As part of the no-deal Brexit preparations, the Board of Supervisors of the EBA have confirmed that a template MoU has been agreed with the FCA and PRA. If there is a no-deal Brexit, this template will be used as the basis of the series of bilateral MoUs required between UK and individual EU supervisory […]
The Treasury Committee has written to Treasury and FCA asking for an investigation into the events at London Capital and Finance. FCA had told the firm to withdraw its promotional materials for its mini-bonds in December 2018 as it found them to be misleading, not fair and unclear. But the Treasury Committee feels there is […]
Womble Bond Dickinson is delighted to have expanded its offering in the financial services and insurance sectors with the hire of white collar crime partner, Audrey Koh. Audrey has substantial experience of advising clients across many jurisdictions, in particular those based in the UK, US and Europe. Further information about Audrey can be found here.
FCA has fined the Carphone Warehouse over £29 million for misselling its “Geek Squad” mobile phone insurance and technical support product, and acting in breach of its Principles 3,6 and 9. Following whistleblowing reports, FCA investigated and found the firm did not give its sales staff the right training to enable them to assess customers’ […]
The UK supervisory authorities have agreed memoranda of understanding with European counterparts, to facilitate the coordinated supervision of insurance entities in the event of a no-deal Brexit. The MoUs cover supervisory cooperation, enforcement, information exchange and mutual assistance.
BoE and FCA have updated their respective websites with coordinated information on their approach to a hard Brexit. BoE has published a series of materials setting out its updated plans to its supervisory approach to a hard Brexit. The papers cover: transitional relief for firms that will broadly (with exceptions) last for 15 months from exit […]
In its first decision under its competition powers, FCA has found that 3 asset management firms have breached competition law by sharing of strategic information, the effect of which was that the firms knew each others plans during one IPO and one placing process, when they should have been competing for shares. The firms in […]
FCA has fined Paul Stephany, formerly a fund manager at Newton Investment Management Limited. It imposed the £32,200 fine after it found Mr Stephany twice submitted orders as part of a book build for shares that were to be quoted, but then tried to get other fund managers to cap their orders at the same […]
As part of the preparation for a ‘no-deal’ Brexit, the FCA has agreed MoUs with ESMA and with EU and NCAs, covering supervision, enforcement and information exchange, including in relation to credit rating agencies and trade repositories.
FCA has published a detailed policy statement to back up the new rules on regular premium PPI complaints and recurring non-disclosure of commission. FCA stresses that one of the main purposes of its consultation and now the new rules is to ensure that customers who may have made complaints about mis-selling of PPI that were […]
The Upper Tribunal has ruled on whether any part of costs claimed by Alistair Burns (on his unsuccessful application) should be awarded. The Tribunal has discretion over the award of costs, but can only make the award if it considered that FCA had acted unreasonably in bringing, defending or conducting the proceedings, or that the […]
FCA’s latest Handbook Update lists rules made in December and January. The key changes: amend the rules on PCAs and Overdrafts from 18 December 2019: these changes amend BCOBS and CONC to tackle low levels of consumer awareness of and engagement with overdrafts; amend DISP to require lenders and sellers to write to certain Plevin complainants […]
We are delighted that Jonny Williams has joined the financial services regulatory team at Womble Bond Dickinson UK. More information on Jonny and his appointment can be found here.
FCA has published its final notices banning Stewart Ford and Mark Owen from performing any function in relation to any regulated activity and fining them £76 million and £3,240,787 respectively. Mr Ford held the CF1, 3 and for some time 8 positions in respect of Keydata Investment Services Limited Mr Owen held the CF1, CF16 […]
In October, the Treasury Committee reported on SME finance, making several recommendations including setting out its views on the availability of FOS and the Tribunal for SME disputes, and the suggestion that commercial lending be regulated to protect SMEs. The Government and FCA have now responded to the report. The Government has refused to bring […]
FCA has published its final framework setting out how it will measure the impact of its past interventions.
