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Session 2010-12
Financial Conduct Authority
UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 1574
House of commons
oral EVIDENCE
Treasury Committee
Tuesday 25 October 2011
Angus Eaton, Paul Killik and Philip Warland
Evidence heard in Public Questions 1 - 51
This is an uncorrected transcript of evidence taken in public and reported to the House. The transcript has been placed on the internet on the authority of the Committee, and copies have been made available by the Vote Office for the use of Members and others.
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Oral Evidence
Taken before the Treasury Committee
on Tuesday 25 October 2011
Members present:
Mr Andrew Tyrie (Chair)
Michael Fallon
Mark Garnier
Stewart Hosie
Andrea Leadsom
Mr Andy Love
John Mann
Mr George Mudie
Jesse Norman
Mr David Ruffley
John Thurso
Examination of Witnesses
Witnesses: Angus Eaton, Operational and Regulatory Risk Director, Aviva Plc, Paul Killik, Senior Executive Officer and Partner, Killik & Co, and Philip Warland, Head of Public Policy, Fidelity, gave evidence.
Q1 Chair: Let us begin. Thank you very much for coming in this morning. As you can see, we have already had quite a busy morning on this, clearly. I don't know how much of what we have just been exchanging you were here for.
Can I begin by asking each of you to comment on the FSA's consultative document on how the FCA would be organised? I am quoting what they said in June: "The Government expects the FCA to intervene more strongly in retail financial service markets". Do you think that more intervention is what is needed and, if so, what type of intervention? Why don't I start on the right-hand side as I look and move leftwards?
Philip Warland: Thank you very much, Mr Chairman. We in Fidelity do believe that strong intervention is needed. I think that the litany that the Chairman of the FSA talked about last week at the Mansion House dinner-£15 billion of redress over a period-just suggests that something isn't working. What they have done up until now is largely looked at how products are sold, how they are advised, and never really got involved in the governance of the product, what the product was aiming to do and was it aimed at the right target market. To the extent that the FCA say, "That is where we think we would go," in principle, we think obviously they could get it seriously wrong and there are issues with openness of markets and competition, but in principle we think that is probably the next step they ought to be thinking about.
Angus Eaton: I think we can understand that intervention is an appropriate step to take now, although we would urge it to be approached in a measured way, in that there is always a danger that the regulator could take an over-protectionist approach without acknowledging the slightly wider public policy issue of ensuring that customers continue to have access to products in the market.
Paul Killik: I differ slightly with Philip on the intervention issue, I must admit. I do feel that the paper was too confrontational. The spirit of the February paper from the Treasury was much less confrontational, and I would like to see the regulator working much more closely with the industry than it is doing today.
Q2 Chair: Can you just explain what you mean by working closely as opposed to intervening?
Paul Killik: I think there is a sense, isn't there, that indeed, in part of the paper they are referring to the amount of analysis that they are doing of the industry. Analysis doesn't work at one level unless you are actually working with the industry itself in understanding it, and they have shown a distinct lack of interest in having a dialogue with the industry; at least that has been our experience.
Q3 Chair: This intervention, you are all confident that in practice this will have the desired effect or is likely to have a desired effect. We can all devise theoretical explanations for the need for intervention, but the crucial question is whether it is going to work. I just want to be clear on that.
Philip Warland: I don't think that you can prove in advance that it is going to work, but, as Angus has said, it seems to us to be a sensible next step. The way we see it working is although they do ask for powers to go out and ban products or withdraw them from the market, and so on and do forth, and-
Chair: We will be coming on to that in a minute.
Philip Warland: Okay. What we think is much more important-and they have already begun to do it a bit in their supervisory practice-is to look at what we would call product governance. If we produce a new product, do we understand the features of it, how it is likely to behave in stressed conditions? Do we take the view as to what part of the market it would be suitable to sell it into, and do we take a view that the advisers who are allowed to handle this product understand the features of the product and where it should end up? If that is the majority of what their "product intervention" is, we think it would be wholly beneficial.
Chair: Anything anybody wants to add before I move on? We are going to come back in some detail to a number of aspects.
Paul Killik: I think product intervention I certainly would agree with. I think there has to be more work done in that area.
Q4 Stewart Hosie: Mr Killik, you said that you were a victim of submission, that there was little detail of how the FCA would be accountable. They will be required to be accountable to us, producing an annual report, holding an annual public meeting and so on. But you have said it wasn't yet clear who would follow up what was in the annual report or conduct ongoing scrutiny of whether or not the FCA was meeting its objectives or operating in a reasonable or proportionate way. What would you have done? How would you like to see the FCA scrutinised in this regard?
Paul Killik: We have had subsequent conversations on this matter since we submitted our written evidence, but I think we are increasingly of the view that the PRA probably could play a role as a superior regulator here in some senses. At least there would be more of a peer group analysis of the FCA if it was undertaken by PRA.
Q5 Stewart Hosie: That is interesting because obviously the PRA are doing the prudential and the FCA are doing the conduct of business. That twin-peaks approach was designed with a particular reason. Would you then have the FCA as a subsidiary or underneath the PRA in that regard or would it simply be a peer assessment of the way they operate, how they behave?
Paul Killik: I think it makes some sense to do that, yes, because there are going to be probably some turf wars as between what is prudential and what is conduct of business.
Q6 Stewart Hosie: So, am I sensing that we could already begin to have an overlap of regulatory function to replace the underlap and the cracks we had under the old regime?
Paul Killik: I would not necessarily go that far, but I think that there has to be some sense in having a superior regulator, but this is a personal opinion. I am not speaking on behalf of my industry.
Q7 Stewart Hosie: Just one final question then. The Government did say in terms of accountability-and you have said you have had some discussions since-the process for the FCA replicates arrangements for the FSA where appropriate and strengthens them where possible. Do you think, given your experience with the FSA, that this is a good starting point for accountability?
Paul Killik: Do I think it is a starting point?
Stewart Hosie: Yes, is it a good starting point or would you have simply taken a clean sheet of paper and said, "Look, here's how we think you should behave."?
Paul Killik: I probably would have taken a clean sheet of paper on this. Yes, I do, I feel that this paper, from this consultative document on the FCA, was written by the FSA and therefore I am afraid it carries a lot of the baggage of the FSA with it.
Q8 Stewart Hosie: So the discussions you have had more recently then, have you suggested to them how they might change the way in which they operate or scrutinise and what has the response been?
Paul Killik: I have not been consulted in the matter at all. We put our own submissions in, but there has been no further consultation.
Stewart Hosie: Right, okay.
Q9 Michael Fallon: This Committee has previously recommended that competition should be a central objective. There seem to be mixed views in the industry about that. Would you agree with the Committee on that?
Paul Killik: Are you directing that to me?
Michael Fallon: Any of you.
Angus Eaton: We would certainly support competitiveness. We think the recommendation goes as far as it needs to in these circumstances. Speaking from the insurance markets' perspective, we consider the markets are competitive and I don't think we need to go any further.
Paul Killik: Yes, again, but I think there was a slight difference in emphasis between the Treasury paper of February and the FCA paper of June, where a more general discussion on the competition was referred to in the Treasury paper, which I would totally endorse. But it was very heavily consumer-weighted that the competition was only provided it was in the benefit of the consumer in the FCA paper.
Q10 Michael Fallon: How do you see the competition objective? It seems to be a catch-all duty now. How do you see it working in practice?
Philip Warland: If I could just say that we disagree with the view of this Committee. It is been argued over since 1984 when much of this was first legislated for. We think it is better to externalise the conflicts between investor protection and competition and to leave the competition where it is at the moment. I think, as I am sure you will when you get the FSA/FCA in front of you, they will set out some of the difficulties that they will have implementing a competition objective.
Q11 Michael Fallon: So you don't think the regulator should be bothered with competition?
Philip Warland: I don't think they should have anything stronger that they have regard to. I certainly don't think they should be considered a competition authority. They don't have the skills. I think they find it difficult to recruit the skills, which are very, very particular.
Q12 Michael Fallon: That is not because you think previous regulation has restricted or promoted competition; it is simply because you think they are the wrong people who are doing it?
Philip Warland: Yes. As I say, I think that the conflict is best handled externally-that is between the FSA and the OFT and the competition authorities. I think later on you are going to talk to witnesses who have the ability to make a super-complaint. That seems to me to be quite a good way to move ahead.
Q13 Michael Fallon: Do either of the other two of you think the competition objective should be more explicit?
Paul Killik: I would agree that it should be more explicit, yes. We have to balance commercial interests, but at the end of the day we are competitive businesses and I have seen examples of it recently where the playing field has been made unlevel by the regulator.
Angus Eaton: I would reinforce what I said earlier, in the sense that it is important for a regulator to have regard to competition in the decisions they make in delivering regulation into an industry. For instance, in the Retail Distribution Review some of the actions that have been taken, one could say, have restricted the number of advisers, for instance, in the market. So I think it is appropriate for a regulator to have regard to competition.
Michael Fallon: Thank you.
Q14 Mark Garnier: I shall start with Philip Warland, if I may, Mr Chairman, and then move to your right. In the draft Bill there is a table making it pretty clear how the regulatory system is going to work and how it is accountable to Parliament through the Chancellor. Do you think that that is a reasonable way of doing it? Do you have any comments on it and also what role do you think this Committee should play in the accountability?
Philip Warland: Broadly, we think that the accountability structure is far too weak and then there is the question as to whom it should be accountable to. Adair Turner has gone on the record-I think I am right in saying-that it should not be accountable to the industry, and in most respects that is true. I do think there should be more accountability to us in terms of their costs, and the NAO audits may have a look at that. But it is quite difficult to look at efficiency and costs without also taking a view on are they meeting their objectives correctly, which I tend to agree. I don't think we should be the arbiters of that. So some mechanism, which allowed a discussion, other than the Practitioner Committee that does not seem to work, between the industry and the regulator-not on a firm-by-firm basis, but on a genuine industry basis-we think would be very helpful and we could point to some places where we think it has gone wrong. We say in our paper that we think that the FCA should make an annual report to yourselves, rather like you have just had the Governor here talking about MPC decisions. I think what the FCA does is not on a quarterly round, but if they had to justify themselves against their objectives to you and you were to hold hearings, we would take considerable comfort from that.
Andrew Eaton: We certainly support this Committee being engaged in the scrutiny of this regulator. From an accountability perspective, we would also add that it is important that the board itself that runs the FCA has been appointed in a transparent way and has a broad representation from the industry and consumers.
Paul Killik: Yes, and I would certainly very much support the broad representation from the industry. One of the weaknesses of the current system is that-as I alluded to earlier on-there is far too little inter-exchange between the regulator and the industry. Indeed, when we are going further away from that with the greater use of call centres and fewer relationship-managed businesses, it just means the regulator gets further and further away from the industry that they are regulating. But coming back to the point of accountability, I would certainly support that the regulator should be accountable to this group, but I also believe that there is some merit in making it accountable to PRA initially.
Q15 Mark Garnier: Fresh in many people's mind is the regulator's response to this Committee's Report on the Retail Distribution Review. Many people have said in the press, and just anecdotally, that this shows a huge amount of contempt for Parliament by the FSA. Do you think that is a fair comment?
Paul Killik: I do, yes.
Mark Garnier: Do you?
Andrew Eaton: As I said, I think it is appropriate that is accountable to this Committee. If that gets hard-coded into the process, then I think they will respond appropriately.
Q16 Mark Garnier: But if they sort of suck their teeth and say, "Yeah, well so what, we will just do whatever we want," how do you think this Committee should be able to come back and make them accountable?
Andrew Eaton: I think the key is transparency. It is important that these issues are raised publicly and the regulator itself is not given the opportunity to operate in quite a closed way.
Q17 Mark Garnier: So there is an argument that they have been transparently contemptuous of the views of this Committee?
Andrew Eaton: That might be an argument, but I still think the transparency is important.
Philip Warland: I agree. I think you have done the world a service in some of the investigations you have had, and I don't know whether you have done it or not, but you might consider having not only the executives here, but actually some of the independent board members. I don't know whether you have done that, but that might just raise the ante a bit.
Q18 Mark Garnier: Can I just very briefly return to the costs? We have two large organisations and one, with great respect, small organisation. You all pay fees to the FSA and you also all have to dedicate resources, in terms of maintaining your compliance function and all the rest of it. Paul Killik, speaking as somebody from a smaller firm-your two colleagues-do you think the cost of the regulatory system disadvantages smaller firms and, as you get smaller, it becomes more of a disadvantage or do you think that is an irrelevant argument?
Paul Killik: Yes, I do. I think it would have been very difficult. I set my business up in 1989. I think it would be a very, very difficult job to start that business up today, to be perfectly honest, I really do. We were helped in starting up business by the regulator of the day, the TSA, who were enormously supportive and helped us with the whole formal completion process. You don't get any of that today from the regulator. So it is a very different world in that sense. As for costs, yes, if you look at the FSA's bill for this year of £500 million and you put that into context, and I know the figure of £15 billion that has been paid out over 20 years is a big number, but simple maths tells you that is £750 million a year. Well, already, we are spending two-thirds of what we are paying in compensation in running a regulator. Then, of course, you have the regulatory cost to all the individual firms, which is a multiplier of the cost of running the FSA. So the cost to the consumer of regulation, in its present form, is huge and I do not think people really recognise how big it is.
Q19 Mark Garnier: To the other two witnesses. That is an incredibly important point. As two big organisations, presumably you have to push the cost of your regulatory departments and the cost of your membership of the FSA down to the consumer. So effectively what you are saying is the cost of regulation, be it direct fees to the FSA or compensation fees or the cost of compliance actually is detracting from the savings culture of this country, ultimately?
Philip Warland: Certainly in our case-and although we are larger than Paul's firm we have a similar business model-the problem we have is the FSA has always treated us as an investment bank when we are not. We are an agency business. So our cost of capital has gone up 10 times in the last three years and our total costs of internal compliance have gone up 70%. We think that is wholly unnecessary and we don't believe they understand our business model. The good news is that early discussions with the proto FCA suggest they do understand that, in a fortuitous way, what they have created with the FCA is a regulator for whom prudential capital is not the key issue, and they are already beginning to think, "How do we have a supervisory practice that deals with agency firms?" where, frankly, if a parent goes down-you can see that from Barings; Barings went down over the weekend. On the Tuesday, the unit trust business was working again. That is our business model and they have never paid attention to that. But yes, those costs that they have inflicted on us will lower the savings rate.
Angus Eaton: I think you are right. The costs are perpetual in the industry, and in fact we would urge stability, if anything, to be honest with you. They manifest themselves in many ways. It is not just regulatory departments. It is clearly big-change initiatives as well. Solvency too costs £100 million per insurance company, for instance. So we would urge that stability. To your question; yes, ultimately, I think the customer will carry it. Hence the reason why we think the regulator should have regard to the ultimate impact on the customer.
Q20 Mark Garnier: Just finally, do you all agree that regulatory stability is key to keeping costs down?
Paul Killik: Absolutely.
Mark Garnier: Okay, thank you for that.
Q21 Chair: Mr Warland, in your submission you said that you were perplexed by the objectives of the Bill, but from what I could tell you were broadly supportive in your opening remarks, or not too critical anyway, and I would be grateful if you could tell me which bits are perplexing you.
Philip Warland: Mainly it is the overlap. If you look at the objectives of the FPC, then the PRA and then the FCA, they all have elements that seem to us to be coterminous. That seems pretty well a recipe for argument and dissent, and so on and so forth. I suppose we would prefer to see something that is much clearer, which is a reference to market integrity, which is one side of the FCA, and a reference to consumer protection that in a sense is the other side of the FCA. Then, as we have set out in the paper, we actually think having regard to international competitiveness is very important too.
Q22 Chair: You have said that you support product regulation. The regulators themselves have said that this will cost more overall. A moment ago I thought I understood you to say you weren't happy about this rise in regulatory cost. Do you think that the type of product regulation you envisage can be delivered for less or the same that is spent at the moment on regulation?
Philip Warland: I made those remarks, and can try and square the circle by saying that I believe the FCA should and, I think, is thinking of a completely different supervisory approach. At the moment, when they come and visit us they do an ARROW visit, and the ARROW visit was based on, "How the banks go wrong and let's stop it". The supervisory approach I believe that they should use for a firm like ours should be completely different. It will not start, or it should not start, with prudential capital and complicated policy-adjusted stress tests of how you get there because, as I have described, prudential capital is not where we are most likely to cause detriment to customers. But if a lot of that is stripped away that is what will push back our compliance costs and if there is a little more on product governance. Frankly, we think we have it in there anyway without being told to do it. So we believe there would be a way to protect the public and yet lower the overall cost base.
Chair: Just one other point just for clarity. There was a general nodding of agreement when the suggestion was made-I think by you, Mr Warland-that independent board members might be given a greater role. Maybe not now, but if you have suggestions on how they may be engaged to secure greater accountability to the FCA, this Committee is interested in hearing your views.
Q23 David Ruffley: Mr Killik, the paper that you submitted to us was interesting where you talk about, "Engagement with industry bodies could help a more segmented approach". You also draw our attention to the fact that in the FSA June paper they were actively talking about reducing the number of relationship-managed firms, and you propose to remedy that. An element of self-regulation and a key part of that would be putting together a panel of professionals, retired professionals, who could give knowledge and advice, I am assuming, to the FCA staff. I just wondered what reaction you have had from policymakers, either at the Treasury or the FSA, to that proposal.
Paul Killik: I have not had any. I have not had consultations with them, so I have not had a response.
Q24 David Ruffley: You have not floated it at all?
Paul Killik: I have in papers, but I had no particular response to them.
Q25 David Ruffley: Did you expect a response?
Paul Killik: It would have been nice to have had a response, but in some senses I am not altogether surprised.
Q26 David Ruffley: I just wondered, because it seems an interesting idea. It is a contribution to the debate. Would you have support from the rest of your industry for that?
Paul Killik: Without a shred of a doubt. I think by putting it forward as people at the latter end of their careers, nobody could accuse practitioners of looking after their own interests, but they are coming with a lifetime's experience. We are currently seeing people being retired out of businesses, at 60, 65 these days, who have probably got another 10 years or at least five years of work within them and they would like to contribute in that way, I am quite sure. It would be beneficial for the whole industry and certainly, I believe, useful for the regulator to have that sort of resource internally.
