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The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
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This email is not intended to nor should it be taken to create any legal
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Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

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Thank you for e-mailing the Financial Conduct Authority's Information
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This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
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distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref:  FOI11476

Dear Mr Cornell,

We write further to your request dated 30 June 2024, for which the
statutory deadline is today.

We are sorry to inform you that we have not completed processing your
request and will not be able to respond by today’s deadline. This is
because there is a large amount of material falling within the scope of
your request. We are required to review this material and this review is
not yet concluded.

We will endeavour to provide you with a substantive response to your
request by 13 August 2024. We will of course respond sooner if we are able
to do so.

Please accept our apologies for the delay.

Yours sincerely

Information Disclosure Team

12 Endeavour Square

London E20 1JN

Tel: +44 (0)20 7066 3362

[1]www.fca.org.uk

Information Disclosure Team

Financial Conduct Authority

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
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Thank you for e-mailing the Financial Conduct Authority's Information
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This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
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of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

Thank you for your email. We are sorry to inform you that we have not yet
completed processing your request.

This is owing to the large amount of material which we are required to
review and the large volume of cases which we are presently dealing with.

In the circumstances, we will endeavour to provide you with a substantive
response by 6 September 2024.

Yours sincerely

Information Disclosure Team

12 Endeavour Square

London E20 1JN

Tel: +44 (0)20 7066 3362

[1]www.fca.org.uk

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. http://www.fca.org.uk/

Our Ref: FOI11476

Dear Mr Cornell,

In our email of 20 August 2024, we advised you that we intended on
providing a substantive response to your request by 6 September 2024.

However, we do not anticipate that we will be able to meet this deadline.
As noted in our earlier correspondence, there is a large amount of
material to review, and this review has not yet been completed.

We now expect to be able to respond to you by 20 September 2024. Please
accept our apologies for the delay in responding to you.  

Yours sincerely

Information Disclosure Team

12 Endeavour Square

London E20 1JN

Tel: +44 (0)20 7066 3362

[1]www.fca.org.uk

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. http://www.fca.org.uk/

Thank you for e-mailing the Financial Conduct Authority's Information
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This is an automatic acknowledgement to tell you that we have received
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Please do not reply to this email.

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This communication and any attachments may contain personal information.
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FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

We apologise for the continued delay - we had anticipated that we would be able to respond to you by the last date advised.

We will continue to process your request and provide a substantive response as soon possible.

Yours sincerely

Information Disclosure Team

12 Endeavour Square
London E20 1JN

Tel: +44 (0)20 7066 3362
http://www.fca.org.uk/

show quoted sections

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

Thank you for your email. We are sorry to inform you that we have not yet completed processing your request.

We appreciate your frustration, and again apologise for the delay.

Unfortunately, it is not possible to split the relevant material into batches and we are still completing our analysis of the relevant material. Consequently, we are unable to provide a partial disclosure.

We anticipate that we will be able to provide you with a substantive response by 16 October 2024. If we are able to respond sooner, we will of course do so.

Yours sincerely

Information Disclosure Team

12 Endeavour Square
London E20 1JN

Tel: +44 (0)20 7066 3362
http://www.fca.org.uk/

show quoted sections

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

Please accept our apologies for not contacting you before today's date. We appreciate that we are in breach of the deadline imposed by FOIA and understand your frustrations regarding the continued delay.

We have not yet completed our analysis of the relevant material but are working hard to satisfy your request. We are close to completion, however, and expect to provide issue our substantive response on or before 8 November 2024.

Yours sincerely

Information Disclosure Team

12 Endeavour Square
London E20 1JN

Tel: +44 (0)20 7066 3362
http://www.fca.org.uk/

show quoted sections

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

We apologise for not updating you before this time.

Following the recent ICO decision notice (IC-316363-G8P2), of which you will be aware, we now consider that further information would likely be disclosable in relation to your request.

Consequently, we are re-considering some of the in-scope material, to identify which additional information should be disclosed. Further to this exercise, we will provide you with our substantive response by 21 November 2024.

