FCA officials shit on the floor, as well as the bed

When I opened my morning paper and read that staff at the Financial Conduct Authority HQ had been condemned by their Chief Operating Officer for leaving liquor bottles in sanitary bins, abusing the cleaners, and defaecating on toilet floors, my first thought was:

“I’m not going to write an article about this. It’s a trivial employee discipline issue, and Bond Review is better than that.”

Then I came to my senses, mixed myself a glass of Old Cynic, and started mashing keys.

So, the news here is that staff at the headquaters of the Financial Conduct Authority have been excoriated by one of their most senior directors for

leaving cutlery and crockery in the kitchen areas, overflowing bins, stealing plants and charging cables from desks, catering and security teams being subject to verbal abuse, colleagues defecating on the floor in toilet cubicles on a particular floor, urinating on the floor in the men’s toilets and leaving alcohol bottles in sanitary bins

according to Chief Operating Officer Georgina Phillipou.

Who probably wasn’t told, when she accepted the job of one of the most senior officials at the financial regulator of the United Kingdom, that it would involve attempting to potty train thousands of highly qualified financial regulators.

On a message posted on the FCA’s Intranet, the Chief Nursery Officer continued:

I did think long and hard about whether to disclose all these behaviours because they are so distasteful and shameful but keeping quiet has not got us far in terms of changing behaviours. This kind of behaviour is unacceptable and will not be tolerated here.

Whether the “look at what you just did” school of discipline works on the UK’s foremost financial supervisor remains to be seen. But it’s worked on millions of dogs, so best of luck to Ms Phillipleasedontpouonthefloor.

Broken windows

Obviously it’s very easy to make cheap jokes about civil servants trashing their office, which is why I’m doing exactly that.

But there is a more significant point here.

In the 1990s a social science theory known as “broken windows” came to prominence in New York City. The idea was that if you tackled low level crime, such as bricks being thrown through random windows, people would start taking pride in their neighbourhoods, and more serious crimes would be nipped in the bud.

In essence, broken windows theory is that you have to make people on the ground care about their environment, and only then can you hope to improve it.

Whether broken windows theory ever led to a reduction in the crime rate is disputed, as any experiment involving a dataset as chaotic as the crime rate always will be. But the theory itself is logically sound.

As to how this theory applies to the FCA, it’s simple. If you can’t trust regulators to not shit on the floor, or swear at the dinnerlady, how the hell you gonna trust them to deal with scammers and crooked bankers?

The Financial Conduct Authority’s job is to ensure billions of pounds in UK capital flows to where it’s needed, and that the 70 million people in the UK can open bank accounts, save into pensions, wave cards and generally interact with the financial system without worrying if they’re going to lose their money by doing so.

If that isn’t enough to get FCA employees out of bed in the morning, without reaching for the bottle on the bedside table, then we are screwed.

And if this isn’t enough to get FCA employees out of bed in the morning, that’s not their fault, that’s the fault of senior management, and the culture they created. That’s not me talking; that’s the gist of the FCA’s own Senior Managers and Certification Regime, due to come into force next month.

SM&CR breach ahoy

After a systemic failure to intervene in unregulated investments flouting UK law on promotion to retail investors, resulting in a billion worth of lost investments in 2019 alone, the FCA is under scrutiny like never before.

The FCA’s failure to stop unregulated high-risk investments being marketed to retail investors who cannot bear the risks is a failure of culture. Part of its job, part of its statutory responsibility is to protect consumers and ensure market integrity.

In treating unregulated investments with a policy of masterly inactivity, by ignoring them as insignificant and not its problem, it has overseen billions worth of lost money and ruined lives. This policy did not come from its loose-breeched employees, but from the top.

There may be some people thinking: “Give over Brev, you can’t leverage a few rogue employees into a screed about financial services regulation. We’ve all worked in large organisations at some point in our lives, there’s always a few nobheads in an organisation of thousands.”

Well, maybe I can’t, but I’m going to leave this to Bond Review’s readership.

Do you work in a large company?

Do your work colleagues shit on the floor?

I used to work in a large financial firm, and I’ve seen my fair share of bad behaviour. I’ve had to dive under a table at a Friday social. But my colleagues didn’t steal chargers from the electrical outlets, they didn’t assault the catering staff, and they didn’t shit on the floor.

An organisation rots from the head. The FCA is now literally putrescent.

The approaching change of CEO is not enough, and messages circulated on the intranet are also not enough. A top-to-bottom change of culture is needed. Until it happens, expect more flogging of unregulated investments to retail investors without consequence, expect more ruined lives, and expect more shit on the floor.