Q27 David Ruffley: I infer from what you just said in your proposals that you don't entirely have faith in the likely expertise of staff on the FCA, because in your submission you made clear that in terms of products, the understanding of products, it would be sensible to have some retired practitioners who have been involved in the market for these products and services. You presumably do not believe, or have much faith, that the FCA will be able to recruit such expertise, hence the need for your panel?
Paul Killik: Absolutely. I have been in one small sector of financial services for 40 years, and I can't claim to be an expert in all aspects of my small segment. It is hugely complex, the whole gamut of the financial services industries. Therefore, to recruit people and believe that you can then train them internally, without any interface with the businesses that they are regulating, strikes me as a bizarre concept. I know how long it takes me to train chaps up before I put them on the telephone to talk to clients. That is a very long process. We are wasting resource when we have people who would happily contribute, I believe, and not using that level of experience.
Q28 David Ruffley: You did not propose this; the June FSA paper proposed that the number of relationship-managed firms be-and I quote-"significantly reduced". To the layman, this seems to be the opposite of what we-
Paul Killik: You are absolutely correct, and since that paper was written by us we have actually been notified that we are now going on to a call centre. As you have rightly observed, we are not a big business, but we are a very particular niche of our industry and I think the FCA are going to be poorer by not having contact with us and understanding where we believe our industry is going.
Q29 David Ruffley: Your views have been given by yourself as an individual. What I am quite keen to understand is, are there other serious concerns of the kind you have identified prevalent in the rest of the industry?
Paul Killik: Yes, there are. I would add that I am a director. I am on the board of APCIMS, which is a trade association for our industry. I have been on that board now for about 15 years, so I am pretty well plugged into the thinking of the industry.
Q30 Mr Ruffley: Of course, APCIMS is a very important trade body. Are they going to make a fuss about this?
Paul Killik: They have made submissions both to the Treasury Select Committee, and also to the Financial Services Group, Peter Lilley's group, as well as, obviously, having dialogue with the FSA. I am not sure yet whether they are in a dialogue with anyone at the FCA.
Q31 Mr Ruffley: Would you think that the idea of a single supervisor across many different product areas is a bad idea?
Paul Killik: What I think is a bad idea is a one-size-fits-all concept. To take a very high-level view of regulation, from a rather analytical approach to it, without understanding the business models of the various companies underneath it, you end up with the regulator effectively designing the business model for our industry. That is not healthy because we are all being shoehorned into a one-size-fits-all regime.
Q32 Mr Ruffley: On that important point, can I ask Mr Eaton and Mr Warland what their comments would be on that issue?
Angus Eaton: I think from our perspective the-
Mr Ruffley: That is, essentially civil servants putting together a model with perhaps limited experience of the products and the industry that they are designing this regime for?
Angus Eaton: We would certainly support the view that it is essential that the regulator has the capability to do what it is set up to do. I endorse Paul's comments, in the sense of that is not an easy thing to do. I would say my fear is these recommendations are predicated on the assumption that the industry itself isn't taking this seriously and not taking consumers seriously. We have invested an enormous amount in product development and have engaged regulators through our product development processes in a positive way. The danger is that if they separately try and analyse the industry in a way that is the broad brush approach, which I think was suggested, that could give rise to issues.
Q33 Mr Ruffley: This could potentially be quite calamitous for your business-not just your business, but for the industry. Would you go that far?
Angus Eaton: I would say the key for us is in understanding the consumer and the regulator needs to have the capability to do that. If we don't understand the end consumer then I think there are issues.
Mr Ruffley: Mr Warland?
Philip Warland: A number of points. First on experience, in general I agree absolutely. I have been in the asset management industry now for 20 years and I can only think of one person who has ever been in the FSA who actually had business experience of the asset management industry. That is the first thing. The second thing I have to confess is that the FSA does have senior advisers who used to be called, "Grey Panthers". The predecessor in my job here in Fidelity was actually an old Grey Panther in the FSA. So they do have that experience in the FSA. But the biggest thing we suffer from is precisely what Paul has described: they do not understand our business model and they throw a whole series of regulations at us, which are really irrelevant and just add to cost. One big one is they talk about governance. They think governance is the way they govern the FSA, which is committee after committee after committee after committee, and we do not think that is a good way to run a business.
Mr Ruffley: Thank you.
Q34 Chair: I am suddenly curious about a witness who says they don't understand your business model but you want them to do product regulation.
Philip Warland: I absolutely agree. There is a whole list of things in where the FCA is going where they don't have the skills. So, they don't have the skills in the business model, therefore they won't have the skills in the product, they won't have the skills in competition. We have discussed it with the proto FCA and they absolutely admit that the thing they are designing-I think it is called the Business Analysis Unit-they don't have at the moment, and I am not sure they know where they are going to get their people. But as an aspiration we think it is not a bad way to go.
Q35 Chair: But it sounds as if the aspiration is already likely to be a triumph of hope over experience?
Philip Warland: You might think that.
Chair: No, I am only drawing on your own evidence that they don't understand the business models.
Philip Warland: Absolutely; no, I agree with that. But I should say that I think they are beginning to understand that they do not understand it.
Chair: He who doesn't know and knows he doesn't know.
Philip Warland: Yes, slightly listening.
Chair: I forget, or at least I won't repeat ,the end of that line, because it is a little bit too impolite to the FSA.
Q36 John Thurso: The PRA is seen by some as kind of the big brother in this supposed twin peak; it has the veto, it has the big voice. What is the danger that, instead of it being a true twin peak, it is more of a mountain and a foothill and of the FCA becoming very much the kind of second cousin in the arrangement? Do you see that as a danger? Perhaps we will start with, Mr Killik.
Paul Killik: No, I actually think that would be positive to be perfectly honest.
Q37 John Thurso: You think it will happen or it won't happen and you think it is a danger or not a danger?
Paul Killik: I don't see it as a danger. It is difficult to predict whether it will or won't happen, but I think there is certain merit. Certainly, looking at the accountability of the conduct of business side, I feel that is the area that I am most nervous about. Therefore, having the regulator answerable to a peer group at the PRA I think would make me feel a lot more comfortable.
Q38 John Thurso: That assumes that they would be answerable to them.
Paul Killik: Or accountable.
John Thurso: Or accountable to them. Whereas the system as it is currently designed is that they both have equal accountability, so that the danger would be that they become much more aggressive and difficult, because they are trying to compete with the big brother, or indeed more relaxed because big brother is doing it, but you don't see those as dangers?
Paul Killik: I don't.
John Thurso: Does anybody else want to add to that?
Angus Eaton: I am happy to speak on that as an organisation that would be regulated by both regulators. The double regulation issue is one that we are concerned about, in the sense that our experience is while the structure of regulation is important, it is actually its operational effectiveness that is essential. We would urge the recommendation to go further and ensure that both regulators share services where it is appropriate to do so, and indeed interact from a single point, because the danger of two regulators coming in from different angles can only drive some confusion, and indeed costs, coming back to the comments earlier.
Q39 John Thurso: So your concern would be they would each go off and do their own thing and you end up having two sets of compliance, two sets of regulation and a double load of bureaucracy?
Angus Eaton: We can see that as a potential risk, yes.
Q40 John Thurso: What other impact would it have on a firm such as yours, which is going to be dual regulated? Are there any other areas of concern?
Angus Eaton: I think it is the co-ordination, ostensibly, which is the heart of our concern, from experience in trades. We completely respect the fact that conduct regulation is important and needs to have the appropriate airtime, and indeed we see that as a very important component of our business. With two regulators, and indeed other regulators, balancing that is a challenge for us.
Q41 John Thurso: For example, on compliance, do you see this as being double the amount of compliance required by you, because you will have to be doing two sets of compliance, or should it be one set of compliance that satisfies both?
Angus Eaton: Ideally, we would like one set of compliance if that was possible.
John Thurso: There's a surprise.
Angus Eaton: We should not lose sight of the fact that clearly there is a prudential regulator and a conduct regulator, so by their nature they are different topics. But there are some specifics-for instance, approved individuals with the regulators. There is the danger that the regulators could come in. We would be approving individuals by two different regulators, which, you know-
Q42 John Thurso: You will be regulated for conduct of business only by the FCA and you will be regulated for the prudential side by the PRA. By contrast, Mr Killik's firm will be regulated for both conduct of business and the prudential by the FCA. So he will only have one person to deal with; you will have two.
Angus Eaton: That is right.
John Thurso: However hard one tries with architecture, we nearly always get it wrong. Is there not a danger that actually you are going to end up-sorry, it is a fact of life, isn't it?-with two masters or two people to satisfy, while Mr Killik only has one? It is really trying to understand the risks in that and of giving you the opportunity to tell us what we should be looking for, and I will come to Mr Warland next on this.
Angus Eaton: Yes, there is clearly that danger. I think we would just add we do have a fund manager as well who, in theory, could be regulated by one regulator so we have that added complication as well. I would reinforce the point that double regulation could drive costs to consumers, and anything that can be done to drive the efficiency in the process between the regulators is something that we would support.
Q43 John Thurso: Mr Warland, if you would like to address that as well, but also, particularly around the question of the PRA's veto, because we can have a situation where the FCA might take a decision on product and the PRA would then veto it. To what extent is that going to get us into difficult territory?
Philip Warland: We think there is a danger there, and I think we gave an example in our paper where, had the PRA and the FCA existed when PPI came forward, the FCA might say, "This is very, very bad, that conduct of business," and the PRA might say, "But we really don't want to take any million, billion pounds out of banks' capital at the moment," and you can see that sort of tension arising. So I think there will have to be very close co-ordination, as Angus and others have said. We are slightly schizophrenic I have to say, because one of the problems with asset management and securities prudential capital is that, in Europe, and only in Europe anywhere in the world, our capital is actually set by a banking directive. There was a reason for that many years ago when CRD first came in, but that reason has gone away. Again, our early discussion with the proto FCA has made it clear that they understand that if you were to define anew what a capital regime looks like for a firm like ours, which is almost 100% FCA agency business, you would not start with the banking model. We think that is a very hopeful idea and we just hope that the PRA don't get in the way of it.
Q44 John Thurso: But as you pointed out in your paper, you clearly see that danger that, as with PPI, you can have a situation where the clear consumer interest might be to do something but a prudential authority might take a different view, and is that not an area that really needs to be fleshed out in legislation? For example, in the Crown Estates there is a veto reserved for Ministers that is never used. It is described as a nuclear option, but it never, ever gets used. I mean that is one possibility: you end up with no veto ever being used so it is pointless. Or the other is it is used too often, which completely takes away from the conduct regulation?
Philip Warland: I think you understand these matters in terms of legislation better than I do, but where you are headed I would agree with you.
John Thurso: Thank you.
Q45 Andy Love: Can I come back to the issue of intervention, which we touched upon at the beginning? I am interpreting now, but my interpretation of what you said was that for all the reasons that we know about-mis-selling and other issues in the marketplace-there is the recognition of the need for greater intervention. But of course the FCA envisages having a power to ban products and issue public warning notices. Is that going too far? Perhaps I will start with you, Mr Warland. You were the most sympathetic, if I could say that? Is it going too far?
Philip Warland: Maybe I should say why, I suppose, we are sympathetic is that our product-the one we use the most-which is the mutual fund, is of course totally regulated. So we are not scared about product regulation and that makes us different, probably, from Mr Eaton. We suspect and believe that the FCA would use the power to ban a product only in the most extreme circumstances, and there have been recent cases, Keydata being the most obvious one, or the Lifemark Bond, where, had they seen it coming and had they had the powers, they might either have said, "You can't do that," which would have been difficult because it was an overseas product, but they could have stopped the advisers selling it. If they had those powers, that would have been both for the good of individuals who bought the stuff and for us who have paid the compensation, or the redress. So, if it is used rarely, then as a reserve power we think that probably could be quite a good idea.
Q46 Andy Love: Mr Eaton, as seductive the argument that PPI could have been stopped in its tracks if they had had these powers, what is the other side of that equation? We understand what it might do and what it might achieve by intervening, but from your perspective what is the downside to that?
Angus Eaton: I think I will start at a macro level, in the sense that there are a number of actors in this industry who have a responsibility to build the confidence back into this industry-one of those actors is the regulator-including ourselves as well. The regulator should exercise its powers in a measured way. I think our fear, for instance, on the warning notice that you cited would be that that could be a tool that was used to publicise potential investigations and not used in a measured way. That itself could undermine the overall reputation of the industry as a whole. So, echoing Philip's comment, it is all about measured, proportionate approach. But if this is a tool that is used in an unfettered way then we do have a fear that it is going to undermine the confidence in this industry that, of course, is already very delicate.
Q47 Andy Love: Mr Killik, guilty without being able to prove your innocence. Do you think that is a real danger and how can we protect firms against an overweening regulator?
Paul Killik: I come at it in a slightly different way. I think there is a lot of sense coming out of Brussels in the concept of simple and complex products. Again, going back a number of years, I remember the days when a unit trust was a unit trust, which was a long-only fund; it could not short, there was no leverage involved and it was basically what it said on the can. These days we all talk about funds, which can be anything from a hedge fund-a very complicated, structured product-to a very simple old-fashioned-style unit trust. I do think that, rather than banning products, probably it is a matter of ensuring that the person purchasing a product can understand what is in the product. Therefore, I think the concept of having a simple product, which can be bought widely by everybody, but keeping complicated products for those who can demonstrate that they have some knowledge and experience and can understand the risks of the product they are buying, has quite a lot of merit and bears further investigation.
Q48 Andy Love: Early-warning notices, what would be the impact? I am thinking about Mr Warland and Mr Eaton primarily here. What would be the impact on your firm if an early-warning notice was issued, in terms of your investors and your employees?
Philip Warland: The first thing to say is that we hope it would not happen. I went back through the records and I can't find a reference to the Ombudsmen that has been upheld for quite some time back. We, as Angus says, start with the consumer. In extreme cases, if the regulator sees that there is likely to be further damage if they do not say, "We think there is something going wrong here," again, as a reserve power, one can see the point or one can see that it could be very helpful. But I also agree with Angus that if you get a constant stream of these things, some of which will turn out not to stand up, then what it will do is it will damage confidence, and one idea we have is to perhaps involve the RDC and make the RDC a statutory body and let them make the judgment as to whether this is in the public interest. So, as a reserve power it is difficult to argue against, but how it is used is the issue.
Q49 Andy Love: Taking that up, Mr Eaton, the fact of issuing such a notice would have an impact, particularly on your investors, so how do you presume that we can protect against that happening? What protections need to be in the legislation to ensure that that will only be done in extreme cases, and when it is done it will be done in consultation with the affected parties?
Angus Eaton: Certainly speaking from experience, my experience of a regulator is to work in a constructive and open way with them as we build products, which is what we do now. I think that will mitigate the risk. I would echo Philip's words. We certainly hope we don't receive such a notice, but it would mitigate us ever getting to that point because we have built products that ultimately service the consumer and are demonstrated to service the consumer and-to Paul's point-the consumer understands what they are buying. So, I think that is where one should start. When it comes to a regulator actually deciding to issue such a notice, then I think the regulator should be accountable, perhaps to a tribunal or a higher body, or higher up, before they decide to take that action. I think the concern as well is that because it is connected with publicity and publicising that notice, that in itself is a big step to take for a regulator, which is not the way they exercise it at present.
Q50 Andy Love: Can I come onto a different issue. Mr Killik, you talked in your submission to us about a heavy-handed regulator, and you mentioned in the initial questions from the Chairman the confrontational attitude that you detected. In your paper, you talked about stifling innovation as a result of heavy-handed regulation. Can you expand on that for us?
Paul Killik: This is a combination both of heavy-handed regulation and also the one-size-fits-all concept. We all have to change our business models to fit with the regulator. That, per se, reduces the ability to innovate. You are being occupied with having to change the business model and not with the further development of the business.
Andy Love: Any of the other two want to comment on that?
Philip Warland: I think in our case it is their not understanding the business model and so they get their supervisory practice pretty well wrong.
Q51 Andy Love: Can I ask all three of you a final question. We are seeing here a more interventionist Financial Conduct Authority. We talked about dual regulation and the consequences of dual regulation with the PRA. There has also been quite a lot of comment about the lack of skills and the need for, particularly, the FCA to up-skill its employees, and you mentioned in particular not understanding the business model. Does all that add up, if we are going to have an effective regulator that it is actually going to cost the industry more? We are being told at the moment that it won't cost the industry more, but in effect all these things, if they are addressed, will actually lead to an increase in costs. What is your view? Mr Warland?
Philip Warland: Certainly that is a potential danger, and if they have to recruit a number of new skills, which I think they do, but if they also alter the way they carry out regulation and make it more appropriate to our business, then we believe actually the costs could drop, so it would be more appropriate. In certain areas it might be more intrusive. That would be pretty difficult these days. But we do think that they can get better investor protection at a lower cost if they are clever.
Andy Love: So you believe in interventionist light-touch regulation?
Philip Warland: No, I don't think I said that. I think they should intervene and be intrusive where that protects the investor. They do it at the moment where it is totally irrelevant.
Andy Love: Mr Eaton, what is your view?
Angus Eaton: I think there is clearly the risk that you have articulated. I think one area that there ought to be some focus on is the regulator demonstrating, from a cost-benefit perspective, the actions that they are taking and being transparent about that, and then retrospectively assessing the impact of what they have done. I think they are attempting to build some capability that could do that, so it is a case of learning and mitigating that cost because, as we said earlier, ultimately it could be the consumer that carries that cost.
Andy Love: Mr Killik?
Paul Killik: I don't think I have anything to add to either Philip or Angus, bar one point. It is often referred to as a cost to the industry. It is actually a cost to the consumer. Ultimately, it is only the consumer who can pay and that is often lost sight of.
Andy Love: I thought you would be less worried about the consumer and more worried about your own cost structures, but I take your point.
Chair: Thank you very much for coming before us today. You have given us a lot of interesting evidence. If you have more thoughts as a consequence of the hearing, please come back to us in writing. We certainly have one regulatory optimist at least among us. It is something of a surprise. I would be very grateful in particular if the point that you just made, Mr Eaton, were fleshed out more. You have argued for greater transparency in almost every reply you have given-transparency for costs and benefits. A cost-benefit analysis is manifestly lacking and we need the industry to supply it to us, of which regulatory costs, obviously, is an important part of the equation. Thank you very much for giving evidence today.


