The day I mis-sold an insurance policy

About five years ago I had a couple in with me who were buying a home, I was helping them to determine their insurance needs and I realised that they had literally no protection if either of them ever fell seriously ill – not via their job/employer schemes or individually. So I suggested that they consider some serious illness cover, it would have cost them about €20 a month but they were insistent that they only wanted what was ‘cheapest and nothing more’.

As an adviser, it isn’t my job to always accept what people say they want because often, with adequate probing and understanding they actually want something entirely different, a skewed but simple way of understanding what I mean is that when saving or investing the majority of people want ‘high growth and high security’ – when in fact, these two features are normally night and day, if there ever was an asset that could deliver high growth with deposit account style security then everybody would pile in and the market would adjust accordingly, therefore you need to …

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Who is really to blame for the crisis?

Today, buried on the inner page of the Independent Business section there was an article stating that an Oireachtas committee found that the responsibility for the financial crisis in Ireland was largely down to regulators and ratings agencies (the same agencies who down-graded Irish debt in 09′).

Sadly, it didn’t make massive headlines, nor will it… If you could get a picture of Sean Fitz, or some scandal element to tag on then it would be everywhere, but the humble work of one of the few independent studies done on the matter, lacking sex-appeal & scandal will be widely ignored by the public, meaning everybody will still only see ‘banks’ as the source of the problem rather than as the conduit, when in fact the source of the problem was the gatekeeper, the person with their hand on the tap of the conduit, who allowed credit to flow too quickly for too long.

I had coffee with a well known economist last April and we spoke about this matter, he felt that it was …

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The Financial Regulator Report

In Ireland each staff member of the regulator costs 23% more than the international average, their cost to the taxpayer is 88% greater and yet they have responsibility – as a ratio toward population- which is only half that of other countries (to be exact its 96% less).

If that isn’t enough, our regulators deal with 15% fewer firms in terms of the number of actual regulated firms per employee, yet it is 26% more expensive to regulate a company in Ireland than elsewhere, and in terms of regulator staff to financial services staff they are dealing with 17% less than in other countries.

We are overpaying for under-service, in fact, in only one other country does the tax payer foot more of the cost of the bill than in Ireland, and for that we get the statistics above based on the figures below. Angry? You should be.

(the breakdown)

Cost per employee: In Ireland it is c. 23% more expensive for every staff member of our regulator than the international average

Cost …

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Failed regulation in the Irish market

There are three broad benefits to regulation of a financial system.

Firstly, avoidance of negative externalities, often the societal costs of these outweighs the private cost and prevention is possible when a regulator is function well and doing their job correctly. They do this by preventing excesses, by promoting conservative risk management in the financial sector and helping to maintain confidence by ensuring (for instance) that a liquidity shortfall in one institution doesn’t spill over into others (i.e. avoiding multiple bank runs which take down well functioning solvent banks in their wake) resulting in a widespread credit crunch.

Secondly, to set solvency and reserve requirements for banks, at times there are significant asymmetries in information within the consumer/institution relationship, or worse still, information gaps (where both institution and consumer don’t have full information – as happened in the sub-prime loan market in the USA), when nobody can determine the quality and reliability of a financial product a strong regulatory environment will ensure that banks are in a position in which they can …

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The Criminal Justice (Money Laundering & Terrorist Financing) Bill 2009

The Main Purpose of the Bill is to:

•Identify and verify the identity of their customer and of any assets ultimate beneficial owner, and to monitor their business relationship with the customer; •Report suspicions of money laundering or terrorist financing to the public authorities, usually, the national financial intelligence unit; •Take supporting measures, such as ensuring proper training of the personnel and the establishment of appropriate internal preventive policies and procedures.

