Tag: fca

  • FCA delays publication of politically uncovered individuals report – Home loan Tactic

    The Monetary Perform Authority has pushed again the publication of its overview into the therapy methodology of politically uncovered individuals till lastly after the usual election.  

    The outcomes from the analysis ended up as a result of of to be launched in keeping with the end of June deadline in accordance with the Money Companies and Marketplaces Act.  

    But this is able to have seem forward of the 4 July nationwide ballot.  

    Having stated that, the FCA claims it could not be “acceptable” to publish the consider within the pre-election interval of time and can now be posted afterwards in July when Parliament has returned.

    The critique was launched final calendar yr subsequent a row between populist ideal-wing politician (now chief of the Reform celebration) Nigel Farage and NatWest’s Coutts arm across the closure of his account by the loan firm.  

    The aftermath of the affair led to the resignation of NatWest important authorities Alison Rose earlier July, then essentially the most spectacular feminine in Uk banking, quickly after she admitted speaking about Farage’s relationship with the monetary establishment to the media.  

    NatWest confirmed Paul Thwaite as its up coming full-time important govt in February. 

  • FCA slaps £6.2m fantastic on HSBC around cure of buyers in arrears – Mortgage loan Technique

    The Financial Perform Authority (FCA) has fined HSBC United kingdom Financial establishment £6.28m for failures in its remedy methodology of shoppers who had been in arrears or coping with financial issue.

    The regulator talked about that regarding June 2017 and Oct 2018, HSBC didn’t accurately think about folks’s conditions once they had missed funds. This meant it didn’t typically do the appropriate affordability assessments when coming into preparations with folks at this time to lower or apparent their arrears.

    Occasionally it took disproportionate movement when folks at this time fell powering with funds, which risked people discovering into higher economical issues.

    The failings had been triggered by deficiencies in HSBC’s insurance coverage insurance policies and methods and the coaching of their staff, as correctly as insufficient measures to ascertain and sort out circumstances of unfair shopper treatment.

    In 2018, HSBC acknowledged that there have been troubles with their coping with of buyers in cash issue and notified the FCA. HSBC invested £94m in figuring out the difficulties and placing them acceptable. HSBC additionally issued redress funds totalling £185m to about 1.5 million prospects.

    FCA’s joint authorities director of enforcement and market oversight Therese Chambers reported in a assertion: “People have to be able to belief their loan suppliers to deal with them fairly when in monetary challenge. By failing to take action, HSBC set 1.5 million people at menace of increased cash injury.”

    She extra: “It deserves credit score for figuring out the problem and placing it correct. The value it has incurred in executing so, nevertheless, have to be a warning to all loan suppliers that they should have to grasp their clients’ circumstances in order to not make a poor state of affairs even worse.”

    The FCA took HSBC’s remediation and redress programme under consideration when setting its nice. HSBC additionally agreed to settle the case and succesful for a 30% low value to the economical penalty imposed, which might in any other case have been £8.97m.

  • FCA strategies to make United kingdom ‘the best location to do business in the world’   – Home finance loan Method

    The head of the Economical Carry out Authority mentioned it is “working tough to make the United kingdom the splendid location in the earth to do business enterprise.”  

    Main govt Nikhil Rathi included: “We actually do not simply make the rules, we assist situation the ecosystem and really long-time interval chance starvation that firms function with.”  

    The head of the Metropolis regulator laid out the agenda of the watchdog in extra of the remainder of the yr and past at the once-a-year conference of the Affiliation of Company Treasurers yesterday.  

    Nevertheless, his speech comes as the watchdog has locked horns with the Town and the Chancellor greater than its proposals to ‘identify and disgrace’ firms lower than investigation.    

    Very final 7 days, the total physique promised to “have interaction additional extra with business” greater than the technique, which it thinks is in the public want.  

    On the different hand, earlier than this month 16 City groups reported the plan may hit the valuations of corporations and “destabilise financial markets”. Jeremey Hunt urged the regulator to “re-look” at its proposals.        

    In a broad-ranging speech previous evening, Rathi said the FCA would “at all times purchase a realistic strategy”.  

    Last 12 months ministers gave the physique a secondary aim to assist enhance United kingdom growth and elevate the intercontinental competitiveness of the British financial system over the medium to prolonged-time interval.  