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The experts at Heritage Plumbing will ensure that your Grants Pass, OR Plumbing needs are met with satisfaction. We offer a wide variety of outstanding services.
Heritage Plumbing is located at the address 2190 Se Portola Dr in Grants Pass, Oregon 97526. They can be contacted via phone at (541) 582-2171 for pricing, hours and directions. Heritage Plumbing specializes in Grease & Sludge, Custom Construction, Tennis Courts.
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Other Landscapes, a new series of photographs from Larry Torno Photo, opens with three inaugural images.
Each image is printed on archival paper, matted and framed in white, to 32" x 24".
This is an open edition.
Follow the link for the slideshow https://larrytornophoto.com/link/otherlandscapes or view the images below.
THANK YOU for your viewership.


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Definition of Bull
What does the term "bull" mean as it applies to the world of investing? What is the definition of the term "bull"?
A "bull" is somebody who believes that a certain asset (or the market in general) is set to rise in value.
For instance, a "gold bull" is somebody who is "bullish" on the price of gold, meaning they believe that the price of gold is set to rise from its current levels.
Or, another example - let's say that you believe that shares of Microsoft are going to increase over the short-term due to a new product release. You think that the fundamentals of the company are sound, and you also believe that the shares are being undervalued by the market. In this case, you would be a "bull" on Microsoft (or "bullish" on Microsoft), due to the fact that you believe that shares of the company are going to be heading higher.
The opposite of a bull? A bear. A bear is a person who believe that the market or an individual asset is going to drop in value.
Davemanuel.com Articles That Mention Bull:
The WeWork IPO: Investors Finally Say "No Mas"
How Do Calls and Puts Work in the Stock Market?
Is Tesla Inc. The Most Polarizing Company in the History of the Stock Market?
How Will The Younger Generation of Investors Handle a Bear Market?
Volatility Reigns Supreme in Publicly Traded Marijuana Stocks