Astute Capital publishes accounts, scrubs critical posts from Internet

Astute Capital logo

Astute Capital plc, which issues bonds listed on the Irish Stock Exchange paying up to 8.9% per year, has filed its accounts for the year ending March 2019.

The accounts were filed two months late, leading to Astute’s bonds being temporarily suspended from the Irish Stock Exchange.

In the year to March 2019, Astute Capital made a marginal loss (£2k) and finished with net liabilities of £82k. The directors assume the company will continue to operate on a going concern basis.

Astute Capital plc on-lends investors’ money to another company, Astute Capital Advisors, which in turn lends to “the UK property and SME markets” and pays 12.5% per year back to Astute Capital plc. As at March 2019, £15.7 million had been lent to ACA.

ACA’s only previous accounts were filed using small company exemptions and were unaudited. Due to being a private rather than public limited company, ACA still has another two months to file its March 2019 accounts.

Whether Astute continues to keep the performance of the company which conducts the actual lending activities under wraps with fileted accounts will become clear when the ACA accounts are filed.

Astute Capital plc advertised its bonds via Google as “up to 8.9% Fixed Return, Easy Online Process” with no risk warnings.

google advert

Astute has been scrubbing material critical of the company and warning retail investors of the high-risk nature of its bonds from consumer forums.

A MoneySavingExpert forum thread “astute capital safe?” was started on 1 Feb 2019 by a first-time poster, who asked simply “Is astute capital a safe place to invest in an ISA?”

The initial responses to their query have since been deleted. The first response to their query, dated a month and a half later, from another first-time poster, now starts “I think so, there are fund managers in place and FCA trustees too…” (neither of which is relevant to the fact that Astute Capital’s bonds, like any loan to a small company, have an inherent risk of 100% loss and cannot be described as “safe”).

The second response from “eskbanker” retorts “And here we go, new shillsposters joining to make a solitary contribution in support of an operation that everyone else is running a mile from because of the risks highlighted in the above posts!” 

This post makes clear that multiple posts highlighting the risks of Astute Capital’s bonds have been deleted between eskbanker’s post and the present day.

As does one a few posts below, which confirms that a total of five posts have been deleted from the thread between 16 June 2019 and the present day.

deletedposts

MoneySavingExpert has refused to comment on why the posts were deleted. Nevertheless the only plausible reason why multiple posts from various users highlighting the risks of Astute Capital’s bonds would all be deleted is that Astute Capital complained about them.

Why Astute Capital feels the need to get posts highlighting the risks of its high-risk bonds scrubbed from consumer forums is not clear.

And in case anyone’s wondering: no I haven’t. Not a dicky bird.

Satchi Wealth subject to strike off notice

Satchi Wealth, which offers three year unregulated bonds paying up to 11% per year, has been issued with a strike off notice after failing to file an up to date confirmation statement.

Failure to file a confirmation statement on time is a criminal offence under the Companies Act. If Satchi fails to file an up to date confirmation statement within two months of the notice and no objections are receiver, the company will be struck off the register and will forfeit its assets to the Crown.

Satchi’s website remains up and continues to promote investments offering 11% per year and claim that they offer “Protected Revenue Stream / Ongoing Contract with Local Authority / Low Variable Business Model” despite the inherently high risk nature of its unregulated investments.

 

Did the FCA withdraw scam warning after legal threats?

An article in Private Eye about the cryptocurrency Ponzi scheme OneCoin caught my eye last week.

OneCoin was one of the earliest and biggest cryptocurrency Ponzi schemes. You handed over money in exchange for OneCoin tokens, which OneCoin and its agents claimed would steadily increase in value, allowing you to cash in your tokens later for more money (or money’s worth).

Large recruitment commissions were also paid in a multi-level marketing (aka pyramid) system.

OneCoin never made any serious attempt to claim that it had external revenue to fund its ability to pay investors more than they’d invested – plus recruitment commissions. Using new investors’ money to allow existing investors to cash out more than they’d invested, while also paying multi-level commissions, made it a Ponzi scheme.

The Ponzi element collapsed in early 2017 as withdrawals exceeded the money left in the system and OneCoin closed its “exchange”. The scheme continued to limp on as a pure pyramid; victims were encouraged to continue exchanging money for OneCoin tokens in the hope the exchange would someday re-open.

So far, so cookie-cutter cryptocurrency Ponzi scam.