    To that cease, the FCA head mentioned the physique was trying at benchmarks for crypto, AI and different areas.  

    Also, he included that internet lending from non-banking establishments has jumped by throughout £425bn over the earlier 15 yrs.  

    Rathi identified: “Much of the progress has taken place whereas fascination prices have been minimal. Therefore, vulnerabilities may be uncovered by the adjustment to higher curiosity costs and the reworking macro-money environment.  

    “For instance, non-public finance valuations have been lower than pressure, and funding and exit routes have develop to be far tougher.   

    “I’ve made clear that the response is just not to attain rapidly for the regulatory cudgel. And I would love to see way more proof forward of we declare we’ve got a systemic state of affairs in the private finance sector.”  

    The regulator reported it is at the moment supporting the Lender of England with its stress testing on banking publicity to private fairness hazard.  

    Rathi additional that the FCA is enterprise its private function on valuation methods in the fund discipline, which is able to embrace “a multi-organization critique analyzing valuation techniques for personal property,” that will function till the conclusion of the calendar 12 months. 

  • FCA promises further talks over ‘name and disgrace’ proposals     – Mortgage Strategy

    The Financial Conduct Authority has promised to “interact further with business” over its controversial plan to ‘title and disgrace’ corporations beneath investigation.  

    The City watchdog outlined proposals earlier this 12 months to launch the title of companies beneath investigation if it believes it’s within the public curiosity.  

    But earlier this month the Chancellor and a spread of City our bodies referred to as on the regulator to scrap the plan, saying the measure may hit the valuations of companies and “destabilise monetary markets”.        

    The FCA’s government director, markets and government director, worldwide Sarah Pritchard mentioned she recognised the transfer was “a delicate and emotive subject,” in a speech throughout TheCityUK’s City Week this morning.  

    Pritchard added: “I do know there have been considerations about our proposals to announce the very fact of some enforcement investigations earlier on within the course of the place it’s within the public curiosity to take action.   

    “We recognise that this can be a delicate and emotive subject so we are going to take time to contemplate the suggestions, interact further with business and discover totally the considerations and proof shared with us, with an goal of reaching a broad consensus.  

    “Be assured that we do pay attention. We are evidence-led so will solely act the place a failure to take action would trigger hurt to shoppers and undermine the integrity of our markets.”  

    She identified: “Input from the market as we design our future-facing guidelines is key to avoiding unintended penalties or worse, taking a hammer to crack a nut.   

    “Confidence out there is crucial, underpinned by a transparent regulatory regime.”  

    The FCA says the transfer will enhance transparency, encourage whistleblowing and enhance the deterrent impact of the watchdog’s probes, which on common final three to 4 years.    

    Earlier this month, FCA chair Ashley Alder advised the Treasury Committee: “In reality, we weren’t anticipating such a stern response that has come from the business.”  

    The transfer by the regulator comes after it and the Prudential Regulation Authority got new competitiveness and progress targets by ministers final 12 months.        

    But earlier this month, in a uncommon intervention in regulatory affairs, Chancellor Jeremy Hunt mentioned: “Last 12 months the legislation modified within the monetary providers market and [the FCA] have a secondary progress obligation.       

    “On the premise of that, I hope they re-look at their ‘naming and shaming’ resolution as a result of it doesn’t really feel according to that new secondary progress obligation that they’ve.”  

    Also, earlier this month, it emerged that 16 finance commerce our bodies — together with UK Finance, The Investment Association and TheCityUK — wrote to the Chancellor asking him to intervene.      

    “Firms imagine that the proposals can have a damaging influence on their valuation, may put in danger the wellbeing of people, and have the potential to destabilise monetary markets,” the associations mentioned within the letter to the Chancellor.    

    Other UK regulators — comparable to these in competitors, water and vitality — typically title companies which are beneath investigation earlier than deciding on whether or not they have breached any guidelines.    

    However, this measure isn’t used by worldwide monetary providers regulators such because the US Securities and Exchange Commission and Germany’s BaFin.   

  • FCA pledges further City talks over ‘name and disgrace’ plans     – Mortgage Finance Gazette

    The Financial Conduct Authority has promised to “have interaction further with trade” over its controversial plan to ‘identify and disgrace’ corporations beneath investigation.  

    fca2-508x330.jpg

    The City watchdog outlined proposals earlier this yr to launch the identify of companies beneath investigation if it believes it’s within the public curiosity.  