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Innovative backyards and patios are being constructed which have their own outdoor furniture purchase requirements. Trends in home furnishings industry continue changing with every passing year.
These markets have been getting different sets of requirements over the last couple of years or so. The exterior equipment can be garden furniture collections, cheap garden furniture and sales of garden furniture.
Furniture has many forms; most of them are for indoor home use, but some are for open-air use. Regardless of what sort of chairs and tables that you want to buy, it's never a simple task to accomplish. Folks desire a mix of several factors such as coziness, low maintenance, Merritt Island Opossum Removal, and last but not the least having good looks. As everybody has their own set of criteria for selecting the right fit, marketers will need to be proactive in their own campaigns.
We discuss some of the latest sizzling summer styles in garden furniture:
An individual can offer a array of options to its clients from high end to midsize and low price fittings. Vast majority of the wooden terrace fitments are costly in nature. They're high maintenance but a few are resistant to weather such as teak. You can even go for the cheaper ones and put on a few pay on them for security.
As stated earlier, wooden terrace chattels will require regular use of oil to keep its original condition.
Due to very high costs of wooden outdoor furniture, the metal has evolved as a favorite choice among many. Largely, made with aluminum, which is very light weight in addition to easy to keep. The other choice is obviously steel.
Both aluminum and steel demand powder coating as a protective finish. They come in various options for customers in exactly the same price range.
Vinyl gear is normally fragile. They're best suited to be used for the outdoor furniture use since they're extremely low maintenance.
For the majority of the folks who desire to enjoy sunlight in afternoon, an outdoor couch is the ideal choice. The have a mix of powder covered steel together with cushions. The exterior fabric sofas provide comfort and coziness that simply can't be matched to interior fittings.
So, these are some of the greatest ideas in outdoor furniture collections that people wish to buy. An individual can opt for any one of these options depending on the nature of its requirements.
Before you get all excited to purchase garden furniture, consider what you really want. Doing this will help you create the perfect garden look, one that will make family and friends content.