OneCoin is believed to have taken in £4 billion from investors around the world, of which about £100m came from the UK, mostly ethnic minority Muslim enclaves, in an example of “affinity fraud”.

In affinity fraud the scammer convinces the mark to invest on the basis that they should trust him as a member of their community, instead of the mainstream financial and legal system. Often the community is a religious one whose members have already been groomed to trust community leaders over facts and reality.

One UK OneCoin recruiter / victim, Jen McAdam from Glasgow who says she and her family lost six-figure sums in OneCoin, made a series of YouTube videos calling out the scam.

OneCoin hired notorious defamation experts Carter-Ruck to send her a letter claiming they “refute all allegations that they are offering a scam” and that McAdam should remove her videos or face expensive legal action.

McAdam stood her ground, declined to remove her videos and heard no more from Carter-Ruck.

So far, still so cookie-cutter cryptocurrency scam.

Where it gets interesting is that Private Eye notes that the Financial Conduct Authority issued a scam warning against OneCoin in September 2016.

Shortly after Carter-Ruck sent its SLAPP attempt to McAdam, the FCA withdrew its warning.

Despite its warning being 100% accurate, and that OneCoin continued to be promoted to UK investors, mostly ethnic minorities.

Despite the FCA having statutory immunity in the UK, which means it cannot be sued for libel for issuing a scam warning against you, unless a court can be persuaded that it acted in bad faith or unlawfully. This is a virtually insurmountable bar, and it is beyond doubt that OneCoin was not going to manage it.

The FCA has refused to comment on whether the removal of the OneCoin scam warning followed any lobbying from OneCoin’s end.

Yet nonetheless, somehow and for some reason it was persuaded to remove an entirely factual scam warning.

Searches of the FCA register for “OneCoin” or “OneLife” produce no results to this day, other than unrelated regulated businesses unfortunate enough to have adopted the name “OneLife”.

When a scam as blatant as OneCoin can somehow persuade the FCA to withdraw an entirely factual warning, is it any wonder that we hit a brick wall when we try to persuade the FCA to protect unwitting consumers from more sophisticated and subtle Ponzi schemes?

Any novice DIY investor should start their research by standing in front of a mirror and repeating to themselves:

The authorities do not care if I get scammed.

The authorities do not care if I get scammed.

The authorities do not care if I get scammed.

Anyone who says “If this was a scam the authorities would have shut it down” is scamming me.

Prime ISA goes dark, receives strike-off notice

Prime ISA, which offered bonds paying some sort of interest between 5% and 7% (its literature couldn’t decide), appears to have vanished. Its website primeisa.co.uk has been replaced with a webhost error message. The company has also been overdue with its accounts since August and has now been issued with the second strike-off notice of its short life.

If the company fails to submit accounts within two months of the notice, and no objections are received, the company will be struck off the Companies House register and its assets will be forfeited to the Crown.

Prime ISA is part of the Northern Provident Financial stable of IFISA bond companies.

A benign explanation would be that Prime ISA flopped and failed to raise any funds, and its owner Daron Lee has abandoned it. If any investors know otherwise, do get in touch.

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What you may have missed in October

(A selection of the more in-depth news articles from the last 4 weeks)

Any Armenian iron; Asset Life plc administrators report

Introducer turns on Carlauren and approaches “fraud litigation” lawyers as investors allege it took 10% commission

Providence and Secured Energy investors compensated in full

Park First investors push back against proposal to “wipe off £115m of debt”

High Street Group attempts total shutdown of Bond Review (oh, and it’s late filing accounts again)

Buy2LetCars increases to £25 million in funds; company hits road with misleading adverts

MJS Capital administrator says shell company used as “conduit for misuse of funds”; former MJS adviser alleges Ponzi scheme

We review Symtomax’s bonds paying 30% over two years for investing in cannabis

Symtomax is offering bonds paying a 30% return over 24 months – 12% in the first year and 18% in the second year.

There is an option to exit the bond after 1 year. However this assumes that Symtomax will have sufficient liquid funds to repay investors who wish to exit.

Who are Symtomax?

Symtomax is incorporated in Portugal as Symtomax – Unipessoal Lda (Unipessoal translates as “sole proprietor”) and in the UK as Symtomax SPV.

Minette Coetzee is the sole owner of the UK subsidiary and listed on Symtomax’s website as CEO and Founder.

According to her LinkedIn bio, Coetzee was previously Managing Director of Atlantis Advice Bureau and a Director of The Mareeba Group. Both are obscure Gibraltarian companies about which there is very limited publicly available information.