In a speech by Christopher Woolard, FCA has called on firms to increase their efforts to integrate diversity and inclusion principles in their business frameworks. While things are moving in the right direction, Mr Woolard said much work is still to be done. He particularly noted that the percentage of woman in senior management below […]
FCA has fined Santander £32,817,000 for failing effectively to process the accounts and investments of deceased customers. FCA found the bank did not transfer funds totally over £183m to customers when it should have done and did not disclose problems in its probate and bereavement process to FCA once it became aware of them. The […]
The FOS has published a consultation on its plans and budget for 2019/2020. It notes that from April 2019, its jurisdiction will be expanded by the addition of two significant areas of work: complaints made by SME customers of financial services, and complaints made by customers of claims management services. The consultation questions include inviting […]
FCA has finally issued its final notice banning Angela Burns from acting as a NED and has fined her £20,000. Ms Burns acted as NED for two mutual societies and was chair of their investment committees. She provided advice on appointing Vanguard Asset Management Limited as investment manager, and the societies believed this advice was […]
PRA has published the Q3 2018 figures for skilled persons reports commissioned. There have been 3 on controls and risk management frameworks and one in the prudential insurance lot.
The Upper Tribunal has ruled on an application by Mohammad Prodhan, former CEO of Sonali Bank (UK). Mr Prodhan contended that FCA was time-barred from taking action against him. He also applied for a direction for his anonymity in proceedings of the Tribunal and the FCA. Mr Prodhan alleged that FCA had not issued him with a Warning […]
Companies House has announced it now carries on additional checks on certain applicants for registration, to guard against designated persons using economic resources such as companies in an attempt to get round sanctions restrictions. From 12 December, Companies House will check applications from UK companies, European Companies, LLPs and SLPs, to assess the name, address, […]
The Charity Commission has warned charities that operate in Syria or Turkey of the dangers of aid passing through the Bab Al-Hawa crossing. There have been reports that the crossing is under the control of Al Qa’ida which means that charities and their partners that use it could inadvertently be funding that organisation and thereby […]
FCA is consulting on permanent rules to restrict the marketing, distribution and sale of CFDs and CFD-like options to retail consumers. The proposals are similar to the ESMA temporary measures, but FCA wants also to cover closely substitutable products and are proposing some different leverage limits. FCA feels the action is necessary because of constant […]
FCA has published the key findings from its recent information gathering exercise on pension transfer advice. This year it has collected information from an additional 45 firms and visited 18 of them. It found less than half the advice given was suitable and FCA is very disappointed that firms are still failing to give suitable […]
The Competition and Markets Authority (CMA) is consulting on its proposed Annual Plan, which sets out its plans and priorities for 2019 to 2020. Subject to the outcome of the Brexit negotiations, the CMA plans to give greater priority to potential market studies and investigations as it considers future work. The themes which it proposes should carry […]
FCA has published a decision notice setting out its proposal to find Mohammad Prodhan, the former CEO of Sonali Bank (UK) Ltd £76,400 in relation to the bank’s AML systems and controls. Mr Prodhan was responsible for the establishment and maintenance of effective AML systems and controls and FCA considered that between 2012 and 2014 […]
SFO announced that the first DPA, agreed with what is now ICBC Standard Bank plc for breach of s7 Bribery Act, has come to an end after the bank successfully complied with its terms. The DPA lasted for 3 years. Its terms included payment of compensation and disgorgement of profits as well as a fine, and […]
At its latest Board meeting, FCA has made changes to DISP and its guidance, effective from 8 November, to confirm that firms must not reject relevant regular premium PPI complaints without considering whether recurring non-disclosure is an issue. Separately, FCA has amended Chapter 13 of IPRU(INV) to require personal investment firms to have PII cover […]
Andrew Bailey has written to Nicky Morgan setting out FCA’s plans for improving accessibility and usability of the Financial Services Register, and updating on its recent consultation on the register of individuals.