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My name is Marlene Pearce. I was elected President of PROBUS Canada for the year starting May 3, 2019. It is my pleasure to welcome you, both existing members of PROBUS Canada and those inquiring about PROBUS, to our newly designed website. PROBUS is an acronym of the words Professional (PRO) and Business (BUS). We are an organization that welcomes people from all walks of life. In one-word PROBUS is Companionship. As members we enjoy the company of other retirees with similar interests and keep active in our retired years.
I live in Moncton, New Brunswick, am a member of two Clubs, the Women's Club of South Eastern New Brunswick and the PROBUS Club of Shediac Shores, a mixed club.
PROBUS Canada has 13 Directors located across the country who are elected by the clubs in each district. These Directors help to disseminate information, advise and assist clubs, accredit new clubs and protect and promote the PROBUS name and logo and spirit of the PROBUS organization.
PROBUS in Canada was started in 1987, has over 250 active clubs and 38,000 plus members. We are an organization that provides social, physical and mental stimulus to retirees. We provide the opportunity to meet men and women in similar situations as themselves and choose those interest activities and social events you wish to participate in. Most of the clubs are combined for men and women while some are either men or women only. Our clubs meet monthly, invite an interesting guest speaker, allow time to socialize with members and get updates and sign up for the various activities the club is planning. Members throughout the year share companionship through the many activities that each club has to offer. PROBUS is a great way to meet and socialize with other members who are likely to become close friends as we grow older in our retired years. While there is much activity and work to do with PROBUS, it is a wonderful investment of time. What one gets back in memories, knowledge, and experience is rich and rewarding. There is no better way than to spend time with the people of PROBUS.
I enjoy hearing from PROBUS members, about their experiences, and their ideas on how to make PROBUS Canada even better for all of us. I welcome anyone to contact me and I will be happy to advise you on all things PROBUS.
I am pleased to be your President and on behalf of the PROBUS Board of Directors and with your feedback, we will continually seek ways to improve and grow PROBUS Canada for the benefit of all retirees, coast to coast.
Marlene Pearce, President, PROBUS Canada.


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Personalised 'R.I.P Sleep' Coloured Leather Keyring
Regular price £15.00
This personalised leather keyring, stamped with 'R.I.P SLEEP', makes the perfect gift for a new mum or dad.
The keyring is the ideal gift for birthdays, Father's Day, Mother's Day or stocking fillers, and the humorous slogan is something sleep-deprived new parents are sure to relate to. As well as the message, you can personalise the keyring with up to 8 characters of text, which are individually stamped by hand with gold foil and a traditional hot press. A name, initials or special date make each item completely unique.
There are five exciting colour options to choose from to suit all personalities: black, blue, blush pink, mint green or red. The bold black and red are sure to make a statement, while the muted pastel tones are bang on trend. All colours beautifully compliment the gold lettering.
*Please note, this cannot be used in conjunction with any other offer.
Each keyring measures approximately 7.5cm x 1.5cm x 0.3cm
Made from sustainably sourced British cowhide leather and solid brass fixings.
As leather is a beautiful, natural product, please note colour and grain may vary from the pictures shown. All keyrings are designed and made by us here in the New Forest, UK, from sustainably sourced materials.
UK standard delivery
- £1.95 or free over £20
- 2-4 day lead time
Tracked express delivery
- £4.95
- Delivered within 2 working days
International delivery
- Worldwide delivery available
- Cost calculated at checkout


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While their working relationship and close friendship have always been public, recent pictures have surfaced of Lorde seeming more than friendly with Fun. guitarist Jack Antonoff in her hometown of Auckland, New Zealand, according to The Daily Mail. The 21-year-old singer had her arms wrapped pretty tightly around Antonoff while they were out and about, even walking with linked arms at some points.
It's only been a few weeks since Antonoff announced his split from Girls creator Lena Dunham, whom he had been dating since 2012, but he's already gone on record to clarify he's not currently dating anyone. "Normally I would never address rumors but I resent having the most important friendships and working relationships in my life reduced to dumb hetero normative gossip," he tweeted in mid-January. "With that said, I'm not seeing anyone."
While that may have been the case in January, these photos might be telling a slightly different story. The pair collaborates frequently, with Antonoff having written 10 songs on Lorde's Grammy-nominated album, Melodrama. Just ahead of this year's Grammy Awards, a source told The Daily Mail the two appeared "very much like a couple" at Clive Davis' annual party in New York City. 'They were very cute at Clive's party, he never left her side," the source claimed. "It was obvious they are dating. He couldn't keep his eyes off her. She looked very smitten as well, as if she was hooked. They are definitely more than friends."
Also Watch


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Petra Low
Telescopic cover with three angles with aluminum structure without rails to the ground.
The modules have a length of 2.10 m introducing one inside the other for its opening.
Opening can be total (from one end to the other) or central (from the Center to the ends).
Standar colors
- White RAL 9010
- Green RAL 6009
- Beige RAL 1015
Polycarbonate ribbed sheet clear roof and SAN clear. SAN clear on facade, bottom and sides.
Any other color of the RAL or finished wood.
- Facades swing arm, fixed or removable depending on the width of the cover with a sliding door on a worksheet according to your height.
- Back fixed with a central sliding door of a freightage.
- Minimum internal height of 1, 20 m, 0.90 m, 0.60 m, 0.30 m.


