1. A contrast

There is a contrast between the findings of the Lord Neill Review, ^x and the opinion of Which?:

"FOS is the unsung hero of UK financial services regulation and helps to maintain consumer confidence in the industry." ^x

The reason for this contrast seems to be that the Lord Neill Review is looking at difficult cases. The Lord Hunt Review does not discuss any particular cases. It refers to:

"3.29 .. the reasonably strong satisfaction ratings scores in the FOS's Annual Report "

But these are based on all cases.

2. "Unable to deal with individual consumer's concerns"

2.1 "Experiences and views"

The Lord Hunt Review requested submissions from the public:

"3.29 .. I specifically asked members of the public to let me know about their experiences of the FOS." ^x

The experiences are probably all, or almost all, difficult cases which go to an adjudicator and possibly on to an ombudsman. They have not been analysed. In return for their submissions, the public has to make do with:

“1.5 .. I hope many of my correspondents will be able to recognise aspects of their experience in some of my commentary and recommendations.”

What about "views"?

"1.4 A number of journalists were kind enough .. to allow me to use their columns to solicit views from members of the public who had used the FOS."

In the Foreword of the Call for Evidence document ^x he asked for not just "experiences", but "experiences and views of the FOS's current practice". In paragraph 6.2 he invites "comments" from organisations. The Review talked only to organisations, rather than to the public:

“1.3 In total, members of my team and I held 61 separate discussions with individual firms; trade associations; consumer bodies, parliamentarians; ministers and officials; and regulators."

This exclusion of the experience of the public is a general problem. For example, I wrote to the Consumer Panel of the FSA without reply. It says:

"The Panel is unable to deal with individual consumer's concerns." ^x

In its report Restoring Confidence in Long Term Savings (2004), the Treasury Select Committee says:

"85. The Treasury explained to us that 'the Financial Ombudsman Service (FOS) was set up in recognition that consumers want a speedy, fair and inexpensive method of resolving disputes. There can be little doubt that the FOS has and continues to meet this aim.'"

Had the Committee spoken to complainants about their experiences, they would have learnt that the FOS is slow for a large minority. They are instead continually talking to representatives of organisations, currently high-ups from the FSA about the Northern Rock collapse. They will not be able to reform the FSA just by talking to the FSA:

"The FSA said that the bank had been an 'outlier' with an unusual business model." ^x

Outliers should receive the most attention, not brushed under the carpet. The people who responded to the Lord Hunt Review are also outliers.

2.2 "Responses may be made public"

The Call for Evidence document concluded:

"Responses may be made public through the website unless privacy is specifically requested."

This gives the Review the option whether to publish or not. "Privacy" implies having a secret influence, which should arguably not be permitted. More positive would have been:

"Responses will be made public through the website."

The Government has conducted a large number of consultations on different topics. What is achieved by not publishing responses? Summaries of responses without the accompanying responses lack credibility. The responses should inform public debates in addition to government policy. They should all be published on the web. ^x They should not be anonymised to show they are genuine. I have been informed by BERR ^x that the responses to the consultations of government departments are either: all published, including names but not personal addresses; or all not published.

Making submissions available for inspection is better than nothing, but it puts people to the trouble of visiting a library. The FSA says:

"It is the FSA’s policy to make all responses to formal consultation available for public inspection unless the respondent requests otherwise."

The Freedom of Information Act says:

"1) Any person making a request for information to a public authority is entitled —

(b) ... to have that information communicated to him."

This is more than "available for public inspection". In the case of a consultation on pensions, before the Freedom of Information Act (2000), I was told that the responses were not available for inspection, and was sent the names and addresses of all the respondents. Parliamentary Committees such as the Treasury Select Committee publish some responses to consultations, and the remaining responses are available for inspection:

"The following memoranda have been reported to the House, but to save printing costs they have not been printed and copies have been placed in the House of Commons Library, where they may be inspected by Members. Other copies are in the Parliamentary Archives, and are available to the public for inspection."

But putting them on the web does not involve printing costs. This would save the public the trouble of going to see the Parliamentary Archives in the House of Lords library.

2.3 Further examples

"4.7 When providing copies of responses, it is legitimate to make a reasonable charge for copying and postage." ^x

This results in the expense of unnecessary potocopying. Only some of the responses may be sufficiently interesting to be worth copying. Until you have read them you do not know which. The responses should be held in electronically so there is no need for "copying and postage".