How safe is the investment?

Adverts for Symtomax’s bonds sent via email and Facebook claim the investment offers “Asset Backed Security” and that “the investment is Brexit proof”.

Secured lending is not risk-free as there is a risk that if the underlying borrower defaults, the security cannot be sold for enough to cover the loan.

Investors in asset-backed loans have been known to lose 100% of their money when it turned out that there were not enough assets left to pay investors after paying the insolvency administrator (who always stands first in the queue).

We are not in any sense implying that the same will happen to investors in Symtomax, only illustrating the risk that is inherent in any loan note even when it is a secured loan.

If investors plan to rely on this security, it is essential that they hire professional due diligence specialists (working for themselves, not Symtomax) to confirm that in the event of a default, the assets of Symtomax would be valuable and liquid enough to compensate all investors. Investors should not simply rely on what Symtomax tells them about their assets.

Claims that the investment are “Brexit proof” are extremely dubious as it is a Portugese company offering bonds in Sterling to UK investors.

Should Sterling rise from its current record lows, it will cost the company more to repay its already-very-expensive bonds.

[This article was corrected on 15.03.2020 to remove a reference to a claim that Symtomax has a market capacity of $9.28bn. This figure actually relates to one of Symtomax’s competitors. A promotional email from one of Symtomax’s introducers suggested it related to Symtomax through some mangled grammar. Symtomax’s own literature does not attempt to put a value on Symtomax’s market cap, referring to it as “?”]

Political involvement

According to a press release, Symtomax has recently hired the former State Secretary for Health and former President of Portugal’s health regulator Infarmed, Dr Eurico Castro Alves, as director of Symtomax.

For investors, the thing to remember is that legitimacy by association is not a substitute for due diligence.

The fact that a former government official has joined the board does not make an investment paying 12-18% per year any less high risk.

[This article was corrected on 15.03.2020 to reflect that Dr Alves’ positions with the Portugese State and health regulator are both former positions.]

Should I invest in Symtomax?

This blog does not give financial advice. The following are statements of publicly available facts or widely accepted investment principles, not a personalised recommendation. Investors should consult a regulated independent financial adviser if they are in any doubt.

As with any individual loan note to an unlisted startup company, this investment is only suitable for sophisticated and/or high net worth investors who have a substantial existing portfolio and are prepared to risk 100% loss of their money.

Any investment offering returns up to 18% in a year is extremely high risk. As an individual, illiquid security with a risk of total and permanent loss, Symtomax’s loan notes are much higher risk than a mainstream diversified stockmarket fund.

Before investing investors should ask themselves:

  • How would I feel if the investment defaulted and I lost 100% of my money?
  • Do I have a sufficiently large portfolio that the loss of 100% of my investment would not damage me financially?
  • Have I conducted due diligence to ensure the asset-backed security can be relied on?

If you are looking for a “secure” investment, you should not invest in corporate loans with a risk of 100% loss.

Consternation as Blackmore delays interest again

Blackmore logo 2019

Blackmore Bonds has delayed paying quarterly interest on its bonds for a second time.

patrick-mccreesh-blackmore-group
Blackmore managing director Patrick McCreesh

Investors received an email from Blackmore director Patrick McCreesh saying that the payment due in two days’ time would be delayed until 29th November.

Blackmore’s last interest payment at the end of July was also delayed by a few weeks. In that case Blackmore blamed a “clerical error”. This time around Blackmore has blamed “circumstances outside their control”. At least they didn’t try to blame Brexit.*

Blackmore’s business model, including the 20% commissions paid from investor funds to Surge and other introducers, requires it to generate returns of up to 15% per year to meet its obligations to investors. As recently as March Blackmore claimed its business was “entirely on track”.

As inherently high risk unregulated investments with a risk of total loss, Blackmore’s bonds should only have been promoted to sophisticated or high net worth investors who could afford to invest no more than 5-10% of their free assets, and shrug off the loss if Blackmore defaulted.

Unfortunately, judging by the Trustpilot reviews, this hasn’t been the case for some Blackmore investors.

After the very late interest payment last time this comes as a shock and has only given us 3 days to prepare.
Why were we not notified earlier. I was depending on this interest payment being on time.

At time of writing the Blackmore Bonds website is down, possibly due to excess demand. Investors report that the Blackmore app which allowed investors to view their investments is also down.

Blackmore has twice put off filing annual accounts, blaming the resignation of its auditor. At the beginning of October it claimed its accounts were “almost ready” and will be signed off soon.