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SKB Standard 5-Piece Drum Bag Set
with 22 in. Bass Drum
(with 22 in. Bass Drum)
Sku #J23667000001000
Drum Gig Bags & Covers
- Write a Review
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SKB-quality soft drum bags for the local gigging drummer.
Ranging in size from 8" toms to 24" kick drums, SKB drum gig bags provide drummers another option for protecting their percussion assets. This 5-piece SKB gig bag set is constructed of ballistic nylon and features heavy-duty dual zippers and lined interiors. All bags include ergonomic handles with double-stitched straps for maximum durability. Case sizes can accommodate various depths.
The 5-bag 1SKB-DBS1 fits up to 10" x 9" and 12" x 10" toms, 14" x 14" floor tom, 14" x 6-1/2" snare and a 22" x 18" kick drum.
- 600 Denier nylon construction
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- Ergonomic handles with double-stitched straps
- Large exterior pockets for ipad or accessories
- Shoulder strap
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- 1-year manufacturer warranty
Call or click to order today!


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Knitted Cotton Tank Top
Cotton yarn is exceptionally nice on the Passap knitting machines if you know how to handle the yarn. You can have it as a tank or have it as a dress.
If you would like to save, you can select the monthly video and receive the video for $17.00 a month for a series of videos that will assist you in learning to use your Passap E 6000. Patterns may be purchased separately.
If you wish to subscribe, hover over monthly in the navigation bar above to watch a short video about the monthly subscription.
You may cancel your subscription at any time if you do not find the instruction is helpful.
Sign Up for fashionable knit garments designed and demonstrated by knitwear designer Marjorie J McDonald.


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Well, National Poetry Month is winding down. We will be selecting our winners of the Haiku contest late next week.
Thank you to all of you that participated. So far, I've really enjoyed the entries. We have a lot of talented library patrons. It will be difficult picking the winners.
Good luck to our participants!


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© Scuba Diving Magazine
Surrounded by over 190 miles of spectacular coral reef on one of the Worlds largest barrier reefs, Beqa Lagoon Resort offers divers a gateway to a wonderland of marine life and some of the best diving in Fiji, the soft coral capital of the World.
With dive sites that start from as shallow as 15ft (5m) and drop away to nearly 100ft (30m) and beyond in some places, divers are able to dive at a variety of depths, depending on what they are looking for. With year round temperatures ranging between a cool 75˚f (25˚c) and a bathwater 84˚f (29˚c) divers are comfortable in 3mm to 5mm suits.
All of our boat dives are guided by PADI Divemasters who have been diving the waters of Beqa since they were children. Knowing every small hole and hiding place on these pristine reefs they are able to show divers all of the colourful and amazing treasures that these waters hold from Blue-ribbon eels, Clown Triggerfish, Leaf Scorpionfish to camouflaged day Octopus. All the while you dive in a rainbow of vivid pink and orange anthias and silver-blue fusiliers. Take some time to explore sunken wrecks or even feed your adrenaline with the Beqa 'Big Fish Encounter', a dive that teases you with huge groupers, bait balls of massive Trevally, and the chance of being up close and personal with 9 different species of sharks. Why not even travel out to the edge of the reef and dive along under the famous Frigates surf break, enjoying your lunch on the boat as you watch waves crash, and sneaking in that third dive before heading back to the resort and happy hour.
The on-site nitrox compressor allows divers to take advantage of extending their no-decompression limits, spending more time looking around the reefs in awe of the colors or searching for the amazing cryptic macro life hidden in plain sight. Not certified as a nitrox diver? At Beqa Lagoon Resort you are able to undertake a wide variety of PADI specialty dive courses including Enriched Air Nitrox, a course that can be done in just one day.
As well as specialty courses, the full-service PADI 5* dive centre is able to teach a wide range of courses from basic introduction to scuba diving and the popular PADI Open Water course, through to entry level professional level courses such as PADI Divemaster and PADI Assistant Instructor.
Our beautiful house reef is perfect for diving any time of day or night, when the fancy takes you. Located straight out from the resort, the reef boast healthy hard corals, numerous juvenile reef fish, rays, and even the illusive seahorse likes to hide in the shallow eel grass. Reaching a maximum depth of 25ft (8m) this site is not only perfect for diving, but makes an ideal protected area for snorkelling your day away. The 5* PADI dive centre has snorkelling gear available for guests, as well as a full range of dive equipment for rental, including wrist mounted dive computers, BCD's, regulators, full length wetsuits for the shark dive, night lights and even UV lights if you want to try fluorescent night diving. The only way to see the true colours of the corals!
Tell us what you want and let us put a package together especially for you.
All diving packages include unlimited shore day and night diving, and any equipment that you need can be rented from the dive centre.


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Teacher retires after a 24-year career at South
Teacher DeEtte Reynolds pioneered the AP Psychology program at Grosse Pointe South during her career
February 9, 2018
DeEtte Reynolds taught at Grosse Pointe South for 24 years. A few weeks ago, she announced her retirement and has since moved to Nevada with her husband. Reynolds taught classes such as psychology, sociology and AP psychology, a program she built at South.
"Psychology was a lot more project based so we were able to do more hands-on stuff, then AP was really nice for me after a while of teaching psychology because it was a lot more challenging to start that class and teach it," Reynolds said.
Before Reynolds came to South, there was no psychology or AP psychology. Originally, Reynolds only taught psychology, until a student approached her asking about an AP program.
"The [student] did an independent study, and then the word got out, so the next year I had two or three kids that wanted to do it," Reynolds said.
Meaghan Dunham, an English teacher, has been a colleague and friend of Reynolds for 24 years. In addition to bonding over the fact that they were the only redheads on staff at the time, Dunham said, the two and their husbands got along very well and became good friends as couples.
"We were both very dedicated to our jobs, so that was a passionate love that we shared," Dunham said. "We had kids at the same time, and we just clicked."
Reynolds impacted other teachers at the school as well. Kendra Caralis, a history teacher whose room was directly next to Reynolds', had her as a mentor teacher in her first years of teaching.
"A mentor teacher, that's somebody that helps you adjust to the school, helps you adjust to the community," Caralis said. "There's a big learning curve, and she was always helpful, always answered any question I had."
Caralis wasn't the only teacher that was able to learn something from Reynolds. Dunham said Reynolds helped her become more politically motivated.
"Her investment in the union and her investment in teacher's rights made me become more aware and many of us on staff to become advocates for each other," Dunham said.
John Meier '18, one of Reynolds' last students, said Reynolds understood that teenager's lives can be stressful and tailored her teaching style to make them as engaged as possible.
"She was able to make psychology interesting," Meier said. "Certain topics by themselves would seem boring but she made it interesting enough so students could retain the information and not just write notes and be done with it."
Reynolds said the students have had the biggest impact on her out of any aspect of this job. Walking into a classroom full of eager students has been a blessing for her.
"I've been so lucky my whole career to be able to teach everyday," Reynolds said. "To walk into a classroom, kids are there, they want to learn, it's been a gift."
Not only have the students affected her, but she's affected them as well. Reynolds said the biggest way she's impacted South is through the creation and growing of the AP psychology program.
"I think we had one or two sections the first year we had [AP Psychology] and I've taught as many as eight," Reynolds said. "Once the class sizes got bigger, I'd been teaching seven for the last couple years. It was my full schedule."
As much as Reynolds loved her job, having a husband who lived across the country made going back and forth too difficult. However, she will be remembered at South.
"She makes everyone rise to a higher standard," Dunham said. "The work she did with the AP program was renowned. She inspired everyone to do more and to be more."


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absoluteBLACK Premium 1X Cyclocross 110/4 BCD oval chainrings are designed for all Shimano 4 bolt cranks like Dura-Ace 9100, 9000, Ultegra 8000, 6800 and many others. Perfect choice for Cyclocross and Gravel 1X setup with road cranks. Eagle 12spd compatible, narrow-wide chainring. Delivered with mounting bolts.
Size (Weight):
Compatibility: Shimano Dura-Ace 9100, R9120, R9150 & R9170 Di2, Ultegra 8000, R8020, R8050 & 8070 Di2., 105 R7000, R7020, R7070, Dura-Ace 9000, Ultegra 6800, Shimano 105 5800, Tiagra 4700 ; 10 / 11 / 12spd compatible.
Material: cnc machined 7075 Txxx Aluminum. Long-lasting construction
Fitment: 110 BCD x 4
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WindBurner 1.0L Personal Stove System
Combining award-winning Reactor® technology with the features solo travelers need most, the WindBurner Stove System is ideal for backcountry adventures and weekend camping alike. Its radiant burner and enclosed, windproof design allow the stove to boil water fast and operate in weather that leaves conventional burners in the cold.
- Radiant burner with boil-to-simmer control
- Pressure regulator for consistent performance
- 1.0 L hard-anodized aluminum pot with integrated heat exchanger & insulated cozy with handle
- BPA-free drinking/straining lid
- 0.5 L integrated bowl
- Includes: Stove burner, folding canister stand, PackTowl, 1.0L pot
Fuel Type: Cannister, Isobutane
Boil Time: 2.5 min
Weight: 15.25 oz


text: Balmoral Residences is a 23 story building with 420 residences. The Balmoral condominium is located on the Ocean at 9801 Collins Avenue in Bal Harbour. The Balmoral units range in size from 1388 to 2000 square and have views of the ocean and intracoastal. The building has Two and three bedroom apartments. Amenities range from sauna, heated pool, valet, security, exercise room and tennis.