The summary to the responses should be based on all the responses not just on a "representative sample", like one FSA report:

“Our thinking at this point is based on reading a significant and representative sample of written responses, but we still have more to do.” ^x

A summary of responses should distinguish between those from industry and other responses. The FSA frequently refers to "most respondents" ^x and "most responses". ^x Most respondents to its consultations are always from the industry. So that doing the wishes of "most respondents" sounds democratic. But it is then continually acting for the industry. It may not be possible to distinguish clearly which responses are from the industry.

Consultations should not ask for information about matters of fact which can be found out without consultation, such as question 2 in the PADA consultation. (The questions are numbered unlike those in the Call for Evidence document of the Lord Hunt Review, pages 23 and 24.):

"What are the charging structures currently used by the financial services industry, both for pensions and other financial products?"

2.4 "Submissions to the review"

The published submissions on the Review website are not all the submissions received, although it does not say so on the website:

"Submissions to the review

Listed below are submissions received for this review." ^x

This implies all the submissions received. But only four submissions from members of the public have been published, from: Mrs Block , Mr Grenet, Mr Reid, Mr Spain. Three won and one is undecided. This indicates that publication is selecting against people who lost.

from	received	published
public	151	4x x x x
organisations	87	49

The Review would not let me see the submissions because it is "respecting individual confidentiality". But surely confidentiality is not a problem if submissions are anonymised. The Review refers to "the openness revolution":

"Foreword .. In the twenty-first century, the openness revolution is here to stay and it is ongoing.

6.20 .. I therefore consider openness both desirable and inevitable."

It proposes the publication of anonymised cases:

".. regular, independently-edited selections of anonymised case reports and a new interactive 'FOSBOOK' system, to provide comprehensive data on the FOS's approach to families of cases and facilitate regular, informal two-way feedback. An 'openness revolution' of this kind will ultimately be far more useful to both consumers and the industry itself than 'league tables' on their own would be." (page 4)

So the Review is proposing that "case reports" should be published in a new interactive system, that is accounts of cases written by the FOS. There are already details of cases in Ombudsman News. This a contrast with only four published submissions from members of the public to the Hunt Review. The FOS and Hunt Review like the publication of cases, provided the text is not written by the complainant.

I asked the Treasury Select Committee if they can help me to see the submissions. They say they cannot because:

"The FOS is not one of our current interests".

The Equitable Members Action Group received a similar reply:

"EMAG’s invitation to the Treasury Select Committee to consider the behaviour of the FOS in the light of Lord Neill’s report has, predictably, been declined." ^x

The Review discusses the advantages of the publication of cases. These advantages apply also to the publication of the submissions:

"4.13 Such publication arguably might assist the FOS in better discharging its role of seeking to help the industry avoid future complaints. It could also help to improve efficiency by making the FOS’ working practices more visible Most broadly, it also might encourage fuller public debate on the remit and jurisdiction of the FOS, which would potentially be of value to other policy-makers in financial services as well as to the FOS itself."

2.5 "Examining cases in detail", "looking at casework practice in detail", "undertaking detailed case reviews"

"1.5 .. Many of my correspondents wished me to examine their cases in detail and offer detailed specific comments on them. I have not done so."

Lord Hunt asked for "experiences and views", rather than "cases", and therefore his correspondents will expect him to examine their experiences and views. He cannot be expected to make “detailed specific comments" on all the submissions, because there are too many.

"1.5 .. As I explained in the call for evidence document, it was not within my remit to repeat the work which Professor Elaine Kempson and her team carried out in 2004 in looking at the FOS's casework practice in detail"

How many respondents read the Call for Evidence document? This is 25 pages long. It asks 20 unnumbered questions. Professor Kempson did not ask for submissions. Her report does not contain any details of particular cases.

"1.5 .. nor was I charged with undertaking detailed case reviews in order to comment on the quality of decision-making"

"3.29 .. I received 151 letters. As perhaps might be expected, the majority of these were critical, coming as they did predominantly from individuals who had 'lost' their claims."

There may be legitimate reasons for being critical, such as delays and bias discussed below.

"1.5 .. My focus has been on the FOS's policy and practice in relation to accessibility and transparency."

But he asked for "experience and views of the FOS's current practice".