Yours sincerely

Information Disclosure Team

12 Endeavour Square
London E20 1JN

Tel: +44 (0)20 7066 3362
http://www.fca.org.uk/

show quoted sections

Our Ref:   FOI11476

Dear Mr Cornell,

Freedom of Information: Right to know request

We write further to your information request dated 30 June 2024, in which
you asked us to provide:

“…emails (including their attachments) sent to or received from the email
accounts of FCA officers listed below between the first of October 2017
and the date of this request, in which the phrase "Collateral (UK)" or
"Collateral UK" appears and also emails in the same chains of
correspondence related to Collateral (UK) Limited.

 a. Nicholas Mears
 b. Charlotte Freed”

Please accept our apologies for the delay in providing you with this
response. We have now processed your request but can neither confirm nor
deny whether we hold any information concerning Charlotte Freed, which
falls within the scope of your request. This is because such information
constitutes personal information and is consequently exempt from
disclosure under section 40 (Personal information) of FOIA. This is in
line with the FCA practice of not generally disclosing the names of
current staff below management level as well as the names of former FCA
staff below Head of Department.

Regarding the remainder of your request, we can disclose the attached
document (Annex A). In line with our previous approach, agreed with you
and the ICO, please note that:

 1. We have removed documents which in their entirety do not relate to
Collateral (UK) Ltd.

 2. Where only some information in a document concerns Collateral (UK)
Ltd, we have ‘whited-out’ those parts which are out of scope because
they do not relate to Collateral (UK) Ltd; and

 3. Regarding the remaining in-scope information, we have removed
duplicated material, and redacted:

 a. Information which is exempt from disclosure under section 44 of FOIA
because we are prohibited from disclosing it to you, as it constitutes
‘confidential information’ for the purposes of section 348 of the
Financial Services and Markets Act 2000 (FSMA) and which the FCA has
received in the discharge of its public functions.

 b. Information which is exempt from disclosure under section 40 (Personal
information) of FOIA because disclosure would reveal the personal data
of the individuals concerned.

 c. Information which is exempt from disclosure under section 36
(Prejudice to the effective conduct of public affairs) of FOIA because
such disclosure could restrict the free and frank exchange of views
when considering issues or otherwise prejudice the effective conduct
of public affairs.

For more information on why these exemptions apply, please see Annex C
below.

Your right to complain under FOIA

If you are unhappy with this response, you have the right to request an
internal review. To do so, please contact us within 40 working days of the
date of this response at [email address].

If you are not content with the outcome of the internal review, you also
have a right of appeal to the Information Commissioner by phone or on
their website at:

• Telephone: 0303 123 1113
• Website:  [1]www.ico.org.uk

Yours sincerely

Information Disclosure Team

12 Endeavour Square

London E20 1JN

Tel: +44 (0)20 7066 3362

[2]www.fca.org.uk

Annex C

• General right of access to information held by public authorities

Anyone making a request for information to a public authority is entitled
to be told in writing by the public authority whether it holds the
information the request describes. If the public authority holds that
information, the person requesting it is entitled under section 1(1)(b) of
FOIA to have the information communicated to them. These rights, in
section 1(1)(a) and (b) of FOIA, also have some exclusions and exemptions.

• Section 40 (Personal Information)

To the extent that the information that we hold contains personal data
about individuals, section 40(2)(b) of FOIA provides that "any information
to which a request for information relates is also exempt information if
the first, second or third condition listed below is satisfied."

We have applied this exemption because the first condition (as stated in
section 40(3A) of FOIA) is satisfied. Some of the information you have
requested comprises the personal data of individuals other than yourself
which, if disclosed, would contravene any of the data protection
principles.

In particular, it would be a breach of the first data protection Principle
as set out in Article 5 of the UK GDPR, to disclose such information, as
it would not be lawful or fair to the individuals concerned to do so. This
is because, they would not have had the expectation that this information
would be disclosed under these circumstances, and therefore disclosure
would not be necessary, or lawful, where none of the conditions in Article
6 of the UK GDPR have been met.

This is an ‘absolute’ exemption, and so it is not necessary to balance the
public interest for and against disclosing the information.

• Section 44 (Prohibitions on Disclosure)

Section 44(1)(a) of FOIA states that information is absolutely exempt from
disclosure if this is prohibited by law. Section 348 of FSMA restricts the
FCA from disclosing ‘confidential information’ it has received in the
course of carrying out its public function. FSMA allows exceptions to this
in a few specific circumstances, but none of these apply to this request.

Confidential information here is defined as non-public and non-anonymised
information involving a person’s business or other affairs, which the FCA
received in the course of carrying out its public function.

