Blackmore Bond again puts off filing accounts

Blackmore logo 2019

A filing on Companies House shows that Blackmore Bond has again exploited the accounting-period-shortening trick to extend the date that its accounts are due.

Blackmore Bond plc should have filed its December 2018 accounts by June 2019, but used the one-day-shortening loophole to legally delay filing accounts for three months. That three months expired on Friday 27th and on the very same day, right in the nick of time, Blackmore Bond electronically submitted a further adjustment.

Blackmore cites the resignation of its auditor, Grant Thornton, as the reason for its failure to file accounts in a timely fashion.

Blackmore has come under heavy scrutiny since the collapse of London Capital and Finance, with more attention paid to relatively small payments of quarterly interest (relative to the amount Blackmore has taken in) than any other investment company I can think of.

Immediately after London Capital and Finance was shut down by the FCA, Blackmore replaced LCF at the top of Surge’s Top Isa Rates and Best Interest Rates websites. Given the level of undesired publicity it has received as a result, this marketing strategy has arguably backfired.

Blackmore has now stopped accepting investment from UK investors and, almost uniquely for a UK-based investment company, only accepts investment from outside the UK, via its Blackmore International website.

Blackmore Bonds late paying interest, according to media reports

Blackmore Bonds, which issues unregulated loan notes in its property development business, is a few days late in paying quarterly interest to some investors, according to reports in Money Marketing and the Telegraph.

According to Bond Review readers and The Telegraph, Blackmore’s switchboard is jammed with worried investors and it is not answering emails.

A Blackmore spokesman told The Telegraph:

Due to delays in the banking system, a number of client interest coupons may not yet have been processed. We are working hard to resolve the issue and are confident it will be resolved imminently.

Normally a company being a few days late in paying interest would be no big deal.

Especially when you consider that in March, Blackmore stated that it was obtaining Return on Capital Employed of 54% and that this was sufficient to meet the high rates of return required to return up to 9.9% to investors while paying commission of up to 20%.

But the collapse of London Capital & Finance in February, and the fact that Blackmore used the same marketing agent as LCF (and paid it up to 20% commission), appears to have spooked some investors and caused them to keep a close eye on their regular payments.

This is borne out by Blackmore’s Trustpilot reviews, which over the last 48 hours have seen a spate of 1-star reviews from worried investors.

Didn’t receive coupon last day of month 31/7 and couldn’t get through. They also appear to have delayed filing the annual accounts. All alarming and concerned end up like LCF scam.

Unfortunately lack of communication breeds mistrust and it is quite understandable that investors are worried due to the collapse of London Capital and Finance, a similar venture.

As per previous posts i am also getting quite worried regarding my investments with Blackmore..I am now preparing for worst case scenario..??

This will be of great concern to Blackmore which prominently advertises a 5-star Trustpilot logo on the front page of its website. At time of writing this is no longer accurate as Trustpilot shows its average rating has dropped to 4 stars.

Blackmore Bonds closed to new business from UK investors in April, but continues to invite overseas investors to invest via blackmoreinternational.com. Obtaining information about its bonds via the blackmoreinternational.com requires prospective investors to declare that they are not from the UK.

To boost its attempts to secure investment from outside the UK, Blackmore opened an office in Dubai this year, with further offices planned in Tokyo and Hong Kong.

Last month Blackmore Bonds used a loophole in the Companies Act to delay filing accounts. Blackmore Bonds says it will file accounts next month in September, after changing its auditor.

Blackmore’s Trustpilot page currently states that it has raised £35 million from investors in its bonds.

Update 7.8.19

According to Money Marketing, Blackmore has now made the late interest payment, describing the delay as a “clerical error” with their bulk payment system.

Blackmore Bond plc delays filing accounts

A few days before it fell overdue with its annual accounts, Blackmore Bonds plc has used a loophole in the Companies Act to delay filing.

Blackmore Bond plc’s accounts for the year ending December 2018 would normally have become overdue on 30 June 2019. On 27 June Blackmore shortened its accounting period by a single day, giving it another three months before it legally becomes overdue.