FCA has published its review of how firms implement FCA whistleblowing rules. Its review covered a range of wholesale and retail banks. It found several areas of both good and poor practice to comment on, and now urges all firms to review the report and consider what steps they may need to take to improve […]
PRA has fined 2 individuals connected with the Bank of Tokyo-Mitsubishi following its action in 2017 against the bank and MUFJ Securities EMEA. It has fined Akira Kamiya, former Chair of Mitsubishi UFJ Securities International plc £22,700, and fined Takami Onodera, a former NED of the firm, £14,945. The actions occurred before the SMR took […]
The CMA has made a provisional finding that ComparetheMarket includes clauses in many of its contracts with home insurers that breach competition law and could lead to higher premiums for consumers. It says the clauses stop insurers quoting lower prices elsewhere and therefore prevent rival comparison sites and other channels from offering cheaper prices than […]
On 30 October 2018 the FCA announced that it had fined Liberty Mutual Insurance Europe SE (Liberty) £5,280,800. The fine relates to failures in Liberty’s oversight of claims and complaints relating to mobile phone insurance for the period 5 July 2010 until 7 June 2015. According to the Final Notice issued by the FCA, Liberty had entered into […]
FCA has published its H1 2018 complaints data, which show that firms received more than 4 million complaints in the period. This was a 10% increase from the previous period. Nearly all the complaints were made to 235 of the more than 3,000 firms which recorded complaints. PPI accounted for 42% of complaints, and then […]
FCA has written a “Dear CEO” letter on the duties of SIPP operators in respect of due diligence. The letter refers to the judgement in the Berkeley Burke case and several other pending civil claims, and asks firms to consider the potential implications of these cases for them and their customers. The Berkeley Burke case, […]
The High Court has delivered a judgment in David Lonsdale v National Westminster Bank PLC. The bank had made several SARs in relation to Mr Lonsdale and companies he was involved with and, as a result, had frozen all relevant accounts. After Mr Lonsdale applied to the court, the bank lifted the freeze. The next […]
PIFMA is concerned that the proposed extension of the upper limits of compensation FOS can order firms to pay out, from £150, 000 to £350,000 could put some small firms out of the market as they will be unable to get affordable PII cover. From 1 April, 2019, FCA is proposing to increase the limits […]
The FCA has published a feedback statement on digital regulatory reporting. This follows the FCA’s call for input on smarter regulatory reporting in February 2018. The FCA found that most respondents agreed that there are significant potential benefits to be gained by introducing digital regulatory reporting, with the most commonly cited benefit being increased efficiency. However, […]
Treasury has published some new draft statutory instruments to be made under the EU (Withdrawal) Act, or announced plans to make them, and also updated existing drafts. New or updated documents include Regulations on : plans for the Solvency II and Insurance measures Bank Recovery and Resolution Credit Rating Agencies (FCA has also published an […]
The FCA has published a ‘Dear CEO’ letter to debt packager firms, setting out its expectations on the provision of debt advice and counselling services. The FCA is concerned about the poor standards it has seen after undertaking a review of a small sample of debt advice provided by debt packager firms. The FCA stated […]
The Court of Appeal has handed down its judgement in R (Holmcroft Properties Ltd) v KPMG LLP. The case had raised the issue of whether KPMG, as a “skilled person” appointed to carry out an independent review of Barclays in the context of the IRHP redress scheme, could be judicially reviewed. The High Court had […]
Christopher Woolard has spoken on how FCA recognises the value of testing interventions so that regulation works most effectively. He highlighted how what may seem well intentioned and well designed interventions may in fact fail and how FCA has made significant use of behavioural economics to assess what works best. He gave an example of […]
FCA has fined Tesco Personal Finance plc £16,400,000. It found the bank failed to exercise due skill, care and diligence in protecting its PCA holders against a cyber attack that took place in November 2016. As a result, it breached Principle 2 by failing to act with due skill, care and diligence. When the cyber […]
ESMA has confirmed the further extension of the restriction on marketing, distributing and selling CFDs to retail clients, for another three months. Alongside the extension it has updated its FAQs, particularly to clarify how the measures apply to rolling spot forex.
