Author: <span>CapitalStackers</span>

The eager clamour from experts and economists to forecast the bursting of the UK property “bubble” is becoming ever more shrill. The reasons they give are varied, but largely boil down to:

• the drop in economic output (which has historically correlated with a property dip);
• the switching off of stamp duty relief;
• the end of furlough payments, and;
• a sharp recent rise in property values.

Now, it’s often said (only partly in jest) that economists “predicted nine of the last five recessions” – and the harsh reality of being a pundit is that if you want to get into print, you’ve got more chance of grabbing the headlines by predicting a disaster than you have by saying “things will just carry on just swimmingly, thank you”.

So one can understand the motivation for pundits to um-err on the gloomy side.

And of course, the shrillness has intensified since many of those asked for predictions last year faceplanted into the egg box and are still wiping the yolk off their faces.

Having seen market growth of almost 25% over a five year period whose turbulent events have included three new prime ministers, two elections, the chaos of Brexit and a pandemic, experts with particularly eggy features include Savills (who predicted a 10% drop in house prices this year), Knight Frank (a 7% drop), Lloyds Banking Group (a 5-10% drop), and Cassandra herself – the Old Lady of Threadneedle Street – predicting a terrifying 16% nosedive!

So the sheer indignation of seeing the housing market blasting out of lockdown with a rocket up its jacksie caused the pundits to respond by screeching that this unpredicted growth actually proved them more right. The fragile housing market, they mansplain, is now clearly overheating and about to go pop. Houses, they say, are reaching unaffordable levels and closing off the crucial funnel-feed from first time buyers. Geoff Meen, Professor Emeritus in Economics, University of Reading, insisted the market is vulnerable to a shock at any time. [1]

So how much truth is in these sentiments?

On the surface…

On the face of it, the figures do suggest things are getting a little warm. The ONS reported a year-on-year increase of 13.2% for UK average house prices in June 2021 – the highest annual growth rate since 2007 – to £266,000 [2]:

Halifax similarly reported a 2.4% increase in the quarter to July 2021, pointing to a record average house price of £261,221, and a 16.7% annual increase in house prices in Wales alone [3], followed by another monthly rise in August, to £262,954 [4], although it did acknowledge a slowing in the rate of growth.

Along with other expert commentaries, Santander’s 2019 First Time Buyer Study compared the average house price to the average net incomes of 25-34 year olds [5]. And they weren’t alone in this blunder. As so often with matters like this, the reality may be more complex than the experts would have us believe.

Averages are not probabilities

For one thing, the above forecasts are based on averages. Which is no basis for anything. Averages disguise spreads – that is, they take a whole world of varied and valuable information and roll it up into a fairly valueless number.

For another thing, “average” first time buyers don’t buy houses at the national average price. If they’re on a lower income than the mean, they naturally buy cheaper houses or flats, in less fashionable areas. And according to HM Land Registry [6], they’re making a good fist of it. The average price of a flat in June 2021 was £221,211, and the average first time buyer was spending £222,712 (Table 1). What’s more, despite overall home ownership being at its lowest level since the early 1980s [7], appetite from first time buyers remains strong. Santander’s First Time Buyer Study [8] also revealed that 9 out of 10 young adults aspired to own their own home. As a top life goal, that makes home ownership twice as popular as having children or getting fit.

And despite being suppressed by lockdowns in the early part of 2020, the number of first time buyer transactions in the second half of 2020 was only 2% down year-on-year.

What’s more, when you break the June national average down by region (according to the Government’s latest figures), you can see differing levels of enthusiasm in different parts of the country:

So, beneath the screaming headlines about “average prices” and “average buyers” lies a delicately detailed watercolour of the true picture. House prices are rising at different rates, in different regions, and are bought by a variety of people from varied backgrounds, motivated by a kaleidoscope of sometimes conflicting factors. But this is difficult to squeeze into a headline.

Moreover, the figures to which the commentators refer to are all based on wildly differing criteria and methodologies. It’s important to remember that house price indices are not straightforward – with varying delays in reporting data. Zoopla, for instance, measures the changes by listed prices, not sold prices. What a seller wants for their home is not always the same as what the house sells for. 

And while ONS data is generally a solid bedrock on which to base analysis, their housing reports are delayed due to the lag in Land Registry sales registrations. And, the most respected indices – Halifax and Nationwide – are weighted by transaction volume. This can skew our view of prices because houses sell at varying values.