Scrutiny has fallen on Blackmore Bond plc as a result of the collapse of London Capital and Finance. Like LCF, Blackmore used Surge Financial as a marketing agent. Immediately after LCF collapsed, Blackmore bonds were promoted in LCF’s place on Surge’s top-isa-rates and best-interest-rates websites. Blackmore recently disclosed that it pays up to 20% of investors’ money as commission. Unlike LCF, Blackmore continues to trade and make all due payments in full, to the best of our knowledge.

Blackmore Bond plc’s last accounts for December 2017 (now a year and a half old) disclosed that it had raised £25 million from investors. At that time it had net assets of minus £7.6 million.

The accounts said that the company “fully intends to reach the £100m fund raising mark”.

Blackmore closed to new business in April 2019. In May 2019 it opened an office in Dubai to promote its bonds abroad. At time of writing its website still says that it is not currently taking new investment.

Why it is unable to file its annual accounts in a timely fashion is not known.

Update

Blackmore has told IFA trade paper Money Marketing that the accounts will be filed in September 2019, following a change of auditor. Blackmore’s last accounts were audited by Grant Thornton.

Blackmore states that it expects revenue of £20 million this year. As to whether it is generating sufficient profit to pay all investors back, we will have to wait and see.

While it was still open to new business, Blackmore paid commissions of 20% to Surge Financial (disclosed via its website and its last accounts). In slightly simplified terms, Blackmore needs to generate returns of 15.6% per year after costs and overheads to repay investors who invested in 3 year loan notes paying 7.9% per year, due to the 20% commission that comes out at the start.

Blackmore Bonds temporarily closes to new business

Blackmore logo 2019

Blackmore Bonds has removed all literature relating to its bonds from its website and replaced them with the following notice:

We have achieved our fundraising goals for this tax year and are not currently taking new investment.

We will be introducing our next offering in the following tax year, so please watch this space for future announcements.

If you are a current investor, you can log in below to manage your account.

At time of writing the rest of the website consists of pictures of six Blackmore property developments and an invitation for residential developers and landowners to contact Blackmore to build partnerships.

After the collapse of London Capital & Finance in December 2018, LCF’s marketing agent, Surge, switched to promoting Blackmore via its top-isa-rates.co.uk and best-interest-rates.co.uk websites. This led to a brief resurgence in web traffic to Blackmore, with its Alexa ranking climbing from sub-1-million to a peak of 500,000 in February 2019.

In February 2019 Surge’s websites stopped promoting Blackmore, and traffic to Blackmore Bonds’ website has declined sharply since, currently sitting at an Alexa rank of 600,000 and falling.

At time of writing, best-interest-rates.co.uk shows a blank page, while top-isa-rates.co.uk promotes a range of peer-to-peer and IFISA investments, with Capital Bridge as their “top pick”. The table no longer misleadingly compares these investments with cash ISAs, instead listing capital-at-risk IFISAs only.

If Blackmore’s offering in the new tax year is materially different from its last one, we’ll bring you an update at that time.

London Capital & Finance on Money Box: the FCA speaks and Blackmore claims returns of 54%

London Capital & Finance logo

Link: All our articles on London Capital and Finance

The BBC’s Money Box programme continued its investigation into London Capital & Finance on Saturday.

Following questions recently asked in Parliament, the actions and inactions of the Financial Conduct Authority continue to be scrutinised. The BBC interviews IFA Neil Liversidge, who was one of the first to warn the FCA about LCF in 2015. The FCA declined to send someone to appear on the programme, but did release a statement:

“Correspondence sent to us is logged and we are looking into this. LCF did not need to be authorised to issue minibonds. Nevertheless its financial promotions were caught by our rules. Our immediate priority is to investigate and to assist in the recovery of any assets. We’ll then be looking into this matter carefully and will consider what lessons can be learned.”

This is a very interesting use of the word “then”. The recovery of the assets, by which the FCA means the administration process, is almost certain to take at least a year, and could potentially take a number of years, particularly as the administrators have emphasised the complexity of this case. As an example, the administration of Secured Energy Bonds is about to enter its fifth year.

If the FCA intends to defer any investigation into its own conduct until after the administration is complete, that helpfully kicks it straight into the very very long grass, and any investigation will conclude long after any senior management in the blast zone have moved onwards and upwards.