    But earlier this month the Chancellor and a spread of City our bodies known as on the regulator to scrap the plan, saying the measure may hit the valuations of companies and “destabilise monetary markets”.        

    The FCA’s govt director, markets and govt director, worldwide Sarah Pritchard mentioned she recognised the transfer was “a delicate and emotive subject,” in a speech throughout TheCityUK’s City Week this morning.  

    Pritchard added: “I do know there have been issues about our proposals to announce the very fact of some enforcement investigations earlier on within the course of the place it’s within the public curiosity to take action.   

    “We recognise that it is a delicate and emotive subject so we are going to take time to think about the suggestions, have interaction further with trade and discover totally the issues and proof shared with us, with an purpose of reaching a broad consensus.  

    “Be assured that we do hear. We are evidence-led so will solely act the place a failure to take action would trigger hurt to shoppers and undermine the integrity of our markets.”  

    She identified: “Input from the market as we design our future-facing guidelines is key to avoiding unintended penalties or worse, taking a hammer to crack a nut.   

    “Confidence available in the market is crucial, underpinned by a transparent regulatory regime.”  

    The FCA says the transfer will increase transparency, encourage whistleblowing and improve the deterrent impact of the watchdog’s probes, which on common final three to 4 years.    

    Earlier this month, FCA chair Ashley Alder informed the Treasury Committee: “In fact, we weren’t anticipating such a stern response that has come from the trade.”  

    The transfer by the regulator comes after it and the Prudential Regulation Authority got new competitiveness and development targets by ministers final yr.        

    But earlier this month, in a uncommon intervention in regulatory affairs, Chancellor Jeremy Hunt mentioned: “Last yr the legislation modified within the monetary providers market and [the FCA] have a secondary development obligation.       

    “On the idea of that, I hope they re-look at their ‘naming and shaming’ determination as a result of it doesn’t really feel in keeping with that new secondary development obligation that they’ve.”  

    Also, earlier this month, it emerged that 16 finance commerce our bodies — together with UK Finance, The Investment Association and TheCityUK — wrote to the Chancellor asking him to intervene.      

    “Firms consider that the proposals could have a detrimental impression on their valuation, may put in danger the wellbeing of people, and have the potential to destabilise monetary markets,” the associations mentioned within the letter to the Chancellor.    

    Other UK regulators — similar to these in competitors, water and vitality — usually identify companies which might be beneath investigation earlier than deciding on whether or not they have breached any guidelines.    

    However, this measure isn’t used by worldwide monetary providers regulators such because the US Securities and Exchange Commission and Germany’s BaFin.   

  • FCA surprised by ‘stern’ reaction to identify and disgrace proposals  – Home loan Technique

    The Economical Conduct Authority was surprised on the “stern reaction” to its plan to ‘identify and disgrace’ organizations beneath investigation — however will select “a number of months” earlier than choosing regardless of if to push forward with the switch.  

    “In actuality, we weren’t anticipating this kind of a stern response that has arrive from the enterprise,” stated FCA chair Ashley Alder, speaking to the Treasury Committee yesterday.  

    The meeting comes instantly after the Chancellor and a collection of Metropolis our bodies recognized as on the regulator to scrap this system, stating the consider may hit the valuations of corporations and “destabilise financial markets”.    

    Having stated that, Alder claimed the go goals to increase transparency, encourage whistleblowing and improve the deterrent affect of the watchdog’s probes, which on common final three to 4 a few years.  

    Other British isles regulators — a lot of these as these individuals in ranges of competitors, water and electrical energy — often identify corporations which are beneath investigation forward of deciding on whether or not they have breached any guidelines.    

    However, this measure isn’t used by intercontinental monetary companies regulators such because the US Securities and Exchange Fee and Germany’s BaFin.    

    But FCA most important authorities Nikhil Rathi instructed the Treasury Committee that the regulator will take “a number of months” to decide whether or not to transfer forward with its system instantly after talks with the economical corporations market, purchaser groups and whistleblowing advertising marketing campaign our bodies.  

    Rathi talked about the system has stepped up investigations into 27 listed, regulated and unregulated companies within the current economical yr.  

    He further that in a single case it has been speaking to an unnamed agency for just a few a few years, and all through that time the group has produced a assertion confirming that it’s beneath investigation in quite a lot of overseas marketplaces.   

