10/2003 and by the The Society Of Lloyd'S between 7/05/1991 and 03/10/2003 
    • firm reference number 154210 - Abbey Stockbrokers Limited regulated by the Financial Conduct Authority from 1/4/2013 on and by the Financial Services Authority between 01/12/2001 and 31/3/2013, by the Securities and futures authority between 27/07/1992 and 30/11/2001.

All the details given through the above data describe the relationship between the brand and the Financial authorities but unfortunately this is the less relevant, from a consumer perspective, among the relationships between a private bank and the institutions and stakeholders it responds and reacts to over the times and you may wish to be aware of.

Nothing would technically impede the Financial authorities to acquire, curate and publish further contextual, commercial and historical data related to the portfolios of products and services the same Register refers to, including complaints, litigations, settlements and compensation cases and changes of management. All these data either on an individual search basis or as aggregated analytics can document the story of a regulated bank or a financial product or brand and the activities of all the approved persons that care for it.

In showing off their skills, care, diligence and above all their errors, approved persons could have a chance to lead the fight against frauds, pillories, disinformation and medieval rituals instead of becoming instruments of "cybercrime as a service".