Here we are again, siblings. Did you know that 2019 is 70% complete? I’m rounding up, it’s only 69.6% and we won’t go through 70% until Saturday, but I’ve always said that spurious accuracy in whimsical yet informative financial services weekly Updates is unnecessary and overrated. Although, to be completely accurate, the nature and quantum of that over-rating will depend on your actual rating. Some of you may rate it fairly low; in that case please disregard the last sentence and move onto the next one. Everyone else: just know that I’m here for you.

Addendum: when I said you should move onto the next sentence, I actually meant the next but two. You can’t be too accurate with these things. Actually, I’m not sure that’s quite true.


Our subject this week doesn’t have much to do with accuracy, but does have quite a lot to do with interpretation: these are two different things but I’ve always found that if you stick two unrelated concepts together in a sentence like that then it provides a useful bridge to the main substance of your piece. You’re getting all sorts of glimpses behind the curtain this week; I’ll tell you why in a bit.

Interpretation, then. As you know, we work in an industry governed by principles-based regulation. Around the edges of that are all sorts of other rules and regulations which also have a bearing on how businesses operate and serve clients. One of these has to do with contract law; another has to do with security and fraud prevention.

Within these three big areas of regulation and jurisprudence, there are plenty of grey areas. One of these is electronic signatures. Are they legal, binding and the equal of lines of colloidal systems of fine pigment particles dispersed in a solvent and applied to compressed moist fibres of celluloid pulp?

The answer to that is yes. Or at least it is now. A Law Commission report released last week (and spotted by the ever vigilant Tom Ellis) has confirmed that it is indeed totally fine to accept electronic signatures as evidence of identity and the basis of contract. The wee link there is to their PDF; it’s only a couple of pages long and is worth a read. You may particularly enjoy this paragraph:

“An electronic signature is admissible in evidence in legal proceedings. It is admissible, for example, to prove or disprove the identity of a signatory and/or the signatory’s intention to authenticate the document.”

Now, most of you will know that most providers want, at some point, to see lines of colloidal systems of fine pigment particles dispersed in a solvent and applied to compressed moist fibres of celluloid pulp arranged in such a manner as to indicate the given name of a given individual at a given point in time before they can have an ISA or a pension or whatever. Reasons for this range from ‘the law says we have to do it’ (nope, says the Law Commission) to ‘it’s for security’ (nope, says the Law Commission) to ‘oh for goodness sake just do it, I’m not going to fight Compliance’ (this is the actual reason in 87.4% of cases, though that number may not be accurate).

And that’s the interpretation thing. Actually, much of what causes irritation in our sector – massive key features docs, lengthy suitability letters, wet signatures – isn’t actually needed at all. It’s all interpretation, and backside-covering, or ‘prudent risk management’ in the language of the industry.

So this Law Commission report is helpful. We now know that there is no legal reason to require a wet signature; it’s all about risk management by providers and platforms. You may form your own judgements as to where risk controls are indeed prudent, or where they may be excessive. I’m going to go ahead and say that you probably shouldn’t need one for opening an account on a platform.


Co-inciding very neatly with the 70% year-complete figure is the 90% complete ten-year lifespan of the lang cat. For those of you trying to unpick that sentence, this company will be nine years old on Sunday coming. No, no fuss please. Maybe just a little cake.

As we enter our tenth year, we’ll mark that with some new, very cool stuff which we think will please you. More on that in November. For now, it’s a time to look back and reflect on the best ever period of my working life, which has seen this little enterprise grow from just me out on my own in a windowless cupboard up to a team of 16 ridiculously talented individuals, plus me trying not to get in the way too much. There is talk of putting me back in a windowless cupboard. I’m trying to ignore it. But a big thank you from me to everyone who’s supported the lang cat, read our stuff, let me come and do talks and all the rest of it.


  • We made it! Our sponsorship target for the #20milecatwalk in support of the Samaritans was £5k and we’re through it. If you’d like to find out more about why we are doing this then please read Steve’s blog and help us power well past the target if you feel able. The fact we beat the target on #WorldSuicidePreventionDay was particularly remarkable.
  • Big news from Aegon with Adrian Grace retiring to spend more time on his needlepoint or whatever it is CEOs do when they retire. The new replacement is a guy with a strong marketing and personal insurance lines background – be interesting to see what he makes of this business we call show.
  • Advisers, paraplanners and admins – we will still take your platform ratings, please and thank you. Only takes two minutes and is anonymous. We want to make this the biggest ever unbiased adviser sentiment exercise on platforms. Currently we need users of Novia, Fundsnetwork, Ascentric and Aegon to step up in particular.
  • And your music choice this week has to come from 2010, the year the lang cat started. The best record of that year was, as you know, Curse of the Red River by Barren Earth. So it might be a bit too obvious, but please accept The Leer as your offering.

See you next week