Of course, not everyone is trying to scare us with generalities. Some commentators on the ground are more precise in their pronouncements.

Cory Askew, of Chestertons estate agents, puts revitalised demand for flats in central London down to “predominantly first time buyers who are feeling a lot more secure in their job prospects.” And David Millar, of Bairstow Eves estate agents in Leytonstone, Waltham Forest, adds “(This) area used to be all buy-to-let years ago, but now 90pc of my buyers are first timers.”[9]

The kernel of truth

So where are prices cooling off? Recent reports suggested that larger houses in selected parts of Greater London and the South of England – traditionally the engine room of national house price growth – had suffered from the growing appetite for larger, rural homes, along with recent surcharges on stamp duty for non-UK residents and possibly concerns about the long term effects of Brexit among a more remain biased populace. The property website Zoopla said central London prices had been trailing the rest of the country for 8 months [10].

David Millar explains how the market split, “The tapering of the stamp duty holiday at the end of June has meant the market for £700,000 to £800,000 houses has calmed down, but the demand from younger couples buying £400,000 to £500,000 flats shows no signs of slowing”.

However, at the very top end of the market, there are reports that buyers from the Middle East, encouraged by the easing of Covid restrictions, are again viewing properties in the £10 million plus bracket [11].

So unsurprisingly, these reports of rising prices have given rise to dour predictions about an affordability gap. However, these tend to be based on the traditional price vs earnings ratio, which has steadily climbed again after a post 2007 dip (Chart 2).

If the headlines are to be believed, how are people still affording to buy houses?

While average London houses cost 11 times the average London wage, this figure is undoubtedly skewed by outliers. In the same way that Bill Gates could walk into a crowded football stadium and raise the average wealth of everyone in it to over $1 million, so properties in Mayfair, Highgate and Belgravia selling for tens of millions obscure the fact that you can still buy a property in London for £100,000 [12]. And yet still the pundits plug the averages to scare us.

The reported growth averages have been skewed by yo-yo performance in lower value areas with lower sales volumes (Table 3), or niche segments. We can see that the double figure surge in Wales [13], for instance, is predicated upon a tiny fraction of England’s sales – so we can naturally expect wilder price fluctuations on a smaller data set. And a post Covid yearning for more space [14],fuelled by lockdown savings among the better off, can explain the lift in interest for larger, higher value houses. So rolling these outliers into an overall market prediction is likely to be misleading.

And if we focus on the picture region by region (Chart 3), in those areas where earnings are lower, prices are lower. In the Midlands, North West and Wales, prices average 5.5-6 times average earnings – which very likely means it’s still possible to buy a house at a highly mortgageable 2-3x salary.

Then again, the broad brushstrokes of national averages blur the issue. When we examine regional variations, the picture starts to clear.

But of course, price isn’t the only factor to consider when we’re discussing affordability. While house prices are among the highest they’ve been for 120 years relative to earnings [15], this ratio tells us little about whether people can afford to buy them. After all, how many people buy in cash?

On the other hand, when we look at the cost of borrowing that money, we begin to understand why prices have continued to rise despite other pressures (Chart 4).

People’s willingness to pay the price of a house depends not on the headline price, but on the monthly repayments. And at the moment, these are still relatively comfortable.

Surely the end of the stamp duty holiday has triggered a slowdown?

Well, not according to Resolution Foundation. The independent think tank’s study reported in August 2021 that prices rose more in areas that least benefited from the tax cuts [16].

The expectation was that the parts of England whose average house prices were close to the maximum benefit figure would have risen most if the tax holiday was the primary driver for the uplift. But the study was surprised to find that a) there was no correlation between areas with the highest gains and house price increases, and b) house prices rose highest in the areas with the least to gain.

So it’s possible that bigger, more global forces are driving house prices higher. The UK housing boom is currently being reflected in almost every major economy in the world [17] – not just in Britain. The combination of low interest rates, lockdown induced savings and evolving homebuyer appetites seems to have fuelled the greatest worldwide house price boom for the past two decades.

This view is supported by anecdotal evidence that the housing market has held steady despite the pulling of the stamp duty rug [18].

