Why Would The #Brexiteers Lie?

Follow the money. 

Years of low interest rates have made investors desperate for higher returns, and volatile markets mean lots of big ups and downs, like the rollercoaster ride we've seen since the Brexit vote and are likely to see for many years as a result. Movement either way is an opportunity for speculators to make money, even if the longer term trend is down. And paying rock-bottom prices for UK assets could mean good profits can be made selling them to predatory trade partners in the future. 

At any rate, steady as she goes won't cut it for the wealthy investor - which is why "strong and stable" is just another #Brexiteer lie. After all, the wealthy don't have to live in Britain when the going gets tough.

So this is why the Leave campaign was largely funded by 5 wealthy financial investors, and why after the Brexit vote, George Osborne knew it was best to leap into an investment fund manager. 

And now that Brexit is hitting the buffers, guess what? Legatum, the Tory's hard-Brexit stupidity "think" tank has received £4m from a wealthy investor from New Zealand who Private Eye says made his money "by finding undervalued assets the rest of market ignored – “transition economies or distressed sectors where information is not easily available and standard metrics don’t apply”.

It's still unclear where the so-called "Institute for Free Trade" got its money, but it has similar hallmarks to the other Brexiteer stunts.

Meanwhile, the same Brexiteers are charging 55p a minute for benefits recipients to call the Universal Credit helpline... never mind that it's illegal for debt collectors to do so.

Make no mistake: Brexit is for a few, not the many who are unwitting pawns in their game. 

Are Retailers Prepared For Financial Regulation From 13 January 2018?

Three years after being announced in the UK and I suspect many retailers are still yet to realise that their loyalty/store card programmes will be regulated by the Financial Conduct Authority from 13 January 2018 - likewise across the European Economic Area. 

As the FCA now also explains, retailers who offer such programmes anywhere in the EEA will need to track the annual transaction volumes very carefully, starting with the completely arbitrary and inconvenient date of 13 January 2018. 

If the volume meets or exceeds €1 million (or the GBP or local currency equivalent) in any 12 month period (the first ending on 12 January 2019), the retailer must notify the FCA (or local regulator) within 28 days (by 10 February 2019).  Firms may also choose to register at any time from 13 October 2017.

But be sure of the outcome before you decide whether or not to register!

The regulator must then decide whether the programme is exempt from regulation as an e-money/payment service.  

If the firm fails to notify, it commits an offence under the Payment Services Regulations 2017 (or local equivalent implementing the second Payment Services Directive (PSD2)). 

If the FCA decides the programme is exempt, then it must include the retailer on the FCA's register of 'limited networks', and the name will be added to a central register of all such firms across the EEA.

If the FCA decides the programme is not exempt from regulation the retailer can appeal, but basically this means the firm will have been found to be violating the Electronic Money Regulations 2011 and/or Payment Services Regulations 2017 by issuing e-money and/or offering a payment service without being duly authorised/registered to do so. Major problem!

So retailers really have to decide now whether they should outsource the operation of the programme to an authorised firm (or the agent of one); or seek their own authorisation (or agency registration). Ultimately, they might restructure the scheme to fit the exemption, or shut it down.

Of course, the mere fact that retailers with loyalty schemes have to be mindful of these requirements and go through the process means they are in effect regulated by the FCA. Ignorance, as they say, is no defence.