FCA’s latest Market Watch focuses on market conduct and transaction reporting issues. It follows up on previous editions, which looked at FCA’s conclusions from a series of supervisory visits on suspicious transaction reporting. FCA had been concerned about over-reliance on “out of the box” alert calibration and that surveillance was not very developed for some asset […]
The FCA has opened a consultation that sets out how it will apply the Senior Managers and Certification Regime (SM&CR) to Claims Management Companies (CMCs), following taking over regulation of them from 1 April 2019. The consultation also sets out when SM&CR may apply to CMCs, and what action they will need to take. The […]
FCA has confirmed it has closed its remaining investigations into life insurers, following its thematic review into the fair treatment of longstanding customers in the life insurance sector. FCA has already closed investigations into some of the firms within its study and has now concluded no further action is needed in respect of the last […]
FCA has confirmed its ban on Christian Bittar, formerly interest rate derivative trader at Deutsche Bank. It found Mr Bittar requested EURIBOR submitters to make high or low submissions, both internally and externally, so that he could benefit his own and sometimes other traders’ profitability. Mr Bittar was convicted and imprisoned for his actions, otherwise […]
Michael Nascimento, the controlling mind of a £2.8m investment fraud was sentenced to 11 years’ imprisonment in the Southwark Crown Court. Between July 2010 and April 2014, members of the public were cold-called and subjected to high pressure sales tactics to persuade them to purchase shares in a company that owned land on the island of Madeira. […]
The ASA has published a ruling which upheld a complaint that the representative APR (RAPR) in an advertisement for Sunny Loans was insufficiently prominent. The advert’s ‘incentives’ that triggered then requirement for the RAPR were the lines ‘At Sunny they don’t charge fees at all’, and ‘Loans with no fees from £100’, delivered in voiceover and […]
The August edition of the PRA’s Regulatory Digest includes: news about a New Insurer Start-up Unit. This is a joint initiative with the FCA. The dedicated page on the Bank of England’s website includes a guide to becoming an insurer in the UK, and also a call for feedback on perceived barriers to entry in […]
FCA has confirmed its ban on Arif Hussein following a decision of the Upper Tribunal published in June. Mr Hussein was a derivatives trader with UBS, who engaged in internal chats with a UBS trader-submitter knowing that it would be improper to participate in conduct intended to influence UBS’ LIBOR submissions. FCA found that Mr […]
ESMA has confirmed the ban on binary options will remain in place for a further three months. The current ban, which prohibits marketing, distribution or sale of binary options to retail clients, expires on 2 October. ESMA has reviewed the specific features of certain binary options which make them less risky and as a result […]
The FCA has cancelled the Part 4A permissions of two firms, Causeway Group Limited and Prime Render Solutions Limited . The cancellation of the permissions is due to both firms failing to satisfy the suitability Threshold Condition, in that the FCA was not satisfied that the firms are fit and proper persons having regard to all the circumstances, […]
FCA has started criminal proceedings against Mark Starling for three offences relating to operating CIS without authorisation or exemption over a 9 year period and of fraud. Mr Starling is alleged to have operated schemes that purported to carry out financial futures trading for investors.
The Financial Ombudsman Service (FOS) has published a statement, following its October 2016 Consultation Paper and December 2016 Feedback Statement on complaints data publication. The Feedback Statement included FOS’s commitment to work with stakeholders to explore a new measure of cases received per 100 FCA-reportable complaints, and to report some resolved PPI complaints by volume only […]
The FCA has published its findings of the review of how Non-deposit Taking Mortgage Lenders (NDTMLs) and Mortgage Third-Party Administrators (MTPAs) handle complaints. In particular the review looked at how NDTMLs and MTPAs treat their customers, whether their complaint handling arrangements pose any potential consumer harm, and how they could handle complaints better. The FCA found that overall […]
The Co-Chair of the All-Party Parliamentary Group on Fair Business Banking has written to Andrew Bailey of the FCA in the wake of the FCA’s announcement that it was unable to take further action in relation to its investigation of RBS’ treatment of business customers. The letter calls for further information and action on a […]
The Upper Tribunal has upheld FCA’s decision to ban Alistair Burns, Director and CF1 of TailorMade Independent Limited, firm that advised on pension transfers and opt-outs, from any significant influence or senior management function because of his lack of competence and capability. It also directed FCA to fine Mr Burns £60,000 for failing to ensure the […]
FCA has added its own views on selling high-risk speculative investments to retail clients. It fully supports ESMA’s measures and notes that ESMA has also recognised the risks of products similar to CFDs. However, it is concerned firms will try to get around the ESMA product intervention restrictions by selling to retail investors products that […]