Blackmore claims returns of 54%

The report also touched on Blackmore, and noted that while Blackmore is not related to LCF, it also used Surge as an agent and has to make a similarly high rate of return to LCF to meet its commitments to investors.

Blackmore is bullish about succeeding on that front, saying in a statement:

“Our business model is entirely on track and current return on capital employed averages 54 per cent. This has been verified by reputable independent surveying professionals. The first bond maturities are due at the end of 2020 and will be paid in full. All investors will confirm that every interest coupon has been paid on time and without issue. We’ve always operated within all required regulation. In line with advice from our solicitors and FSMA section 21 sign off partner, we continue to update and improve our website and other promotions in an ever-changing regulatory environment.”

The proof, as ever, will be in the pudding. The reference to surveying professionals means that Blackmore’s figures showing a ROCE of 54% come from “mark-to-market” valuations from a valuer rather than actual sales of their developments.

There is no reason to doubt the integrity and independence of Blackmore’s valuers, but no matter how good the valuer, the price it actually ends up being sold for can vary significantly – especially as the property market will inevitably fluctuate between now and 2020.

Blackmore boldly enters new era of transparency by declaring up to 20% commissions

Blackmore logo 2019

Blackmore Bonds has been making a number of changes to its website recently to improve its compliance with the FCA’s “clear, fair and not misleading” rules.

Around a year ago, the top of Blackmore’s website prominently featured the headings “Capital Protection” and “Income Certainty” below its interest rates. Immediately below this, in letters half the size, were the words “Capital at risk | Please read our risk section. Illiquid and non-transferable. Not FSCS”.

By including risk warnings in text half the size of headlines saying “Capital Protection”, this old version of the website put Blackmore potentially afoul of the FCA’s regulations that “balancing statements” such as these must be displayed with equal prominence to be clear, fair and not misleading.

Blackmore’s new version of its website is a considerable improvement in this regard, with the “Capital Protection” and “Income Certainty” headings gone, and a risk warning “The products on this site offer a high return on your investment, it is important to understand that as with all investments of this type your Capital is at Risk” displayed in 27-point font, the same size as its headlines.

The FCA-regulated firm responsible for approving Blackmore’s website has recently changed from NCM Fund Services to Northern Provident Investments.

One of the most notable changes is that Blackmore’s website now includes the following text prominently at the top: “Up to twenty percent of your money will go towards paying for the cost of raising capital & the overheads of Blackmore & adds to the risk of capital not being returned.”

For Blackmore to disclose the extremely high commissions paid to its introducers out of investors’ money is a refreshing change. Indeed, its own website stated as at March 2018 “Blackmore Plc [sic] does not have any set-up charges or management fees“. How this earlier statement can be reconciled with the new disclosure of up to 20% of your money being paid out in commission is not clear to me.

That Blackmore Bond paid out up to 20% in commission is already known from Blackmore’s December 2017 accounts, which disclosed that £25.4m had been raised in the period (covering July 2016 to December 2017) and that £5.1m had been paid to Surge Financial for “sourcing investors loans and front and back office operations” – almost exactly 20%.

However it is a safe bet that not many investors will have read the accounts on Companies House, and this is the first time Blackmore has disclosed the upfront commissions it pays on its website. Indeed, it is one of the few companies offering unregulated bonds than does so. Which is refreshing, if slightly depressing that Blackmore is the only company with this level of commitment to transparency.

Effect on risk

As Blackmore’s notice says, the fact that up to 20% of investors’ money is paid out to Surge or other parties “adds to the risk of capital not being returned”.

Indeed, the commissions paid to Surge by London Capital & Finance were recently identified as a contributor to the company’s insolvency by LCF’s administrators.

It should be emphasised that unlike London Capital & Finance, there are no reasons to doubt Blackmore’s current solvency. It showed net liabilities of £7 million on assets of £18 million in its last accounts of December 2017, but that was a year ago and the position could have changed significantly. To my knowledge Blackmore continues to make all its interest payments on time.

That balancing statement comes with the caveat that Blackmore Bonds plc was incorporated in July 2016 and its bonds have a minimum term of 3 years, so its first capital repayments will not fall due until the second half of this year.