The 2009/Bill/Act will be applicable to Intermediaries – investment, mortgage and insurance and other investment/insurance businesses which are regulated by the Financial Regulator.  Going forward the term “Designated Body” will be replaced by the term “Designated persons”

The changes which the new Act will bring are:

•“Designated Persons” will be required to perform customer due diligence on a risk based approach. There will be 3 types of customer due diligence depending on the circumstances, (1) Simplified (2) Standard (3) Enhanced identification

•The following products are exempted from the requirements in relation to Customer Due Diligence: – Life Assurance policies with an Annual premium of not more than € 1000 …

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Boom Bust, house prices, banking, and the depression of 2010 by Fred Harrison (book review)

I have been quite public about my belief in property tax (caveat being we should have far less income tax/levies etc. perhaps a ‘flat tax’ would be best), and if there is one book that has really helped to shape that opinion quite succinctly it is Fred Harrison’s masterpiece on the topic, and the subject of this review ‘Boom Bust‘.

Fred Harrison saw the property crash in the UK of 1989/90 in 1980, and furthermore, he named a date, he also named a date of specifically 2010 (as a bottom, not as the ‘start’ of a crash) in the mid 90’s. How? It is due to his analysis which goes back to the 1500’s of property cycles, and while I am still sceptical about his ’18 year’ cycle, the one thing that fully convinced me was the basis and need for a more rational and working approach to property and taxation of same, or the ‘democratisation …

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The tax of Regulation

It is worth noting that the constant calls for ‘Regulation’ are partly flawed, on one hand we do need more regulation, such as regulation of our Government agencies who can’t control their spending, regulation and accountability of our regulator, and of course (most importantly), some regulation of central banks who’s ability to keep rates too low and aid in the creation of money is closely linked with every major boom/bust in the last 100 years.

However, further regulation on financial services companies, and in particular small financial companies is not going to achieve the very aim it sets out to do, namely that of protecting consumers. It would be far better to have an ombudsman and regulator with teeth than to look for more laws that can be broken without retribution [in this respect banks have broken strict rules with almost total impunity].

Financial services are also a zero VAT business, this means that while we pay 21.5% VAT for everything we receive, we cannot charge VAT to our clients, thus, all of our …

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Why a rate cut is now inevitable

The ECB generally maintain that they are there to control inflation, normally we interpret this as ensuring that prices don’t get out of hand, or shoot up too quickly and indeed that is generally what rate changes are for, rates are raised to control price inflation. However, when the inverse happens (deflation or rapidly falling inflation) they will cut rates to stimulate the economy.

Today the treasury briefings put the flash estimate of inflation as being 1.6% while estimates were that it would be 1.8% which means that we are witnessing less inflation than expected and at a pace much faster than expected, if the ECB want to maintain inflation at ‘near but just below’ 2% then they have to reverse this trend and fast so there is strong likelihood that we will see a rate cut this week in order to achieve this (or at least work towards it!).

The Zero Interest Rate Policy (ZIRP) being pursued in the USA may come to our shores, the UK is already contemplating …

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Banks need to stress test themselves

Reverse stress testing has been advised by the FSA (Financial Services Authority) in the UK who have said that stress testing in UK financial firms is too weak to prevent another Northern Rock crisis. They are advising firms to do “reverse stress tests” to identify high-risk scenarios. The want banks, building societies, investment firms and insurers to consider scenarios that may cause their firms business to become unviable.

Normally ‘stress testing’ refers to something banks do when considering clients, they stress loan rates taking into account potential rate hikes, but they have never been asked to stress test their own business models in the way they are presently being asked to do.

In a consultation paper published yesterday, the FSA said UK firms were still not testing themselves against sufficiently severe scenarios. The proposed changes are intended to better reflect the importance that is attached to robust stress and scenario testing and to clarify the Regulators expectations of firms.

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The weight of compliance

Compliance is set to become a core area in financial services because one result of the current financial crisis is that people will want to prevent another similar disaster from occurring and the method used to fight this will be (likely) regulation.

After the Great Depression there was a wave of compliance and regulatory measures brought in and it was during this time that the FDIC (Federal Deposit Insurance Corporation) was created, thus guaranteeing depositors funds were safe.

Basel II which was seen as the ‘new’ answer to how risk was mitigated will probably be replaced by some other form of guidance, we’ll call it Basel III for the sake of prediction, or Basel II 2.0 or whatever you like. The fact is that the burden of compliance is set to rise but if not done correctly it could actually happen with little or no benefit to clients or the broader economy.

If compliance becomes weighted heavily in a process rather than principles based approach then it could hamper innovation and the creation of …

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