"3.29 .. Such evidence has to be considered in counterpoint with the reasonably strong overall satisfaction ratings recorded in the FOS's Annual Report and tracked through its regular consumer surveys."

Why make such a comparison? "Reasonably strong overall satisfaction ratings" refers to initial enquiries, rather than full blown cases which go to an adjudicator and possibly then on to an ombudsman.

2.6 "Very high customer satisfaction scores"

At the 2007 AGM of the FSA, in answer to an FOS complainant, Chris Harlow:

"I have talked to several hundred complainants to the FOS over the course of the past five years, every one of whom has had sound reasons for doubting the procedures and the fairness of that body. I would be prepared to give the names of them in confidence if I had their permission to do so and they were prepared to do that. " ^x

in his reply Clive Briault (Managing Director, Retail Markets) said:

"I am always struck by the in general very high customer satisfaction scores that the FOS receives from its own consumer surveys."

This is pointing away from the "several hundred complainants" of Chris Harlow, at complainants who are satisfied with the FOS. Regulators should be concerned with the people who have problems. The "customer satisfaction scores" are based on "initial enquiries" rather than "full-blown cases". It says on the website of the FOS:

"Each month we send a customer satisfaction survey to a random selection of around 350 people whose complaints we have dealt with, asking a range of questions about their experience of our service." ^x

I have been informed that this survey is of people making initial enquiries. It says in the 2006/7 Annual Review:

"Only around one in six of these initial enquiries go on to become 'full-blown' cases requiring the involvement of our adjudicators or ombudsmen."

Clive Briault continued:

"With all due respect, I think that is the body with which it should be discussed because of its operational independence from us."

To say "it should be discussed" with the FOS because it has "operational independence" is inadequate. Why should it not be discussed with the FSA or Treasury? The FSA set up the FOS, and has the duty to ensure that it exercises its functions as defined by legislation.

3. Delays

The Financial Services and Markets Act (2000) defines the FOS as:

"A scheme under which certain disputes may be resolved quickly .. " (S. 225)

The Review found that "one consistent theme" is delay:

"3.32 .. Nonetheless, if there was one consistent theme that did emerge during the review, it was delay, and this does rather correlate with the general consumer survey, the evidence of the Independent Assessor's Annual Report and the views of industry respondents to the consultation. It also greatly exercised Elaine Kempson in her review in 2004."

That was four years ago. Why was this problem not fixed? The 2007/8 Annual Review of the FOS shows the lengths of time required to settle disputes:

"The chart opposite shows the time it takes to settle disputes that are referred to the ombudsman service." (page 47) ^x

These are "initial complaints and enquiries" most of which are easy. Only "round 1 in 6 of the initial consumer enquiries we received turned into cases involving our adjudicators and ombudsmen" (page 1). In answer to the question (page 62) “Do we settle disputes within an acceptable length of time?”: agreed 47%, no opinion 18%, disagreed 35%. Therefore 43% of those who expressed an opinion disagreed. The Lord Neill Report says:

"The FOS frequently took more than a month to reply to correspondence, it required a reply from complainants within 14 days, often stipulating that if no response was received within that time frame the case would be deemed to be closed." (page 40)

The Prospectus of the FOS (in the Lord Neill Report) says:

"(14) The service will be adequately staffed and funded so as to ensure that there are no unnecessary delays."

The Lord Neill Report says that the FSA has the:

"59 .. duty to ensure that the FOS is at all times capable of exercising its functions in or under the legislation."

But:

"67. .. the FOS has repeatedly sought to excuse long delays on the basis of pressure of work. ..

161. This appears to be a forthright admission that the FOS lacks the actuarial resources to do a proper job. ..

The FOS refuses to acquire the necessary resources, i.e. actuarial staff, to crack the problem." (page 71)

The FOS is not "capable of exercising its functions" because of inadequate resources. The industry and FSA are clearly unwilling to finance an adequate service. The submission from Paul Grenet said:

"I have the impression that when a claimant tells the firm that they will take the matter to the FOS, the firm breathes a sigh of relief .. 'We've made it!' They know that the FOS will delay further (thus delaying redress payments), not make a rigorous examination of the case, probably not check any calculations, not criticise the firm, not publicise any mistakes, however disgraceful. They know the award will not exceed £100,000 and that the claimant can’t afford to go to court. Many firms would settle for that."