The FCA has published an update on its investigation into RBS’s treatment of small and medium-sized enterprise (SME) customers transferred to its Global Restructuring Group (GRG). The FCA commissioned an independent review in 2014 and found that RBS’s GRG unit had systematically mistreated customers. However, the FCA has now confirmed that it has no power to take […]
FCA’s latest Handbook Notice confirms several rule amendments, including: changes to DEPP and EG to explain the status of industry codes of conduct that FCA has formally recognised; changes to several parts of the Handbook including SYSC and COBS in respect of the IDD, to ensure professional firms regulated by FCA meet similar requirements to […]
FCA has banned the 4 former directors of a now-dissolved credit broker, Secure My Money Limited. It found the firm misled customers into thinking they had been approved for short term loans and as a result took fees of over £7.2m from around 124,000 online customers. The failings happened over an 8 month period. Customers […]
On a new page on its website, ‘Measuring our impact before we intervene‘, the FCA has published a group of documents that aim to provide an indication of how the FCA assesses the likely impact of its policies. These documents consist of: a paper setting out the FCA’s approach to conducting cost benefit analyses for […]
The Complaints Commissioner has published its annual report on complaints against FCA and FCA has responded. FCA notes that the Commissioner upheld FCA’s decision in 90% of the cases reviewed and generally feels FCA deals with the large majority of complaints fairly. It also takes on board the recommendations as to how it could have […]
FCA has published its annual report on enforcement actions. In 2017/18 it issued 269 final notices (of which only 21 were against individuals), secured 303 regulatory/civil outcomes (mainly involving refusal, variation or cancellation of permission or authorisation) and 14 criminal, and imposed 16 financial penalties which totalled nearly £70m. This contrasts to the £884m of fines 2 […]
Treasury is consulting on a proposed ban on cold calling in relation to pensions. The consultation is a technical consultation on the wording of the legislation necessary to implement the ban, as the policy decision has already been taken following earlier consultation. The consultation period lasts only until 17 August, and Treasury hopes to lay […]
FCA has published its Annual Report and Accounts for 2017/18. The report includes details of: FCA’s work preparing for Brexit; key regulatory changes such as MiFID 2 and PSD 2; work on SMCR extension; thematic work on high cost credit and consumer debt; and the PPI customer information campaign. It also articulates what FCA has done […]
FCA has published a paper looking at how it should approach fairness in price discrimination in financial services. It notes that price discrimination is not in itself unfair as practices such as student discounts are widely accepted. But others are more controversial, such as where longstanding customers receive a worse deal than new ones. Views […]
A new court dedicated to cybercrime, fraud and economic crime is to be built on the site of Fleetbank House, and is expected to be completed in 2025.
We recently wrote an article for Compliance Monitor setting out themes from recent FCA thematic reviews.
FCA has made new rules. The changes affect several parts of the Handbook, including: miscellaneous minor and clarificatory changes, including a change to the application chapter of SYSC to clarify that certain rules in SYSC 4.3A do not apply to an AIFM investment firm that is not a CRR firm; changes to make the Handbook consistent […]
Nicky Morgan and Andrew Bailey have exchanged letters of the problems customers faced following TSB’s IT migration. The Treasury Committee had asked about the work FCA had done in advance of the planned migration, its assessment of the problems and its views on TSB’s evidence to the Committee and its communications with customers as well […]
FCA has fined Canara Bank £896,100 for failings in its AML systems, and has restricted it from accepting deposits from new customers for 147 days. FCA found that, for a period of over 3 years, the banks failed to maintain adequate systems and did not take sufficient steps to remedy weaknesses that it had been […]
FCA’s latest quarterly consultation proposes the usual minor miscellaneous changes to its Handbook, including; changes to the appointed representatives appointment firm: the changes are spurred on by IDD changes but generally require firms to make a statement that they have complied with their regulatory obligations as principal; the COBS rules for insurance distribution to ensure […]
Carillion’s rise and spectacular fall was a story of “recklessness, hubris and greed”. Last week, the Work and Pensions Committee and the Business, Energy and Industrial Strategy Committee published the final report of their joint inquiry into the collapse of Carillion – a “giant and unsustainable corporate time bomb”. If, as the report states, Carillion […]
The FCA has published a memorandum of understanding (MoU) it has entered with the Insolvency Service (IS). The MoU sets out the agreement between the IS and the FCA that governs the exchange of information to better deliver the objectives of both organisations, in particular, in respect of information relating to misconduct, investigations and enforcement. […]
The FCA has today published a decision notice in which it has banned a director, Darren Newton, from working in any regulated activity in the financial services sector. The FCA found that Mr Newton had used customers’ money to purchase a debt management firm, First Step Finance Limited. The FCA commented that this “showed a […]