Blackmore has nothing to do with London Capital & Finance other than sharing the same marketing agent and call centre provider, but it is subject to the same laws of mathematics that mean that – as it says – the higher the commissions it pays out, the higher the risk of capital not being returned.

In slightly simplified terms, if Blackmore raises £10,000 from an investor in its 3 year bonds paying 7.9% per year, and pays out 20% in commission, it now needs to turn £8,000 into £12,370 to repay the investor in full, representing a 55% return over 3 years – or 15.6% per year.

For its 5 year bonds paying 9.9%, the return required to turn £8,000 into £14,950 is 87% over 5 years, or 13.3% a year.

Any investment targeting a return of 15.6% or 13.3% a year will inevitably be extremely high risk – and while Blackmore can diversify over many such projects, some of its projects will fail, which will lower the overall return.

Blackmore’s website states that it pays up to 20%. However, as its last accounts disclosed that it raised £25m and paid Surge £5m, it seems fair to assume the maximum  commission payable in the above calculation.

Despite Blackmore’s commendable new-found appetite for transparency and risk disclosure, I have to say I’m still not getting a sense of the very high risk of its projects not delivering returns of 13%+ per year from its website.

Risk of “investor appetite” waning

There is one last new risk warning on Blackmore’s website to comment on. Under the “Risks” page, one section states:

Failure of bond marketing

There can be no guarantee of investor appetite for the Bonds to the extent predicted by the Company or, indeed, at all. In such circumstances investors may lose some or all of their investment.

How a decrease in investor appetite (i.e. new investment) could lead to existing investors losing some or all of their investment sorely needs clarification.

RPDigitalservices, former chief promoter of London Capital & Finance, stops promoting unregulated investments

London Capital & Finance logo

Link: All our London Capital & Finance articles

Until the FCA shut down London Capital and Finance, one of its most important promoters was RPDigitalservices, the company behind the top-isa-rates.co.uk and best-savings-rates.co.uk websites.

Both websites formerly contained misleading advertisements that placed London Capital & Finance bonds on the top of a “comparison table” which compared London Capital & Finance’s high-risk unregulated bonds to FSCS-protected deposit accounts. RPDigitalservice’s websites failed to mention the immense difference in risk involved.

RPDigitalservices is not authorised by the FCA to issue financial promotions to the public.

RPDigitalservices was one of the most important sources of investment for London Capital & Finance. At the time they were promoting LCF, analytics data from Alexa showed that half of visitors to LCF’s websites had previously visited RPDigitalservices.

RPDigitalservices was until July 2018 controlled by Ronak Patel, after which Patel relinquished control to Paul Careless, head of Surge Group, LCF’s marketing agent and call centre operator. Careless has claimed that Surge and RPDigitalservices share staff (and directors, and owners) but operate separately.

After London Capital & Finance was shut down by the FCA, RPDigitalservices switched to promoting Blackmore Bond.

This coincided with Blackmore’s web traffic picking up dramatically. Alexa stats show a steady decline in traffic to Blackmore’s website until April 2018, at which point Blackmore fell out of the top 1 million websites and Alexa stopped tracking it entirely. However, since January 2019, Blackmore’s web traffic has surged (sorry), leaping back into the top 1 million websites and currently standing at around 520,000th at time of writing.

Alexa rank Feb19
Alexa traffic stats for blackmorebonds.co.uk, February 2019.

Alexa shows that at time of writing, approximately half of visitors to Blackmore’s website came from either best-interest-rates.co.uk or top-isa-rates.co.uk – just as it used to be for London Capital & Finance.

It should be emphasised that Blackmore Bonds has met all its debt obligations to date and is not subject to any regulatory action that we are aware of. Like London Capital & Finance’s bonds or any other unregulated bond, Blackmore bonds are an inherently high-risk investment with a risk of up to 100% loss.

RPDigitalservices has now dropped unregulated bonds from its comparison tables entirely. The results at the top of the page for top-isa-rates.co.uk are now two P2P platforms. These P2P platforms are, like all P2P, also high risk, but regulated by the FCA.

RPDigitalservices continues to fail to provide any disclosure of the wildly different risks involved in the products it compares.