This problem of delays is more general:

"The Local Government Ombudsman routinely uses delay as a tactic to block or at least significantly delay valid complaints of maladministration." ^x

4. The calculation of awards

Lord Hunt discusses the calculation of awards very briefly in comparison to Lord Neill:

This paragraph and the recommendation does not include an explanation of how the award is calculated. "Model redress calculations" are mentioned in paragrah 5.7. The Lord Hunt Report mentions the word "calculation" only 4 times in comparison to the 97 times in the Lord Neill Report which has a section on this topic:

There are numerous examples in the Lord Neill Report, such as:

"The FOS declines to intervene and is apparently content with a situation in which a successful claimant does not and cannot know how an award in his favour has been calculated." (page 77)

The two longest published submissions from the public, complained about calculations, from Mrs Block:

"On 24th October the FSA wrote to us revealing that the Principal Ombudsman's formula for calculating the redress was 'not viable' and advising us to take legal advice. After issuing the Final Decision, the FOS ignored our requests for an explanation of the formula." ^x

and from Paul Grenet:

"The Independent Assessor has, on several occasions, drawn attention to the problem caused when FOS just accepts the firm’s calculations. I have asked to be shown the calculations relevant to my case but they are never produced and I suspect that no such calculations were actually made, if FOS had checked the firm’s figures they would have seem the intention to deduct tax, but this was missed. I believe the FOS should check all calculations and if this requires extra staff or resources then so be it. Something must be done as the current situatin is biased in favour of the firms and destroys the FOS’s credibility." ^x

The submission of The Association of Financial Brokers also complained about:

5. "Partiality" and "bias"

The Lord Neill Report finds "partiality", for example:

"(5) The adjudicator displayed a lack of impartiality in his handling of the case. ... He behaved like an advocate for EL." (page 99)

Concluding:

"177. (1) The impression gained by the complainants whose cases I have studied is that the FOS is not a body which holds the scales of justice evenly. It is a body which in many ways and in many instances has displayed partiality towards the financial firm, in this case EL." (page 82)

The submission of Paul Grenet finds "bias":

"The whole FOS process is biased towards firms. I do not suggest this is deliberate, but it is what happens in practice. The Adjudicator’s initial assessment of my case was based on the firm’s evidence, not mine, she showed my letters to the firm but I was not shown theirs, the firm used professional staff and advisers, but consumers are dis-encouraged from doing this, the firm knew guidelines existed and kept quiet about them but FOS did not tell me about them, FOS accepted the firm’s calculations without cross-checking them and don’t apply their guidelines, massive delays at the FOS means the firm retained the compensation funds for years invested at inter-bank rates before paying out with interest at bare base rate. Even when a tax error was finally picked up, FOS paid the money itself rather than instruct the firm to repay the money." ^x

Bias in the The Local Government Ombudsman service is discussed on several websites. ^{x x x}

6. "Independent"

6.1 Operationally independent

The FSA describes itself as "operationally independent of Government", "does not act on behalf of the Crown". But then on whose behalf is it acting? It should be acting on behalf of savers and investors to protect their saving and investments.

The Prospectus of the FOS says the Ombudsman is "completely independent" and "impartial like a judge". Is it possible to be "independent" and also accountable? In the US judges are largely elected. The Lord Neill Report claims the Chief Ombudsman, Walter Merricks, was not acting independently when he decided not to proceed with "Penrose related" claims of Equitable Life policyholders. In his letter to EQUI, Walter Merricks, refers to: "Lord Neill's report paid for and commission by the Action Group". ^x But Lord Hunt Review is paid for and commissioned by the FOS. The Lord Neill Review does not claim to be "independent" like Lord Hunt's.

6.2 The Independent Assessor

In this area "independent" is often claimed when it does not in fact exist. Just calling someone "independent" does not automatically make them independent, any more than referring to the FOS as "speedy" in the legislation makes it speedy. In Appendix 2 below, Mrs Block and Mr Grenet question whether the Independent Assessor is really independent of the FOS. They point out that he uses a PO Box, and is appointed by the FOS. Mrs Block has a helpful suggestion:

"If the FOS is accountable to the Treasury Select Committee, then it seems to me to be logical that the Treasury Select Committee should appoint the Independent Assessor to ensure proper independence. "

6.3 Independent financial advisers

If an "independent financial adviser" is paid by commission, both "independent" and "adviser" are misleading, for example: Adviser lost my pension £250,000 . ^x This may not continue following the establishment of the proposed national generic financial advice service, ^{x x} and also the FSA's Retail Distribution Review recommends that IFAs should no longer be allowed to receive commission. An article in the Financial Times Death of advisers is no tragedy (2/5/08) says:

"Independent advisers will no longer be able to receive commissions or incentives from fund managers and insurers, but will have their pay decided by customers.