*Correction 29.10.19: Oh dear, they did blame Brexit. Money Marketing, who obtained a copy of the full email, notes that McCreesh’s opening stated “2019 has been a very challenging year for businesses in all sectors, with the uncertainty around Brexit slowing down markets. The property market is no exception…”

MJS Capital administrator says shell company used as “conduit for misuse of funds”; former MJS adviser alleges Ponzi scheme

MJS Capital (aka Colarb) collapsed in 2018 after ceasing payments to investors. In March this year it was placed into liquidation.

Relatively little news has emerged from MJS Capital since then, other than a filing on Companies House showing that a creditors committee has been formed, and the odd tidbit released to the press. The liquidators have not yet released a report into the liquidation of MJS Capital (now Colarb Capital plc) itself.

The liquidators, David Rubin & Partners, have however released a report into MJSC Marketing Limited, a shell company used by MJS Capital to move money.

MJSC Marketing Limited was formed by sole director and owner Nigel Peck, who was described as a member of MJS Capital’s advisory board in investment literature.

He has worked predominately in London, as well as Russia and the USA, with major companies holding both senior management and director positions focusing on marketing, sales, compliance, human resources, and corporate governance, and has many institutional connections. – MJS Capital brochure from 2017

Peck’s last regulated role in the UK was at Park Caledonia Associates, which he left in 2010 according to the FCA register.

shaun prince
MJS Capital CEO Shaun Prince

The administrator reports that he met with Peck and MJS Capital CEO Shaun Prince in September 2018 when MJS Capital was starting to collapse under the weight of winding up petitions from aggrieved investors.

During his discussions, the administrator “grew concerned that investors’ money may have been used for purporses inconsistent with the terms on which it had been invested.”

A week later Peck expressed concerns to the administrator “that the company was being used as a conduit for the misuse of the funds invested by members of the public supposedly into MJS Capital plc”.

Despite being the sole owner of MJSC Marketing, Peck told the administrator that he was not in full control of MJSCM’s bank account, as Prince and another person acting for Prince were “moving funds into and out of the Company’s account without Mr Peck’s knowledge or consent”.

Peck also alleged that MJS Capital had been investing into companies in which Prince had a personal interest.

Peck also alleged that MJS Capital operated as a Ponzi scheme.

Mr Peck also advised me that he believed that investment monies from new investors was [sic] partly being used to pay off older investors who had been threatening MJS Capital PLC with winding up proceedings.

Shortly afterwards Peck accepted the administrator’s advice to place MJSC Marketing into administration.

According to the administrator, this was too late to prevent £300,000 disappearing via MJSC Marketing under “highly suspect” circumstances.

I quickly established that over £300,000 had recently been deposited into the accounts and that in the days preceding my appointment, all of those funds had been transferred out of the accounts at the direction of an employee of Mr Prince. These transactions finally emptied the bank accounts on the very day my appointment took effect. I view that circumstance as highly suspect but the bank was unable to reverse the transactions.

A total of £965,000 was paid from MJSC Marketing to third parties which did not meet MJS’ investment criteria, according to the administrators.

The MJSCM administrators, David Rubin & Partners, have now also been appointed administrators of MJS Capital itself, and the administrators are of the firm view that the affairs of MJSCM and MJS Capital need to be viewed together.

Nigel Peck may not be off the hook either.

No useful purpose can be served by the return of control of this Company to its sole Director, Mr Peck. It is apparent from my enquiries that the conduct of Mr Peck itself may warrant further scrutiny.

With the accounts having been emptied by Prince and his merry men, Peck paid £6,000 into the company, which paid for legal advice from Taylor Wessing and obtaining the court order to liquidate the company. The administrator’s own fees have not yet been drawn.

Buy2LetCars increases to £25 million in funds; company hits road with misleading adverts

buy2letcars logo

Buy2LetCars has released its accounts for December 2018.

The figures for Raedex Consortium Limited, the group holding company, show limited information as the company used small company exemptions and did not release a profit and loss statement, or have the accounts audited.

The figures are however clear that the overall company remains loss-making, with the profit and loss account falling from minus £9.3m to minus £14.1m. Net assets decreased from an already negative £2.3 million to minus £9.5 million.

According to a February 2019 Sun article, Raedex has a total turnover of £4.3 million (profit is not mentioned) and has raised £25 million in total from investors.

The Raedex Consortium accounts say that the directors consider it to be a going concern as it will continue to receive support from group undertakings.