BBC’s You and Yours programme covers unregulated investments

You and Yours, BBC Radio 4’s consumer affairs programme, has just released its latest episode which partly deals with three investors who were encouraged to invest their money in unregulated investments.

The programme makes interesting and, at times, painful listening for anyone with an interest in unregulated investments.

[2:40] Winifred Robinson (BBC presenter): The three people you’re about to hear were encouraged to invest their pension savings into risky unregulated funds. Two of them say they were cold called at home.

In 2015 Stephen Sefton needed to transfer his pension from his company pension scheme to a new one in order to access income drawdown.

[4:28] John Douglas (BBC presenter): He, like many people, was looking to take advantage of new pension rules. He wanted to be able to access his pension savings and leave money to his children. To do it, he had to transfer from his company pension scheme to a new one. That was why he went looking for a financial adviser, and he found David Vilka’s company [Square Mile International Financial] online.

W: Did he have much money in his pension?

J: Yeah, around £415,000. And Stephen agreed it should go into an overseas pension scheme before being invested in two funds. The first, called Blackmore Global, is where most of his money went. The rest went to another fund in Malta.

No reason is given in the BBC programme for why Mr Sefton was recommended an overseas pension. Overseas pensions are generally only suitable for expats with very specific tax circumstances.

Mr Sefton first encountered problems a year later when he couldn’t find out what his pension – his share of the two funds – was worth. He subsequently found out that Square Mile International Financial was not authorised to provide financial advice or transfer UK pensions. They were on the FCA register, but only to provide insurance mediation.

[5:48] J: The FCA has confirmed to us that Square Mile International Financial does not have the necessary permission to deal with pension transfers. David Vilka though maintains his firm is authorised and it hasn’t done anything wrong.

The programme then moves on to the nature of the underlying investments.

[6:10] J: We’ve seen a document which shows the fund is Malta is a “professional investor fund”, in other words it was never supposed to be for the general public, so wasn’t appropriate for someone like Stephen.

Then there’s that other fund, Blackmore Global, where most of his money went. We know the managers of a pension scheme on the Isle of Man were worried about that; they sent a letter to their clients who’d already invested in Blackmore Global saying they’d concluded it posed an unacceptably high level of risk.

W: In what way?

J: Well, the letter said that they’d become increasingly concerned at the lack of financial accounting information that was available for Blackmore Global, so they’d removed it from their list of approved investments.

The BBC programme goes on to describe a man named Paul (not his real name) who was one of those who received that letter from the Isle of Man pension firm. He’d invested all his pension savings, around £100,000, in Blackmore Global, after being contacted by a firm called Aspinal Chase.

The Isle of Man SIPP provider offered to try and get his money out of the Blackmore Global fund, and said that if Paul didn’t want to do that, he needed to get confirmation from a regulated adviser confirming it was still suitable.

Paul contacted Aspinal Chase, who

[8:25] J: …sent him a reassuring letter suggesting the Blackmore fund was performing well, the letter said the advice still stood from his financial advisers that the fund fit his circumstances perfectly. The thing is Winifred, Aspinal Chase listed Paul’s financial advisers as none other than Square Mile International Financial in Prague, the same company that dealt with Stephen Sefton’s pension. And the letter to Paul from Aspinal Chase went on to say that Square Mile certainly has the correct regulation, which of course we now know is far from certain. But those reassurances from Aspinal Chase were enough for Paul to leave his money where it is in Blackmore Global.

What he didn’t know is that there’s a connection between Aspinal Chase and Blackmore Global. Both companies were run by the same man.

W: So the people who are behind the company that Paul says cold-called him… they also own the fund where his money ends up?

J: That’s right. Philip Nunn and Patrick McCressh are both directors of the Blackmore Global Fund and directors of Aspinal Chase. Aspinal Chase was linked to David Vilka’s financial advisers in Prague, because it was described as the “UK administration team” on paperwork sent to advisers. So both the cold calling operation and the financial advisers’ admin team were based at the same address in Manchester. Phillip Nunn and Patrick McCreesh’s businesses were also involved in processing applications to transfer money out of pension schemes – money that would ultimately end up in the Blackmore Global Fund, which they control.