    A amount of abroad regulators have at the moment opened group probes into this enterprise, Rahti extra.  

    The FCA chief govt stated: “This group has fairly just a few million Uk buyers. This is the type of case the place we might properly need to validate that an investigation is underway.”  

    He further: “We will get our time over this proposal to ensure that we get it ultimate.”  

    Rathi suggested the Treasury Committee that of the 27 circumstances he talked about the watchdog may need to publicise the probes of three even additional corporations.  

    The FCA most important govt defined that the watchdog already has the electrical energy to identify corporations lower than investigation however solely beneath “distinctive circumstances”.  

    The switch by the regulator arrives simply after it and the Prudential Regulation Authority ended up provided new competitiveness and progress targets by ministers closing calendar 12 months.      

    But final week, in a peculiar intervention in regulatory affairs, Chancellor Hunt stated: “Last 12 months the regulation adjusted within the economical knowledgeable companies market and [the FCA] have a secondary improvement obligation.     

    “On the premise of that, I hope they re-glance at their ‘naming and shaming’ determination because it doesn’t really feel common with that new secondary enlargement obligation that they’ve.”    

    It additionally emerged earlier week that 16 finance commerce our bodies — like United kingdom Finance, The Investment Affiliation and TheCityUK — wrote to the Chancellor asking him to intervene.    

    “Firms really feel that the proposals could have a detrimental have an effect on on their valuation, may place in danger the wellbeing of people, and have the chance to destabilise economical marketplaces,” the associations stated within the letter to the Chancellor.    

  • FCA stunned by marketplace backlash to ‘title and disgrace’ plan – Mortgage loan Finance Gazette

    The Monetary Conduct Authority was shocked on the “stern response” to its strategy to ‘title and disgrace’ suppliers beneath investigation — however will get “a number of months” upfront of figuring out no matter whether or not to push forward with the shift.  

    fca2-508x330.jpg

    “In truth, we weren’t anticipating this type of a stern response that has come from the market,” defined FCA chair Ashley Alder, talking to the Treasury Committee yesterday.  

    The convention comes instantly after the Chancellor and a wide range of Town our bodies recognized as on the regulator to scrap the put together, stating the measure may hit the valuations of corporations and “destabilise financial markets”.    

    Having stated that, Alder defined the go goals to elevate transparency, stimulate whistleblowing and elevate the deterrent impact of the watchdog’s probes, which on common final three to 4 yrs.  

    Other British isles regulators — this form of as individuals in stage of competitors, h2o and energy — usually title corporations which are beneath investigation prior to deciding on whether or not they have breached any insurance policies.    

    Nevertheless, this measure is seldom used by worldwide financial corporations regulators this type of because the US Securities and Trade Commission and Germany’s BaFin.    

    But FCA chief govt Nikhil Rathi knowledgeable the Treasury Committee that the regulator will take “a number of months” to decide whether or not to transfer forward with its plan after talks with the economical suppliers enterprise, shopper groups and whistleblowing advertising and marketing marketing campaign our bodies.  

    Rathi reported the physique has stepped up investigations into 27 said, regulated and unregulated corporations within the present-day cash 12 months.  

    He added that in a single case it has been conversing to an unnamed company for 3 a long time, and in the course of that time the enterprise has launched a assertion confirming that it’s beneath investigation in a number of overseas markets.   

    Other abroad regulators have presently opened neighborhood probes into this group, Rahti added.  

    The FCA chief government stated: “This firm has fairly just a few million United kingdom customers. This is the sort of case the place by we would need to validate that an investigation is underway.”  

    He further: “We will take our time greater than this proposal to be certain we get it proper.”  

    Rathi knowledgeable the Treasury Committee that of the 27 conditions he talked about the watchdog may need to publicise the probes of some further firms.  

    The FCA chief authorities talked about that the watchdog by now has the electrical energy to establish firms beneath investigation however solely beneath “distinctive circumstances”.  

    The go by the regulator arrives simply after it and the Prudential Regulation Authority had been offered new competitiveness and development goals by ministers final 12 months.      

    But previous week, in a unusual intervention in regulatory affairs, Chancellor Hunt claimed: “Last 12 months the legislation modified within the financial merchandise and companies market and [the FCA] have a secondary growth obligation.     