London estate agent Jeremy Leaf, formerly of the Royal Institution of Chartered Surveyors, said, “the predicted price correction immediately after [the withdrawal of the stamp duty holiday] failed to materialise”. Chris Hare, a senior economist at HSBC, agreed. While there was of course a rush to complete transactions before the stamp duty holiday before the stamp duty holiday ended, this was “certainly not pushing the UK housing market into a slump”.

And Cory Askew, of Chestertons concurs: “The absolute peak of demand was at the end of March when the stamp duty holiday was extended.

“Then there was a steady decline in inquiries through April, May and June – levels were much lower than in 2020, but higher than in 2019. It is a normalised market.” [19]

A normalised market, then. Not a crash.

These are soothing, perhaps sensible words. Rather than expecting bust to follow boom, perhaps we should see the rampant figures in context and rather than scaremonger about bust following boom, ask ourselves, “Is it a boom? Or are we seeing a lot of localised wildfires?”

Of course, the dark forces that could trigger a crash are never far away. But the question is, do they currently have the power to do so?

So are interest rates the secret trapdoor that could bring down the market?

Well they could be…and let’s face it, raising them significantly could trigger a slide in prices and be the fastest way for the Government to keep its pledge to solve the affordable housing problem across the country [20].

But in truth, any government would do anything in its power to stop this happening. They know it would be a political and personal disaster.

The last time we saw a sustained drop in house prices was the 12.3% fall from the September 1989 peak – and they didn’t return to their previous level for over eight years.

The superficial reason given (see below) was ‘overheating’ in the UK, fuelled by a rush to buy before the MIRAS tax relief scheme for couples was withdrawn by the government. It was a very British market crash.

Which is why, despite the pledges, all Governments have conspired for decades to support or inflate house prices.

After all, no government wants to be left holding the housing bubble when the music stops, so they tend to shovel cash into the jukebox whenever it seems to be slowing down.

In other words, the standard solution to making housing affordable is to prop up prices and simply give people a leg up to meet them.

For instance, the New Labour government responded to the 2008 crash by launching the Mortgage Rescue Scheme (MRS) to support mortgagees who couldn’t sell or keep up their repayments. They bolstered this with Homeowners Mortgage Support (HMS), whereby the state would underwrite up to 80% of the losses of a banks who looked the other way when homeowners couldn’t pay. Then in 2009-10, the same government diverted £1 billion from their regional economic programmes to prop up the housing market.

Successive governments followed with modest policies like HomeBuy Direct and HRS, paving the way for ‘Help to Buy’, which sprung a huge number of people – 280,000 households – onto the housing market by 2020. And in 2021 Boris planned to bounce the housing market still higher by lending up to £25 billion directly to home buyers over a two year period.

However, even before they began to spend that £25 billion, prices shot up even faster than they had before – dragging sales up to nearly 140,000 a month by late spring 2021.

Whether or not these measures have been successful it’s evident that this Government – along with most governments across the world – is pulling all the levers it can to avoid another crash.

Aditya Bhave, economist at Bank of America, said policymakers around the world were “now acutely aware of the risks around housing policy”. In contrast to 2008, that “meaningfully reduces the chances of an adverse outcome”, he added.

The independent housing analyst, Neal Hudson concurs: “We are stuck where we are – with house price inflation. The clear message that I took away from the Budget last month was that this is a government which recognises that maintaining house prices where they are or higher is important to them politically and economically because so much of our economy is now based around the lending which is secured against house prices.” The market behaviour we’re seeing now is “exactly what you would expect in a financialised housing market where mortgage rates are very low”. [21]

And of course, while the Government has learned lessons, so have the banks. The key differentiating factor between the situation now and that of 2008 is that central banks now carry a lot of scar tissue from the last property crash and are now much more vigilant.

And unlike the period leading up to 2008, the flames are not being fanned by sub prime debt.

Deniz Igan, deputy chief of the IMF’s macro financial research division, opines, “Mortgage growth was driven largely by people with strong financial positions, and across most advanced countries households were less indebted than before the financial crisis, suggesting a lower risk that the situation would follow the same path with a wave of defaults and fire sales”.

So if mortgage rates are kept under control, a crash can be avoided?

Not so fast. We haven’t heard all the witnesses yet.

While all the experts were getting their predictions wrong last time, the author and economist Fred Harrison was one of the few who correctly predicted a 10% rise in UK house prices over the UK Pandemic.

And he has a theory.

Whether there is any credence to it, we’ll let you be the judge.