The Solicitors’ Regulation Authority has fined Anthony Gale, partner at Maurice Smiths solicitors who was also its compliance officer and MLRO, £10,000 for various conduct failings in relation to a number of mortgages. Mr Gale acted on a number of conveyances at the instruction of third parties without confirming the instructions with the client. The […]
The Financial Guidance and Claims Act has received Royal Assent. The Act: establishes a single financial guidance body, and sets out its objectives, functions and funding details. It also sets out requirements on regulators to make guidance and permits the making of regulations that ban unsolicited direct marketing relating to pensions and other financial products […]
PRA and FCA have published the first final notice for breach of an Individual Conduct Rule. They have jointly fined James (Jes) Staley £642,430 for breach of Individual Conduct Rule 2 (failure to act with due skill, care and diligence), after he tried to find out who had sent an anonymous letter. The letter claimed […]
Barclays has confirmed that FCA and PRA have issued draft warning notices in respect of their investigations into the the bank and its group CEO Jes Staley in respect of an attempt by Mr Staley to identify the author of an anonymous letter. The regulators propose a fine for breach of Individual Conduct Rule 2 […]
The FCA and the PRA have both published their business plans for 2018/2019. The FCA’s business plan shines a spotlight on consumer protection, including in relation to pension products and high-cost credit, as an area of concern for the forthcoming year, as well as ongoing programmes such as Brexit, and firms’ culture and governance (including […]
The FCA and PRA have, separately, published consultation papers on regulated fees and levies for 2018/19. In its consultation paper, the FCA sets out the proposed 2018/19 regulatory fees and levies for itself, the Financial Ombudsman Service, the Money Advice Service, the Pension Wise service and HM Treasury’s illegal money lending expenses. The FCA also […]
FCA has clarified its views on the regulation of cryptocurrency derivatives. It has previously explained that cryptocurrencies are, of themselves, not regulated although they may be part of other regulated products or services. Cryprocurrency derivatives, though, may be financial instruments for the purpose of MiFID 2. FCA says those who deal, arrange deals in, advise […]
FCA has reported that the defendants in its case against Capital Alternatives have been ordered to pay compensation and that it has obtained new undertakings from or injunctions against some of the defendants to protect against the risk of dissipating or diminishing assets.
FCA has warned firms it is prepared to take action against those who have failed to implement rules that have now been in force for a year designed to clearly show customers who are due to renew their general insurance the premium they paid the previous year. RAC has just agreed to contact customers after […]
In a recent report the Complaints Commissioner expressed concern about the absence of published information about how and in what circumstances information about live ombudsman cases may be shared between the FOS and the FCA. The complaint alleged that the FCA illegally influenced the FOS in its handling of complaints against a firm represented by […]
FCA has published a draft of its approach to enforcement and supervision. The documents follow its publication of its Mission, in which it committed to publishing a series of documents setting out how it carries out its main activities. The approach to supervision explains FCA’s commitment to being forward-looking and pre-emptive, focusing on firms’ cultures […]
John Griffith-Jones has reflected on FCA’s first 5 years of operation, since it took over from the FSA. He outlined: highlights – specifying FCA’s engagement with pension exit charges, general insurance renewals, interest-only mortgage work, FX and LIBOR issues and reform, MiFID 2 implementation, the Innovation Hub, market abuse enforcement, fixing PPI, the asset management […]
FCA has updated on its work reviewing potential closet tracker funds and closet constrained funds – funds that look like and charge fees in the same way as active funds do, but are managed like passive funds. Closet constrained funds do make active decisions, but on a restricted basis around their benchmarks. FCA is concerned […]
The Treasury Committee has written to Caroline Wayman, Chief Executive of FOS, following an episode of “Dispatches” that suggested FOS was staffing cases with individuals with inadequate training or understanding of financial products, and claimed some cases had been decided in favour of banks without a proper reading of the files. Nicky Morgan’s letter asks […]
As part of its ongoing work on culture and governance, the FCA has published a discussion paper, comprising a series of essays from academics and industry thought leaders covering: what a ‘good’ culture might look like; the role of regulation and regulators; how firms might go beyond incentives; and how to change behaviour for the […]
The Financial Stability Board (FSB) has published the final version of its Supplementary Guidance to the FSB Principles and Standards on Sound Compensation Practices. It consulted upon this guidance in June 2017, as part of its work on misconduct risk management. The Guidance is aimed at ‘significant’ firms and supervisors, and provides a framework to […]