    “On the idea of that, I hope they re-search at their ‘naming and shaming’ choice as a result of it doesn’t really feel common with that new secondary development obligation that they’ve.”    

    It additionally emerged final 7 days that 16 finance commerce our bodies — equivalent to Uk Finance, The Financial funding Affiliation and TheCityUK — wrote to the Chancellor asking him to intervene.    

    “Firms suppose that the proposals can have a opposed affect on their valuation, may put in danger the wellbeing of males and ladies, and have the possible to destabilise cash markets,” the associations stated within the letter to the Chancellor.    

  • ERC provides advice to advisers in advance of Consumer Duty alterations – Home loan System

    The Equity Launch Council has warned advisers they may want to have to critique extra mature life time residence loan situations, as these will shortly fall lower than the brand new Purchaser Duty rules.

    From July 31 the Fiscal Perform Authority’s Client Obligation pointers will contain beforehand purchased merchandise and ‘closed’ books of enterprise in addition to new product sales.

    The ERC is publishing guidance for advisers to allow them with the 2nd interval of this regulation, which is claims might be considerably way more onerous for corporations. 

    It claims this will likely be more durable to implement  as a result of closed textbooks of residence loans could be many years earlier and are normally offered on with out the necessity of the whole client heritage.

    However, the ERC components out that equity launch merchandise might doubtlessly provide a ‘lifeline’ to consumers whose conditions have gotten reviewed as portion of this process. This might contain residence finance loan prisoners and desire-only consumers with out the necessity of reimbursement automobiles – who might be recognized beneath these guidelines.

    The Council not too way back revealed steering for its members, which incorporates the general fairness launch profit chain, in collaboration with a member consultancy group.

    The ERC’s director of likelihood, protection and compliance, Kelly Melville-Kelly means that although distributors shoulder essentially the most accountability, advisers have a important place to carry out as effectively.

    “Consumer accountability is about equity. Companies ought to act in the perfect pursuits of their prospects and simply take acceptable care to keep away from main to harm, always.

    “Embracing this proactive technique via the open up guide interval has meant that organisations have had to replace and alter their procedures, however our prospects have risen to the issue.

    “Applying the very same scrutiny to shut e-book prospects is probably going to be more durable nonetheless. Some corporations may have inherited closed guides which current a good bigger problem as tons of of the originator corporations are not any extra time in market place. For distributors this might essentially imply unpicking legacy methods which have in depth contemplating the truth that been archived.

    “For advisers, or distributors, it’s about functioning with the suppliers as correctly as checking client data to see if any are on closed e-book items and ensuring they’re saved knowledgeable of their picks.”

    She provides that advisers will even will want to be certain that if a shopper’s scenario have remodeled, there may be an analysis of the continuing suitability of the product, with particular focus paid to weak consumers.

    “Even if the shopper sits inside a closed e-book, corporations have to test regardless of whether or not the merchandise continues to be appropriate and that the buyer nonetheless understands the dangers and added advantages. If the reply to is not any, then corporations may have to have a plan to steering that purchaser.”

  • ASTL joins business phone calls to quit FCA strategy to ‘title and disgrace’ companies   – Mortgage loan Finance Gazette

    The Association of Quick Term Creditors has joined a wave of discipline our bodies who need to forestall the City regulator from ‘naming and shaming’ companies beneath investigation and have voiced their protest to Chancellor Jeremy Hunt.   

    fca2-508x330.jpg

    The Financial Carry out Authority reported it deliberate to decide companies on the get began of an investigation primarily as a result of it’s within the public curiosity to achieve this in a session paper in February.  

    It set out the controversial proposals in its ‘Our Enforcement Guidebook and publicising enforcement investigations – a brand new strategy’ doc, introducing that it might give companies beneath investigation 24 hours’ uncover that it might make its probe group.  

    However, 16 finance commerce our bodies — which embrace British isles Finance, The Financial funding Association and TheCityUK — have ready to the Chancellor asking him to block the transfer.  

    “There has been a considerable response towards the proposals from throughout the monetary merchandise and providers sector,” says the letter dated 26 April however revealed these days.  

    It provides: “Firms assume that the proposals can have a unfavorable affect on their valuation, might put at hazard the wellbeing of individuals at present, and have the potential to destabilise financial markets.”  