In his 1983 book, The Power in the Land, Harrison correctly forecast the property price peak in 1989 and the recession that followed it.

His prophetically titled 2005 book Boom Bust: House Prices, Banking and the Depression of 2010 then successfully forecast the 2007 peak and the ensuing slump. He suggests the market will continue to boom and then crash in 2026.

Harrison also claims he already predicted the 2008 crash at least a decade before, having identified an 18 year business cycle from trends in the city of Chicago.

All the factors we’ve discussed, according to Fred, are like waves on the shore. Disruptive, but not in themselves enough to change the course of a vessel.

But what we haven’t discussed is the tidal effect of the Land Price Cycle.

The what?

‘It rested on a theory about the land market, which operated on a 14 year cycle,’ he said. ‘I checked the theory against US wide evidence for the 19th century and cross checked the theory against the diverse cultural and geographic evidence from Japan and Australia over the 20th century.

‘And I identified the cycle as operating within the UK for at least 300 years.’

The cycle, said Fred, roughly comprises two main phases, divided by the mid cycle downturn.

After a crash, the market takes about four years to gain enough confidence to start climbing again.

There then ensues the recovery phase – six or seven years of moderate growth.

Next comes the mid cycle dip, perhaps a one or two year downturn, before a final boom phase, typically lasting another six or seven years and where prices generally rocket more than at any other point in the cycle.

‘There are ups and downs within each of the two halves,’ he goes on, ‘but the trend is inexorably upwards towards the final peak.’

So while the low interest rates, the stamp duty holiday, the 95% mortgages, the rehash of the Help to Buy scheme and the exodus to the country in the wake of the pandemic all potentially have a powerful inflationary effect on the market, the significant undertow, insists Harrison, is the finite supply of land.

This is then fuelled by human nature, sentiment and speculation to turbo charge prices.

The population and the economy continue to grow…without the land supply to satisfy demand, property prices rise, while banks have little choice but to lend more against accelerating asset values to fuel the spiral.

More people resort to property as a financial safe haven and prices are further bloated by the appeal of capital gains, prices soar above what they otherwise would be until the bubble bursts.

Harrison’s 18 year property forecast is that Britain is right at the beginning of the final boom phase, with the next crash on schedule not next year, but in 2026.

But you’ll notice above that Fred is vague enough about timescales to avoid being pinned down to anything less than five years in terms of accuracy. So it’s less of a cycle and more of a wheel of fortune.  

To put Fred’s theory into perspective, below are the house prices since 1845 (Chart 6). As you can see, the “cycle” appeared to have a “flat” until the 1860s and then rocketed as we all know.

But in order to maintain this zero house price inflation required factors that would hardly be replicable today. For one thing, the Victorians and Edwardians more than doubled the UK housing stock between 1851 and 1911 – from 3.8 million houses to 8.9 million – and almost halved the size of the houses. [22]

To repeat the feat today would involve building 28 million houses half as big as those currently being built – and considering the current trend is for more space, not less, this might not make them very saleable.

So will Fred Harrison’s theory be proved right? Who can tell? Every day the world turns is a revolution. Other long term effects may yet come into play. Because while the pandemic will change the way we live, work and interact as a society, it looks unlikely to suppress the good old British trust in bricks and mortar.

And as things settle down, we may either see a reverse of the exodus from London – or a crystallising of its effect, with new technology facilitating networks of rural homeworkers.

Then again, we may see a remarkable new phase of inheritance fuelled growth. Until now, this hasn’t really figured in market modelling, because inheritances have been so much smaller.

But when we consider that people born in the 1960s – many yet to inherit – will be the indirect beneficiaries of an average 343% price rise since 1996 [23], we can see a potential game changer on the horizon.

Bearing in mind that the effects of this unprecedentedly huge cash injection will neither be uniform, nor restricted to any particular place or time, but spread out over decades and potentially filtering into every corner of the UK, who can begin to imagine its effect as a mood enhancer on whatever the prevailing passions are in future eras? How, for instance, might it sway the WFH/Office saga? Might it combine with HS2 to inflate house prices in the North? Or even shift focus to Northern France?

So those who turned to this column for answers and concrete predictions…come on. Do you think we’re that daft?