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2019 Historic 1901 Water Tower Open Houses and Tours
1901 Water Tower Open Houses are held the first Saturday of the month, May-October, and on the 4th of July. (Weather Permitting) Other tours are by appointment. Please contact Tammy Doellstedt at 568-8069, or email@example.com. to reserve your spot.
Age and Height restrictions apply, for those wishing to ascend the 120 steps to the viewing platform. The 1901 Water Tower is not wheelchair accessible. The tower is located at the corner of South High Street and South 4th Street. Parking available on the street or in the FA Middle School Parking lot. Tours conducted by the Fort Atkinson Historic Preservation Commission.
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The Air Jordan 11 Concord is one of, if not the most iconic sneaker silhouette ever created. The iconic design was first debuted back in 1995, and today the iconic kicks are back. This time around we get our first look at the Air Jordan 11 Concord Golf Shoes. Michael Jordan has long been a fan of golf and had the Jordan 11 flipped into a golf cleat for himself and his close friends. Well, the Air Jordan 11 Concord golf shoes are finally being released to the public, set to release next month. The kicks come rocking all of those iconic and eye-catching details, rocking a low-cut design in the process.
The sneakers boast white leather uppers and black patent leather while the midsoles are the exact same as the originals. The sneakers are accented with two-tone translucent outsoles, even rocking replaceable spiked bottoms. The design is functional, fashionable and certainly bringing a dose of classic style to the links.
Check out the Air Jordan 11 Concord golf shoes in the images below and give us your thoughts in the comments below. Look for the sneakers to drop on February 15 at Nike and select retailers.


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Business Need
Organizations of all types empowering business users to improve relationships and communications with prospects and customers. Providing an instant competitive edge for their company with easy to create customized portals that help increase revenue through cross-selling and up-selling.
Key Benefits
- Drive cross-selling and up-selling
- Message to one or many, incubate and generate better quality leads
- Reduce emails and streamline communications using targeted messaging
- Drive collaboration with customers and build better relationships
- Improve customer satisfaction with 24/7 access to information
- Track portal users and usage to understand customer and buyer behavior
- Close the loop on enablement by understanding what enablement materials are used by customers and prospects
- Share anything requiring private communication and frequent document exchange


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Covela 2017 Rosé Wine
Price €12.13
0 review
In a natural amphitheater with a southern exposure on the slopes of the river Douro, located on the border between the granitic zone of the Vinhos Verdes Region and the shale region of the Port Wines, Quinta de Covela is located since the 16th century.
With panoramic views over the river, the farmhouse has 49 hectares, 18 of which planted with vines, distributed by two parishes of the Baixo Douro, São Tomé de Covelas and Santa Cruz do Douro, recognized for their extraordinary natural beauty and rich cultural history .
There are 5 products.


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The ERB, in its meeting yesterday, discussed the issue of parameter entities in XML. We are *strongly* leaning towards voting to remove parameter entities entirely *from V1.0* as long as GI name groups are reinstated in ELEMENT and ATTLIST declarations: <!ELEMENT (a|b|c) ...> <!ATTLIST (x|y|z) ...> We plan to vote on this at next Wednesday's meeting; your input is welcome. The reasons to prefer GI name groups: o Many of the uses of parameter entities that new DTD writers and simple DTDs are likely to want can be replaced by GI name groups: synchronizing the content models or attribute lists of elements o GI name groups add extremely little complexity to XML processors o Now that we have multiple ATTLISTs, GI name groups have quite a bit more power than they used to (e.g., you can add a set of attributes to "all the list elements," and then add a unique attribute to only one of the elements) o GI name groups give us the syntax (if not the semantics) to do a kind of element subclassing, where all the elements in a "class" have the same characteristics One consequence: o Existing DTDs and any new complex DTDs that need parameter entities would have to be transformed to resolve parameter entities before XML delivery (note that several existing tools, such as NormDTD, do this) EveReceived on Thursday, 19 June 1997 08:28:06 UTC
This archive was generated by hypermail 2.4.0 : Friday, 17 January 2020 20:25:10 UTC


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Snack Review
Taste test: In retrospect, the idea seems obvious, but let's give credit to the good folks at Jays for being the first ones to package together pretzels with mustard.
It was a truly brilliant idea, and this is one great snack kit. The mustard is sweet, almost a honey mustard (but not actually that sweet). The pretzels are good on their own, and they're great once you dip them.
Shop: Buy Pretzels on Amazon #ad
Smell test: The dip has a slightly sweet mustard aroma.
From the package: "Can't stop eating 'em®"
Online store: Buy Pretzels on Amazon #ad
Company: Jays Foods, L.L.C.
Categories for this snack:
This snack was discovered at Snaxpo.
Most popular in previous months
Still hungry? Check out the 100 latest reviews


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Good afternoon traders, Looking to position ahead of tonights Australian inflation data which we expect to come in below expectations of 1.5% (yoy) in a similar manner to the recent New Zealand data. Given the data driven nature of this trade we are trading with a tight stop loss just above the previous candle wick high on 17th April. Backing the entry of this...
Morning traders, Looking at a great short setup on Euro versus New Zealand Dollar on the recent move higher coming up against resistance dating back to early January at the same time as volumes are dying out- suggesting this rally up to the resistance level is running out of power to break any further higher. This coupled with multiple indicators showing...
- Bullish divergence on H4 using stochastics - Breakout of the consolidation zone and mini channel on the H1 - Supported by monthly key level if price decides to retest the consolidation zone once again - 90 pips target with 45 pips stop loss
I'm not a fan of Head and Shoulders patterns - inverted or otherwise - but many people will have noticed the formation in the FTSE100 and will be waiting for the break down. Whilst oversold stochastics could promote further right shoulder development, the eventual break will likely target 6400/50 as profit-taking pressure increases. Would Victor be a seller?
looking for a bearish stochastic crossover at the upper limit of the trading channel which has been well respected by price so far. The upward trend has had strong support so I'll trade this with a tight stop in case there is a continuation, will move to B/E quickly and will exit at the bottom of the channel or when there is a bullish stochastic crossover...
price way below 50 ema. Price has been rejected from 6928 level a couple times with bullish jumps. Smaller time frames showing bullish momentum. Time to start buying to the weekly high. Stoch oversold.
Weekly lows have been touched and resisted. The only way is up for now to 1.70000 at least. My trend line is touching the 50ema stochastic is telling me oversold so price should consolidate itself.
Price is touching both EMA's you can wait for a pullback for an entry at 0.889 level. stochastic and RSI is showing bullish momentum.. Adjust TP and SL to your own RR (Risk/Reward) in the past price has shown bullishness on the 6th where the red X is.
Major selling will be reversed now, the dollar will weaken this week TVC:DXY So if the dollar drops gold will rise, target 1 can be 1280 then 1300 long term after that
Bullish momentum should be coming to an end. wick of doji touching 20 ema, really overbought by Monday or Tuesday price should be lower sl placed near weekly high which is unlikely to be touched. 0.766 level mostly has bearish tendencies.
EURGBP you know how it go, self explanatory to be honest, simple
Be careful of the volatile news affecting the dollar but anyway the downtrend is coming to an end and us seeing bullush momentum when price reaches 1.51 level it will jump. Price is well belo wboth EMA's and stoch is oversold.
With the choppyness and slightdowntrend recently INDEX:MIB is going to see a bullish jump basic support and resistence along with the TL being broken shows a reversal (OVERSOLD). Price is well below the 50 and 20 EMA
Hey people FX_IDC:XAUUSD is about to go down on the weekly, firstly this huge uptrend is about to end. Recently when price touches 1306 resistence is shown and price comes crashes down. Support is met on price and is touching 0.786 level on the fib and touching the 20 EMA soon the TL will be touched. Stoxh confirms direction.
Firstly some fundamentals. Basic materials have dropped 4.4% in the last month and 5.7% in the last week. In this sector mining has seen a 7.83% drop in the last week and 12.49% in the last month (source finviz and stockcharts.com). This specific stock has performed worse with a weekly drop of 8.23% and 14.02% monthly. This gives an overall picture of weakness at...
candle confirms downtrend along with stochastic. uptrend has been broken. fibonacci shown price is below 0.618 and price is touching 20ema.
FX:NZDJPY key support is being broken, price is way below both EMA's the trend line has also broken so price should jump up soon.
FX:GBPCAD is touching the 50 EMA with a slight green doji appearing showing the end of the minimal downtrend. The stoch is showing oversold and will touch the highs of the 1.74 level again that it was struggling to touch before.


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Your health and safety is our primary concern. We have measures in place to ensure that you can buy or sell a motorhome safely through Motorhome Depot, without coming into close contact with any other person. These measures exceed government guidelines (at the time of writing) and are practical, common sense measures that enable to you to use us with confidence.
Have You Been Affected by Unbeatable Hire Going into Administration? If this has left you in the position of owning one or more motorhomes that you now wish to sell, we can help you. We are the UK's largest buyer and seller of used motorhomes.
How Motorhome Depot gets you the widest advertising coverage for free.
Thinking of selling your motorhome? There are some very good reasons to get a habitation check done first.
The latest Market Brief report from the National Caravan Council has revealed that new motorhome sales in the UK reached an all time high in 2018.
Private Motorhome Sellers Beware. We have just been made aware of a new scam aimed at private sellers of motorhomes and campervans. It is very simple and easy to see how people will be taken in by this one. The scam is specifically aimed at people advertising their motorhome privately online. The scammers don't seem to be targeting any particular website or advertiser, so all private motorhome sellers should be aware.
One of the questions we are often asked is whether "Now is a good time to sell my motorhome?".
The recent demise of St Andrews Motorhomes and the financial impact it has had on some of its customers raises a familiar issue for motorhome and caravan owners. It highlights the risks that come with selling your motorhome through a third party on a 'sale or return' basis.
These days it seems that almost every part of life where there is money to be made is being targeted by fraudsters. Here are three types of fraud that we have recently been made aware of. New types of fraud appear all the time, which is why you should only use a reputable company to buy or sell a motorhome.
When you start to think "The time has come to sell my motorhome", one of the first things you have to address is how you are going to do that. Here is our simple guide to the different ways of selling your motorhome and why brokerage may be the way to go.