Those group undertakings are listed as Buy 2 Let Cars and Rent 2 Own Cars, which in the same year to December 2018 made a profit of £305k and a loss of £599k respectively.

There is therefore a clear risk that Raedex’s group undertakings will not continue to provide sufficient funds to keep the company afloat.

There is another company, PayGo Cars Limited, which according to the Sun article sells Buy2LetCars’ cars after the three year investment term is up.

PayGo Cars Limited is however wholly owned by Buy2LetCars head Reginald Larry-Cole rather than being a subsidiary of Raedex.

Promotional activities

Buy2LetCars is currently on a tour of the UK promoting its investments in hotels up and down the country.

The Leeds leg of its tour was recently promoted in local paper Leeds Live. Despite being clearly an advertorial, the promotion is not marked as such and is described as a “special feature”.

The piece is a blatantly misleading financial promotion, containing no mention of the inherent risks of investing in a small company offering returns of 7 to 11% per year, and repeatedly exhorting investors to invest money currently on deposit.

If you’re tired of seeing your savings tied up in the bank earning low interest rates and are looking to invest your money wisely, Buy2LetCars are hosting a free seminar event in Leeds on Thursday October 24.

Inflation is eating into your hard-earned savings or capital by virtue of low interest rates and loss of buying power. Now is the time to find out how you can change the negative growth on your money and deliver proven returns of up to 11 per cent per annum.

Since our launch in 2012, Buy2LetCars has delivered the expected returns to 100 per cent of our clients with zero percent default.

Misleadingly comparing high-risk investments with FSCS-guaranteed savings accounts was singled out by the FCA as an example of bad practice after the collapse of London Capital & Finance.

On its website Buy2LetCars states that if an investor invests in one of its buy-to-let cars and Buy2LetCars was unable to repay the investor from leasing it (e.g. because the hirer stopped paying fees and Buy2LetCars could not find another end-user), it will make up any shortfall up to 85% of the investment.

Buy2LetCars goes beyond this in the LeedsLive promotion, saying that it has a 100% repayment record.

There are only two possibilities:

  • Either Buy2LetCars has, despite lending cars to people with poor credit, never failed to recover investors’ money from the people it lends cars to;
  • or it pools investors’ money in order to repay investors on those occasions where the end-user has failed to pay sufficient fees to allow it to repay the investor from their car alone.

The first is implausible, especially given the company’s ongoing losses reported in its accounts.

The second means that Buy2LetCars is running an unauthorised collective investment scheme.

Buy2LetCars has no authorisation from the Financial Conduct Authority to run a collective investment scheme, nor to issue financial promotions.

Holiday reading

For those looking for inspirational Christmas gifts, Buy2LetCars CEO Reginald Larry-Cole has released a memoir, Compassionate Capitalism – How I Turned 150 Nos into 1 YES, detailing his rags-to-riches story about how he went from being rejected by 150 venture capitalists to founding a £25m unauthorised collective investment scheme.

The self-published book is optimistically on sale for £25 (current Amazon bestseller ranking #981,479) but Larry-Cole is handing out free copies to the first 10 people who turn up to Buy2LetCars’ seminars.

Larry-Cole has also recently launched a penny-auctions gambling company called Lifestyle Bids.

Penny auctions are a form of lottery where players pay fees (£1.99 to £4.99 in Lifestyle Bids’ case) to place very low bids for expensive items. Only one player wins the item, with all other players losing the fees they paid to place the bids.

The winner therefore gets an expensive item for almost nothing (allowing the lottery to be promoted as “You could buy a luxury holiday for £3.74!”) but the cost of the item is covered by the fees paid by the losing players. This contrasts with a normal auction where fees are paid by the buyer and seller and the failed bidders lose nothing. Simple maths means that the majority of players will lose more in fees than they gain in won items.

In a traditional penny auction the highest bid wins, while Lifestyle Bids works in reverse, with the highest unique bid winning. (I.e. if five people bid 1p, one person bids 2p and one person bids 5p, the 2p player wins the item.) The underlying lottery mechanism is however identical.

Penny auctions are currently unregulated in the UK as the Gambling Commission can’t be bothered does not consider it gambling.

Lifestyle Bids does not appear to solicit investment (though it does pay 20% commission to affiliates who introduce players who place bids). Its 2018 accounts show net liabilities of £784k.

Larry-Cole’s concept of “compassionate capitalism” comprises a heavily loss-making unauthorised collective investment scheme and an unregulated lottery. Surely a political career can’t be far behind?