The BBC report then reviews the charges applied by the Blackmore fund disclosed in its fee document, with the aid of Rory Percival, a leading industry consultant and former regulator at the Financial Conduct Authority, where he specialised in the regulation of investment advice.

[10:45] Rory: Gosh. The fees are… in comparison with most investments, very very high. You’d have to be getting very very high levels of returns even to make any money out of that.

J: Is this sort of investment suitable for someone wanting an income from a pension?

R: No, because it’s up to the directors when you get your money. If you’re saving for your retirement, you want to be in control of when you get your money, to live on in retirement. So no, absolutely not.

J: Now even though it was mentioned in some of their paperwork, some investors didn’t realise their money would be locked into the Blackmore Global Fund for ten years. Even after that time, Rory says, getting the money out might not be easy, as it depends on the fund being able to sell its underlying assets.

Paul says he’s been trying for a year to get his money out of the fund, and has got nothing to date. He had hoped to retire at 60, and has found his money is locked into Blackmore well beyond his 60th birthday.

[12:25] P: I’ve got three grandchildren – we’d like to take them all to Disneyworld in America. I want to spend the money I’ve earned over the years – a bit of that money would pay off the last bit of me mortgage – so that is a big chunk of my future.

J: How has all this affected you and your family?

P: We do have the occasional arguments, and I feel as though I’ve let the family down. I’ve tried to put it to the back of my mind but when you start looking at what’s going to happen in the future… it’s what is going to happen in the future… I don’t know, I just don’t know.

The third investor (who does not speak on the programme) is Jacqueline, who invested £50,000 in Blackmore Global after being cold called by Aspinal Chase, and also has documents showing Square Mile International Financial as her adviser. Blackmore Global has refused to release her money “to protect the integrity of the investment for its other stakeholders”.

Stephen Sefton did manage to get his investment back, but only after taking a £30,000 loss on the unnamed fund in Malta, and after repeatedly emailing and complaining over a period of 18 months.

David Vilka and Square Mile International Financial say his company’s permissions and activities have been inspected and verified in full by numerous regulators, and that there is no financial relationship between his business and those run by Philip Nunn and Patrick McCreesh. He says he helped Stephen Sefton get his money out of the Blackmore fund.

Philip Nunn and Patrick McSheesh say there is no connection between themselves and David Vilka / Square Mile International Financial. They say Aspinal Chase never engaged in cold calling, and did not give pensions advice; any advice was given by separate regulated financial advisers. They told the BBC “they had nothing to hide, and wished to act with as much transparency as possible”, but refused to grant an interview or send audited accounts for the Blackmore Global Fund, or a list of its underlying holdings.

Conclusion

Stephen Sefton believed his adviser was authorised to offer financial advice because he found them on the FCA register. He did not know that he was supposed to check the drop-down list under “Permissions” to make sure they had the necessary authorisation to give advice, and to advise on pension transfers.

This is a well-known issue. It is simple for anyone who knows they have to check “Permissions” to check it, but for everyone else it is the classic unknown unknown. How are they supposed to know they should check the list of Permissions when they don’t know they should know?

Even government bodies such as the Pensions Advisory Service tell users to “check the FCA register” without making it clear they need to check the Permissions drop-down.

The FCA is under some pressure to make its register more “user-friendly”, but in the meantime investors should bear in mind the following:

  • Professional advice should always be taken from advisers regulated in the UK and authorised to provide advice. Do not just check the register, but check they have permission to advise. Do not respond to cold calls.
  • UK Investors should not invest in an offshore arrangement, whether a pension, a fund or any other wrapper or security, unless they have a need that would not be met by an onshore arrangement. Any regulator or compliance consultant will confirm this principle.
  • Any investor who is advised to invest all their investments in one or two funds should be very confident that it is highly diversified and liquid. Examples of funds which may be suitable as a single holding include Vanguard Lifestrategy or Legal & General Multi-Index, which are spread across thousands of mainstream blue-chip shares on recognised stock exchanges. This is trivial to verify. This is not the case with any investment which does not disclose audited accounts or a breakdown of its underlying assets.
  • There are many legitimate reasons to invest in unregulated and/or offshore arrangements. Any UK investor who should be investing in such arrangements will know exactly what they are, because they will either be a professional investor, or they will have a suitability letter from an FCA-regulated adviser detailing why the investment is suitable and why a regulated/onshore investment would not meet their needs. If you are advised to invest in any arrangement which is not regulated in the UK without good reason, proceed with extreme caution.