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Research shows way to secure cyber physical systems via anomaly detection
Recent successful cybersecurity attacks, such as the 2010 Stuxnet attack on uranium centrifuges central to Iran's nuclear program, have made it impossible to ignore the lack of effective security of cyber physical systems today.
ITI researcher Sibin Mohan, along with co-PI Lui Sha, a professor of computer science and researcher in the Coordinated Science Laboratory, have recently been awarded a three-year, $500,000 NSF grant titled "Small Behavior Based Zero Day Intrusion Detection for Real Time Cyber Physical Systems," to help solve this problem.
"This research is incredibly timely because now we are seeing a lot of attacks on critical systems," Mohan said. "Even five years ago, people thought these kinds of attacks weren't possible. Unfortunately, the attacks are not only happening, but they're not just limited to stealing data. Attacks also could result in real physical damage, such as crashed cars or power grid crashes that could harm equipment or worse, people."
According to Mohan, these real-time cyber physical systems are much harder to secure because there are limited resources for it. You can't just run an anti-virus program because it is hard to gauge the amount of time and resources the software will take and that would distract from the program running properly since these systems have limited hardware resources. If a anti-virus software runs too long or uses too many resources, that could affect the execution of critical tasks.
"We are trying to look at the practical side of how you detect security violations in a real time system," Mohan said. "These systems are designed to be predictable and behave in a certain predetermined fashion, so we can use those behaviors to look for attacks. When a system deviates from what it's designed for, that's an indication of an attack."
For instance, Mohan and Sha would be looking at how long it takes a particular program to run, what resources are being used in the system or how much memory is being used -- and how it's being used -- to determine if there are anomalies.
The first step is to build an expected behavioral profile of a system, some of which can be determined at design time.
As the technology becomes more refined, Mohan hopes to collaborate with automotive, aviation or power system companies, or even mobile companies such as Qualcomm, to adapt the newly developed architecture to a variety of devices. Mohan anticipates this to be the biggest challenge -- working with real systems -- after the technology is created in the lab.
"A lot of systems are very proprietary and the technology is secret because they deal with critical infrastructures or have taken a lot of time to develop," Mohan said. "In our labs, we can do simulations and work on smaller testbeds, but that's still not representative of real-world configurations. We've gotten great positive feedback so far, so hopefully this will lead to many collaborations."


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155 Results for Elbonian's
View 151 - 155 results for elbonian's comic strips. Discover the best "Elbonian's" comics from Dilbert.com.
Wednesday January 25,
Boss Tweets Racist Stuff
Tags #cell phone, #conversation, #desk, #sitting, #technology
You retweeted a racist conspiracy theory. I did? I checked snopes.com, and they say it is not true that Elbonians evolved from pandas less than a hundred years ago. You might want to delete the tweet. nah. What's the worst that can happen?
Saturday December 09,
Elbonian Hackers Delete Wally's Report
Tags #evidence, #excuses, #hackers, #hacking, #laziness, #assignment, #elbonians, #a, #zing report
Boss: Did you finish your assignment? Wally: Yes, but Elbonian hackers deleted my report along with all of my backups. Boss: I have no way of knowing that's true. Wally: It was an amazing report! Better than you've ever seen.
Tuesday December 05,
Elbonians Hackers Get Into Network
Tags #hacker, #hacking, #malware, #virus, #infection, #cyber security, #obliviousness, #password
Boss: Elbonian hackers got into our network. We don't know how. Dilbert: Maybe it was the thumb drive you found on the sidewalk in front of our entrance. Alice: Or maybe it was because your password is "password." Boss: How do you know my password?
Thursday July 19,
Death By Ninjas Is Best
Tags #ninja, #hit man, #optimism, #frustration, #irony
Wally: Why aren't you worried about the Elbonian ninjas who are reportedly coming here to kill you in your sleep? Dilbert: That's the best way to die. I won't care about anything after I'm gone, so this is the ideal scenario for me. Elbonian 1: He's ruining everything with his cheery attitude. Elbonian 2: Let's see how he likes another thirty years in a cubicle.
Friday July 20,
Elbonians Call Off The Hit
Tags #cruelty, #hit man, #murder, #torture
Boss: Elbonia called off its plan to kill you for your culturally offensive sales video. They decided it was more cruel to keep you alive and working here. Dilbert: They're monsters! Boss: Get back in your cubicle.


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Will Trump take his NAFTA trick to Iran?
Tehran, This week Donald Trump hailed the new trade agreement with Mexico and Canada as a great deal for all three countries. And maybe it was. But it also was surprisingly similar to the North American Free Trade Agreement (NAFTA) that it replaced � and which Trump has denounced ferociously for years.
The approach appears to be much like the one he's trying to take with North Korea: start by denouncing and threatening, then work toward achieving modest progress.
Can the same pattern work with Iran?
Trump's negotiating style is now familiar. He begins by creating a crisis by attacking existing arrangements. Negotiations follow and a tweak to the pre-existing arrangements is established. The new normal looks a lot like the old normal, but is rebranded. Trump takes credit for saving the country from the errors of his predecessors.
The Nafta replacement, dubbed the US�Mexico�Canada Agreement, includes some noteworthy changes to its 24-year-old predecessor. But many of the most significant changes are drawn from the Trans-Pacific Partnership that former President Barack Obama had negotiated and which Trump consigned to the trash as soon as he took office.
Rebranding relations with Iran, though, may prove to be more difficult. North Korea was delighted to engage with the US at the leader-to-leader level, gaining unprecedented legitimacy at no cost. Iranian leaders, by contrast, would be taking a considerable political risk by meeting Trump in public.
Trump enraged both Iran's leaders and public by summarily withdrawing from the nuclear agreement reached during Obama's presidency, calling it the worst deal ever, and launching a campaign of maximum pressure, largely in the form of financial war. European efforts to create a special payments vehicle that would allow countries and companies to pay Iran in currencies other than dollars and skirt US sanctions may help to some extent.
All this is bolstering Iranian hard-liners and causing many Iranians to rally around the flag.
Beyond the sanctions, the US has teamed up with regional allies to intensify strategic pressure. US troops are staying in eastern Syria. And the US and Saudi Arabia have been pursuing a campaign to weaken Iran's grip on Iraq.
Both sides began the confrontation with exaggerated confidence. But it soon became clear that there were limits to what either could achieve. Iran isn't going to be able to isolate Washington, no matter how frustrated Europeans become with Trump. And US pressure on Iran isn't going to produce a major policy change, let alone regime change.
So, unless both sides want a war, and neither side does, Iran and the US will have to find a way to re-engage.
Trump has signaled that he wants a new understanding with Iran, saying in July: They want to meet, I'll meet. Anytime they want. No preconditions. If they want to meet, I'll meet.
Washington's idea of a deal would address three aspects of the six-nation nuclear deal that Trump withdrew the US from in May.
First, the US wants restraints on Iran's nuclear activities that don't expire in a few years, as they do in 10 to 15 years under the nuclear deal. Second, it wants to limit Iran's missile development, which is not covered by the nuclear deal at all. And third, the White House wants agreements curtailing what they claim to be Iran's destabilizing regional policies, especially support of groups like Hezbollah.
It's going to be politically difficult and emotionally galling for Iranian leaders to get back into a dialogue with Washington. But the only way to relieve the pressure they face is to seek a new accommodation. So they are already laying the groundwork. At the September meeting of the United Nations General Assembly, Iranian Foreign Minister Mohammed Javad Zarif left the door open, saying, I'm not ruling out the prospect of talks. In July, President Hassan Rouhani enraged Trump by warning of the mother of all wars, but he also offered to help craft the mother of all peace with Washington.
According to David Ignatius of the Washington Post, at the UN Trump told French President Emmanuel Macron that he was ready to negotiate with Iran, but added: It's too early. They need to suffer.
Ignatius wrote that he was skeptical that US pressure tactics can work against Iran. But even the faint signals of re-engagement show that the two sides are closer to a new dialogue, possibly beginning through European intermediaries, than many people would have thought when Trump pulled out of the nuclear agreement. Washington and Tehran are communicating that neither wants war, but also that neither is satisfied with the current arrangement.
That means both sides must want a deal. And that's progress, even though it's far from clear that either side's idea of a fair deal would ultimately prove acceptable to the other.
Excerpts from an article published by Bloomberg.
Source: Islamic Republic News Agency - IRNA


text: Eurotransplant has been informed that although Austria had a lot of snow, there is good access to Alpbach. Nearby airports and train stations are open and roads are kept clear of snow. It is expected that the weather forecast for coming days will not impact accessibility of the congress venue and hotels. We wish all participants a safe journey and look forward to welcoming you in Austria on Thursday!