Prophecies, like the promises of a faithless lover, may as well be written in wind and running water – as the last 18 months has shown. The property world is currently in a giant tombola spun by unpredictable long and short term forces. One can plot the variables and model best and worst case scenarios. In April, Neal Hudson was adamant that high house prices were here to stay. By the beginning of September, he wasn’t so sure: “There is still a lot of economic stress that could impact things,” he stresses. “The end of furlough could have an effect and so there remains a great deal of uncertainty.” That is, prices might still fall, or at least flatten their growth curve. In short – something might still cause prices to fall, or at least stall. [24]

The latest Halifax figures showed house price growth eased from 7.6% to 7.1% in July. [25] The number of property purchases dropped in July when stamp duty ended in England and Northern Ireland.

But by other metrics, the expiry of the tax break has so far failed to trigger the predicted collapse.

Russell Galley, managing director of Halifax, comments, “We believe structural factors have driven record levels of buyer activity – such as the demand for more space amid greater home working,”

“These trends look set to persist and the price gains made since the start of the pandemic are unlikely to be reversed once the remaining tax break comes to an end later this month.”

But when all’s said and done, does it really matter? For the vast majority of homeowners, undulations in value are of little concern when the underlying trend is inexorably up.

After all, the only real group who might suffer from a drop are the minority looking to downsize in the near future, or the unfortunate souls in negative equity facing repossession. We can only hope that the downturn of this economic cycle is not so severe on these individuals.

However, most people buy houses for the long term, which has so far been kind to all of us.

And of course, the likelihood is that if you’re reading this, you’re even higher up the food chain. You’re more likely to be reasonably well heeled and looking to invest spare cash, rather than counting the pennies into your gas meter. So if you’re buying to let, the vagaries of house valuations should have limited effect on you.

More so if you’re putting your cash to work through CapitalStackers, since your exposure to the ups and downs of the property market will be heavily cushioned. Since we only lend a maximum of 75% of value, the brunt of your volatility risk will of course be absorbed by the developer’s own equity – giving you at least a 25% cushion against the worst happening.

To put that in context, let’s consider how the market came off its 1989 and 2007 peaks:

So given that the biggest ever drop in UK housing history was somewhat less than 20% (albeit induced by a unique and spectacular concatenation of circumstances), we’ll leave you to draw your own conclusions….

Shouldn’t the FCA proposals to ban promotion of P2P property development lending differentiate between pooled and direct lending? What will happen if they don’t?

The FCA has come in for a good deal of criticism recently, and as a result has promised to raise its game – restructuring its organisation, improving training and establishing a “programme of change that transforms the way we handle and prioritise information and intelligence”.

The fallout over the Lendy administration – where the owners drifted from being gilt-edged pawnbrokers putting boats in hock, into the world of property development which they clearly didn’t understand, achieved FCA approval status in July 2018 “following a detailed end to end assessment of its business and operating model”, collapsed just 10 months later and saw the directors’ personal funds frozen following allegations that they siphoned money out of the company into accounts in the Marshall Islands – will no doubt have focused their minds on the need to review and tighten regulations, as of course will the reviews into the collapses of London Capital & Finance and The Connaught Fund (neither of which were P2P platforms, by the way). 

So the FCA will be aware of a lot of eyes on this next wave of regulations as it rolls out. And one of the first proposals to be aired is a call for a ban on promotion across all property development lending in the P2P sector.

Of course, we applaud and welcome measures to protect investors and weed out the dirty players in the P2P sector. In all financial services, regulation and scrutiny are crucial to keep the bad actors out and to build on the work of the conscientious ones so that everyone plays a part in creating a culture of best practice. Roger Gewolb of the Campaign for Fair Finance has rightly called for more scrutiny. “There have been too many crashes and too much money lost,” he said, and we agree. Even one crash is one too many.

But the first rule of throwing out bathwater is surely to check for babies first. And to respond to a few crooks that have fallen through the cracks in the FCA’s processes by treating the entire sector as potential crooks feels like quite a violent reaction. A total ban on promoting legal business services – the majority of which are run by conscientious, experienced lenders – would unnecessarily hobble them to the point that most could not go on. Certainly not in their present shape.

We’ve already discussed in this blog the reputational damage caused to our sector by a handful of bad operators. And it’s clearly wrong for so many to be judged on the basis of so few.

To those who use it (or should we say need it?), P2P property development lending is an intricate knot that requires careful unravelling to save what’s valuable and discard what’s not – in the FCA’s own words, “use of data and intelligence” – rather than putting everyone to the sword.