The quote above from Paul at 12:25 shows why these steps are necessary with heartbreaking clarity.

Correction

Mr Sefton, who was interviewed in the above report, got in touch with us to request a correction (this article originally read “No reason is given in the BBC programme for why Mr Sefton needed an overseas pension”).

I did not need a QROP; the BBC’s turn of phrase was unfortunate for giving that impression. I was actually “mis-sold” it by David Vilka on false statements of tax advantages that I later discovered were untrue, and also that it is “approved by the HMRC” which I later discovered is not true because HMRC do not approve schemes.

We review Blackmore’s bonds paying up to 8.5% per year

Blackmore offers unregulated fixed-interest bonds paying 6.5%pa over three years, 7.5%pa over four years and 8.5% over five years.

Blackmore also offers a “Blackmore Multi Strategy” investment trust registered in Frankfurt and a “Blackmore Global” fund described as “a medium to long-term investment vehicle with a diversified investment portfolio under one structure”. These investments are presumably regulated financial products and beyond the scope of this blog. The rest of this review deals with the fixed-interest bonds.

Who are Blackmore?

Blackmore’s website lacks details of the directors, but it does have blog posts which show that Philip Nunn is the Chief Executive.

Companies House suggests that Blackmore Group Ltd is jointly owned by Philip Nunn and the other director, Patrick McCreesh.

How secure is the investment?

These investments are unregulated corporate loans and if Blackmore defaults you risk losing 100% of your money.

On Blackmore’s web page “How Is Your Money Secured?” it states “Investors have a legal charge over the assets of Blackmore Bond Plc. In the event of business insolvency then the sale of these assets, contribute towards paying back our investors’ capital. Please note that where there is bank borrowing, the bondholders will rank second in order of priority over the charge.“

It is not clear how much Blackmore Bond plc owns in assets, as it was incorporated in July 2016 and has not yet filed accounts – its first accounts are due in March 2018. The latest accounts for its parent company, Blackmore Group Ltd (31 December 2016) show net assets of £2,281. (2,281 pounds, not thousands or millions.) The parent company accounts also state that the parent company owes Blackmore Bond plc £247,769 in respect of expenses incurred on its behalf – which shows that Blackmore Bond plc has at least £247,769 in current assets at the time the accounts were filed.

These accounts are “total exemption” accounts meaning that Blackmore Group Ltd did not have to disclose full details of its finances and was exempt from auditing due to its small size.

If the sale of assets is insufficient to pay back investors in full, the website states that a “Capital Protection Scheme… comes into play”, which is an insurance contract “underwritten by Northernlights Surety”. There is a Northern Light Surety in the USA but it is unclear whether this is the company referred to. There is little public information available on Northern Light Surety.

If for whatever reason Blackmore is unable to sell the assets your bond is secured on for enough money to cover its obligations, after repaying bank borrowers, and Northernlights Surety does not make good the losses, investors still risk losing up to 100% of their money.

With a complex structure like this, it is essential that investors undertake professional due diligence and satisfy themselves that:

  • In the event of default, the assets owned by Blackmore Bond plc are liquid enough and valuable enough that they could be sold and raise enough money to meet investors’ claims, after paying bank borrowings
  • The bondholders’ charge over these assets has been properly recorded
  • The insurer “Northernlights Surety” has sufficient resources to pay out on any claim
  • That the insurance contract in place with the insurer will cover investors in the event of a default

Should I invest with Blackmore?

As with any unregulated corporate bond, 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.

This particular bond is advertised as asset-backed. Before putting any reliance on the security backing the bond, investors should undertake professional due diligence to ensure that a) the security exists b) in the event of default, the security could be easily sold and would raise enough money to cover all investors’ money c) the charge over the security has been properly and legally recorded.

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 capital protection structure can be relied on?

If you are looking for “certainty”, “capital protection” or “security”, you should not invest in unregulated products with a risk of 100% capital loss.