    The finance our bodies incorporate the shift by the watchdog “took the business unexpectedly” because it skilled not been earlier elevated by the regulator, introducing that “the FCA has underestimated the extent and the chance of the proposals proudly owning a harmful affect”.  

    The letter tells the Chancellor, “we strongly urge that the FCA doesn’t start with their proposals as outlined”.  

    The FCA has defended the measure as an additional transfer to accountability and transparency all through the financial providers sector.  

    But Association of Limited Phrase Loan corporations chief govt Vic Jannels suggests: “It’s normally the case that an FCA investigation advantages within the regulator getting little or no untoward with the agency that it is investigating.   

    “However, if that agency is known as on the outset, it’s going to actually undergo reputational, and possible business, damage though the investigation is taking put and probably past even when it success in no disciplinary movement.   

    “This is a responsible till lastly confirmed harmless tactic that might drastically negatively have an effect on investigated monetary providers distributors and in the long term their clients.” 

  • House loan Constitution New FCA Regulations

    Created on 4 July 2023 by Ray Boulger

    Mortgage Charter New FCA Rules

    In his assertion saying the Mortgage loan Charter The Chancellor acknowledged the alterations he declared can be provided to debtors with “no queries requested”. The Lender of England and Monetary Providers Act 2016 states that The Treasury could nicely at any time make suggestions to the FCA on financial plan, however by saying a brand new protection with out session The Chancellor has absent previous recommending! Nonetheless, the FCA should mirror The Chancellor ‘s plan in its insurance policies.

    It has now revealed a Coverage Assertion (PS23/8) confirming its enabling provisions. While staying succesful to self discover a forbearance choice will likely be handy and welcomed by some debtors, a number of of whom will likely be liable and solely use the options out there after they genuinely should should, as I acknowledged in my prior web site I feel it’s harmful because of the truth having mentioned that considerably information is put in entrance of debtors a major proportion will both not completely acknowledge the implications or will ignore them.

    In observe I believe most debtors who must decrease their funds will want to take action for greater than 6 months and so previous to the cease of 6 months might want to should discover with their monetary establishment extending forbearance, because the FCA recognises at place 2.28. Yet, however obvious it’s constructed that this forbearance solely lasts for six months I believe a number of debtors will likely be lulled right into a faux notion of stability, until contacted by their loan firm, that they will go on to make diminished funds with out getting a dialog with their loan supplier.

    For the similar motive I anticipate fairly couple of debtors will revert again once more to their preliminary residence loan phrases inside 6 months. However, I’m fairly delighted that the FCA highlights at 2.10 the ERC free overpayment answer which may understand the same final result as reverting to the unique phrases however with the achieve of further versatility and the potential to revert steadily if much more acceptable. It additionally avoids incurring the modest admin worth which a number of loan suppliers generally cost for a deal variation.

    The COVID situation was extraordinarily numerous just because there was a sudden fear that quite a few individuals immediately would cut back their employment, however with hindsight we all know that a number of of us took the three months “no ideas requested” vacation break as a security net alternatively than primarily as a result of they in actual fact mandatory it.

    In the present state of affairs the problem is extra about training and lack of enough forward organising. Debtors should know when their mounted fee ends and method correctly in progress what they’ll do if new higher funds are heading to be troublesome or unaffordable many do however some actually don’t, regardless that clearly the tempo of current degree boosts could have understandably caught some out.

    A unique important place which should be created extraordinarily apparent to debtors is that there is no such thing as a affirmation within the FCA Policy Assertion that, in distinction to with the COVID 3 month home loan getaway, everybody deciding on to coaching any of those forbearance choices is not going to have their credit score rating adversely impacted.

    In the absence of those affirmation debtors should consider that figuring out any of those forbearance choices could have a dangerous results on upcoming residence finance loan or different credit score rating functions. Hence the FCA ought to mandate that the data offered by loan suppliers ought to encompass a warning of achievable unfavorable outcomes on debtors’ credit score rating.

    At final, Section 2.5 within the Coverage Statement is attention-grabbing. It claims: “These laws are exemptions from accountable lending calls for.” The solely conclusion I can draw from this assertion is that the FCA thinks its present reliable lending calls for are unduly onerous, as the one affordable alternative interpretation is that these new exemptions are irresponsible!

    Classification: Ray Boulger