So we would hope the FCA’s new training programme will include modules on how to differentiate and discriminate. How to build a programme of smarter regulation that will enable the industry to grow legitimately and support both investors and SME developers – both of which have come to depend heavily on P2P in the last 10 years.

We need sharp, discerning rules that encourage good practice and make bad practice impossible. Rules that recognise the difference, for instance, between:

1. Pooled lending – where all loans are basically chucked into a bucket and investor money is chucked in after it, relying on new investors to buy out existing investors if they wish to exit because the cash will be forever rolled into the next deal; and,
2. Direct lending – where an investor lends to a single borrower for a specific building project which they can scrutinise for its individual merits, review the detailed due diligence and risk modelling and get repaid when that project completes.

As it stands, the proposed ban makes no distinction. Direct P2P development lending is spoken of in the same breath as mini-bonds when the two products actually bear little resemblance.

And yet we believe investors would welcome legislation that makes this crucial distinction. Regulations that protect them from the incompetent, the inexperienced, the self-serving and the criminal – but also allow them the freedom to seek higher returns than are available from mainstream interest rates, on portions of their portfolios where they are happy to accept higher risk, and where they have sufficient specific information to be able to properly assess that risk, make their own decision and set their reward accordingly. 

There’s certainly a requirement to ban platforms from promoting to any investor without a high level of transparency and total honesty – especially small retail investors. Nobody wants to see them lose money they can’t afford due to risks they don’t understand – although if the risks and repayment horizon are made as clear as they should be, this ought not to be a problem – especially if their exposure has been limited, as is the case following the 2019 rule changes.

So while the FCA’s scrutiny of property development P2P is understandable, lazy media reporting and adverse pundit publicity aimed at the industry is not. Even mainstream investments can trap investors, as victims of Neil Woodford and, more recently, Aviva found.

But should we be regulating to prevent platformsfrom promoting secured lending opportunities to Sophisticated and High Net Worth Investors, where risks have been made transparent and they will be fairly compensated for the risks they choose to take?

Is it not sufficient to make it clear how and when an investor can get repaid rather than shut them out altogether?

Should not smart regulation of P2P involve forcing ALL platforms to make all risks clear to all investors, all relevant information fully transparent (as the good ones already do) and in particular whether or not an investor is dependent upon the platform bringing in new investors down the line to maintain future liquidity? For the record, at CapitalStackers we ensure that all the funding needed to complete and exit a project is in place before a penny is drawn down. In the absence of a functioning secondary market, to get their money back, our investors only need wait for the project they are funding to come to fruition – and that is typically no more than 2 years, well inside the 5+ year terms referred to in the context of mini-bonds, ‘High Risk Investments’ and ‘Speculative Illiquid Securities’ (to use FCA parlance). And as a number of our investors have found out, even during the pandemic, they could liquidate investments within periods measured in days, not weeks or months.

Investors (from the most sophisticated to the most vulnerable) are free to invest in the stock market, where there is every chance they might make a poor decision and lose money. They’re free to take a punt on murky, poorly run companies. And yet we never consider regulating the stock exchange.  

So has the FCA considered all the implications of policing what individual investors can or can’t do – i.e. policing the product as opposed to policing conduct? They’re certainly open to canvassing your views on the matter.

A spokesman for the FCA said: “We have not suggested a ban for most types of peer-to-peer agreements but are seeking views on whether there are certain types of high risk P2P agreements that should not be mass marketed to retail investors”. By ‘certain types’, they mean property development loans.

“Where we have suggested a ban, we need to balance the benefits of stopping consumers investing in inappropriate products with the impact on firms. We are seeking views on how we get this balance right.”

So what now faces you as Sophisticated or High Net Worth investors is both an opportunity and a threat. The threat is that P2P property development lending is very much in the FCA’s sights and could end up being closed off as an investment vehicle as we go back to you only being able to invest in property through institutional funds (in which case think low yields and high costs). Developers would be forced into the institutionally backed debt fund market, removing an extremely important funding plank that’s been in place for some 10 years. The opportunity is for you to try and influence the outcome. Do you feel the FCA is right to impose these protections upon you or would you rather the choice remained yours? Your views will be considered by them until 1st July this year, so we would really welcome your input before that deadline. This link will take you to the FCA’s website. There’s a link at the top of the page to the FCA’s discussion paper and at the foot of the page is an invitation to “Respond to the consultation”.