So, with the stroke of a pen, the FSA brought about not only the death of a salesman in adviser’s clothing, but also the birth of a new breed of honest salesman – who says which insurer or bank he works for, and doesn’t pass off his sales spiel as 'advice'.

It’s worth remembering who was the author of the original regulatory farce, which saw 'tied' and 'multi-tied' agents masquerading as 'advisers', while shamelessly promoting inappropriate products to a bewildered audience, and trousering hefty commissions in the process. Step forward, the FSA." ^x

But the FSA proposes to replace commissions with "payments". This is discussed in the Interim Report (2008):

"3.16 .. how we may require remuneration practices .. to operate in a way that ‘reduces effectively any conflicts of interest.. To achieve this, we could go so far as to consider no longer permitting any payments to pass from manufacturers to distributors, but we recognise that this is not practicable at the present time." ^x

Why not? This is arguably what should happen. In the following paragraph "manufacturers" changes to "product providers" and "distributors" to "advisers".

"3.17 So we are not seeking to end the role for product providers in organising payments to advisers from customers’ accounts or investments.” ^x

The Government and FSA continually claim to be reforming the financial industry, but then to do this they appoint "industry figures" ("Godfathers" ^x). In the case of the Retail Distribution Review:

“The Financial Services Authority (FSA) today announced the industry figures that will lead the working groups of its Retail Distribution Review (RDR).” ^x

The proposal to abolish commissions to IFAs was in the Sandler Review. ^x Another wise recommendation in the Sandler Review is to abolished the 5% withdrawal rule for insurance/investment bonds.

7. The sixth flop

EMAG has a list of five FSA flops on its website:

“FSA: THE FIVE FLOPS
2001 Equitable Life Collapse
2001 The Split Cap Debacle
2004 Precipice Bonds Mistakes
2005 L & G Fines Botch
2008 Northern Rock Failure" ^x

FOS problems as discussed in the Lord Neill report are so serious, that this seems like another FSA flop, because the FSA is responsible for supervising the FOS under the Financial Services and Markets Act (2000). Continuing the reply of Clive Briault to the question of Chris Harlow, mentioned above:

"The very points you have made have been made to me on numerous occasions by members of the industry from each sector, who actually use exactly the same words to describe what they believe is the institutional customer bias of the Ombudsman against firms." ^x

This is saying there is another side to this topic, which is another reason why all the submissions to the Lord Hunt Review should be published. But Mr Harlow was not just complaining about bias:

"It was delayed and not prompt in its delivery of judgements. It was obscure in the way that it explained awards. Unfair conditions were attached to the judgements that it made. There was an uneven playing field between the judgements made by the FOS in terms of the company’s representation and the complainant’s representation. There was inequality of arms, that is to say of the weapons that could be brought to bear in the disagreements between consumers and the FOS."

There is a E-Petition to abolish the FOS:

"The Financial Services Ombudsman is accountable to no-one. It is funded by the very businesses consumers complain about. There is a huge disparity between the way in which the FOS presents itself to the public, i.e. 'impartial' and its actual subjective and biased behavior. The FOS maintain they 'don't have to ask for evidence' or even explain themselves. Internal service review complaints about the FOS are stonewalled and/or dismissed but the FOS are not even obliged to publish details in relation to these internal complaints. They are an affront to any notion of consumer rights and merely add to the misery and suffering of those injured by unethical and unscrupulous financial organisations. The FOS should be abolished." ^x

There needs to be a FOS and FSA. But they should be constituted differently. They should not be entirely financed by the industry. Many of the complaints to the FOS are concerned with mis-selling. The industry should be subject to the Sale of Goods Act. Complaints concerning mis-selling would then be taken to Trading Standards ^x rather than the FOS. Further reforms are needed. ^x

References

1. The Lord Hunt Report^x

2. The Call for Evidence document ^x

3. The Professor Elaine Kempson assessment ^x

4. The website of the Lord Hunt Review ^x

5. The Lord Neill Review ^x

Appendix 1
"Use plain English"

"Recommendation 21 .. use plain English"

In the title of the Lord Hunt Report there is "Accessibility and Excellence". In the Foreword there is both "accessibility and transparency" and "transparency and accessibility".

The Report uses words which have the same, or very nearly the same meaning. An example is: “contribution", “evidence”, "feedback", “response", "submission". In Appendix 3 this is: "information provided for the purpose of the public consultation exercise". As mentioned above, in paragraph 1.5 in the Report there is: “examined cases in detail”, “looking at casework practice in detail ", "undertaking detailed case reviews".

Words may sound similar and have slightly difference meanings such as "correspondent" and "respondent", or have opposite meanings such as "prescribe" and "proscribe" in the Call for Evidence:

"3.2 The regulatory framework neither prescribes nor proscribes any specific access-related or publicity activity by FOS.“

The Report uses both the terms "members of the public" and "individuals". The former is only used in relation to the submissions. It is absent from the Lord Neill Report.

The Report sugggests changing the name "FOS" to "FCS" which stands for "Financial Complaints Service" (page 9). This will surely just cause confusion. "Complaints Service" seems vague.

Appendix 2
The Independent Assessor

From the submission of Mrs Block: ^x

The Independent Assessor cannot be regarded as independent in any real sense of the word and his terms of reference are so weak that he can have little real effect on how the FOS operates. His office is located at a PO Box. His real address, telephone number, fax and email are deliberately kept secret. There must be a reason why this information is not published and I can only guess that it is to disguise the location of the Independent Assessor’s premises, indeed he may even be housed in the FOS headquarters. Whether this is correct or not, they are obviously hiding something. Added to this is the fact that the Assessor is not independently appointed but chosen (and probably paid ?) by the FOS Board. Furthermore he took up his post only two months after ceasing to be an FOS board member himself. His terms of reference are toothless, he can make recommendations to the Chief Ombudsman and Board but they have no force. The FOS can ignore them if they wish with the sole proviso that in such a case they publish their reasons in the Annual Report. No ordinary person would regard this as truly independent.

Even within these shallow arrangements the Assessor is too close to the FOS. In the case of my Aunt he asked the FOS to review the outcome of my complaint, he told me that he reserved the right to make a formal recommendation in the light of their reply. They refused to reply, so I enquired why a formal recommendation had not been forthcoming and he responded “the response I have received from the Principal Ombudsman has left me in no doubt that FOS would not have accepted any recommendation I might have made on the interest rate issue”. So the Independent Assessor, instead of independently posting his recommendation thus forcing the Board to address his request, cosily discussed the matter with the Principal Ombudsman and when he found his recommendation would be ignored, he collapsed. One wonders why he bothered to ask FOS to investigate in the first place if he is prepared to accept a blank refusal to respond.

I believe the Independent Assessor should be appointed independently and should be able to investigate decisions, or at the least require FOS to review a decision in circumstance where there is cause for concern. His terms of reference should be made much more assertive and powerful and he should have his own office and staff demonstrably separate (independent) from the FOS. It would be better if he was not an ex-FOS employee."

Appendix 3
Freedom of Information

"7.7 Under the Freedom of Information Act (2000), all information contained in your response, including personal information, may be subject to publication or disclosure."

The next sentence mentions "disclosure and publication":

"By providing information for the purposes of the public consultation exercise, it is understood that you consent to its disclosure and publication. "

This sentence should come first, because personal information is excluded from the Freedom of Information Act without this consent. So we have:

"By providing information for the purposes of the public consultation exercise, it is understood that you consent to its disclosure and publication. Therefore under the Freedom of Information Act (2000), all information contained in your response, including personal information, may be subject to publication or disclosure."

The text continues:

"If this is not the case, you should limit any personal information which is provided, or remove it completely. If you want the information in your response to the consultation to be kept confidential, you should explain why as part of your response, although we cannot guarantee that it will be possible to do this."

Is this text really necessary? The following seems adequate:

"By responding to this consultation, it is understood that your response may be published, or disclosed under the Freedom of Information Act (2000)."

especially as probably no one will actually ask to see the responses under the Freedom of Information Act. If the responses were published, it would be unnecessary to become tangled with the Act.

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