The information you requested is confidential information under this
provision. Disclosure of this information in breach of section 348 of FSMA
would be a criminal offence.

In many requests for information under FOIA we have to consider different
factors to decide whether disclosing the requested information would be in
the public interest or not. For this request, we have an ‘absolute’
exemption against supplying the information, and so we do not need to make
this kind of consideration.

• Section 36 (Prejudice to the effective conduct of public affairs)

Under section 36(2)(b)(ii) and (c) of FOIA this exemption applies if in
the FCA’s reasonable opinion, disclosure would be likely to restrict the
free and frank exchange of views for the purposes of deliberation or would
be likely to otherwise prejudice the effective conduct of public affairs.
This decision was taken by a Qualified Person. This letter explains why,
in their opinion, the exemption applies, and it is not in the public
interest for us to disclose this information.

The FCA needs a protected space to hold discussions about sensitive
information and to function effectively, the FCA needs to feel confident
that sensitive information will not be disclosed. If it is disclosed, this
would seriously undermine the mutual trust that exists between the FCA and
its staff.

Section 36 is a ‘qualified’ exemption, which means that it is subject to
the public interest test. Therefore, the Qualified Person has considered
the below factors for and against disclosure.

In favour of disclosure

• It is in the public interest that information on how the FCA makes
decisions is made available to the public, as these are of importance
to consumers and for the wider regulatory regime.

• Disclosure of this information would also show the FCA to be an open
and transparent organisation and would offer greater transparency on
the operation of the FCA, its decision-making processes.

• Public scrutiny could lead to robust deliberations leading to better
decision making.

Against disclosure

• Disclosure could inhibit the free expression and constructive
deliberation of FCA staff on similar matters.

• Disclosure of this information may inhibit FCA staff from engaging in
free and frank discussions because of concern that their discussions
will be exposed to public scrutiny or comment – which in turn would
damage the quality of deliberation in such exercises and lead to
poorer advice and decision-making.

• Disclosure of this information would lead to unwarranted speculation
and the FCA needs space away from live public scrutiny so that the
decisions it makes are sound and well considered. Without a protected
space for open and honest discussion of the important and complex
issues involved, decision-makers could be discouraged from frank
exchanges.

Overall, taking into account these factors, the Qualified Person is
satisfied that we should give greater importance to protecting the FCA’s
ability to have full and open discussions on these such matters, and so
this exemption should apply.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. http://www.ico.org.uk/
2. http://www.fca.org.uk/

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

Thank you for your email. We can confirm that those pages were not whited-out and contain no other information.

Please let us know if we can be of further assistance.

Yours sincerely

Information Disclosure Team

12 Endeavour Square
London E20 1JN

Tel: +44 (0)20 7066 3362
http://www.fca.org.uk/

show quoted sections

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Our Ref: FOI11476

Dear Mr Cornell,

Freedom of Information: Right to know request

Thank you for your email, dated 29 November, regarding the information you
have requested under the Freedom of Information Act 2000 with the above
reference.

We are considering the points you have raised in making a request for an
internal review and will contact you again as soon as possible. If it is
likely to take more than 20 working days from the date of receiving your
email to respond in full, we will write to you again.

Yours sincerely,

Information Disclosure Team

Communications Division / FCA

This email is classified as FCA Official, unless marked otherwise

Please be polite to our people when requesting information, as we don’t
allow abusive behaviour towards them and it may impact how well we are
able to communicate with you on your request. Find out [1]more.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. https://www.fca.org.uk/contact-us/unacce...

Our Ref: FOI11476

Dear Mr Cornell,

We refer to our email dated 03 December. I am sorry to inform you that we
have not yet concluded our internal review of the FCA’s response to your
information request with the above reference, made under the Freedom of
Information Act 2000.

We are still considering this matter and now hope to be able to respond to
you by 28 ^ January, although should we be able to contact you sooner, we
will do so.

Thank you for your patience and understanding.

Yours sincerely

Information Disclosure Team / Operations Division

12 Endeavour Square

London

E20 1JN

Tel: +44 (0)20 7066 1000

[1]www.fca.org.uk

Please be polite to our people when requesting information, as we do not
allow abusive behaviour towards them and it may impact our ability to
communicate with you on your request; abusive language is a factor in
considering whether a request is vexatious (which can form a basis for
refusing a request). Find out [2]more.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. http://www.fca.org.uk/
2. https://www.fca.org.uk/contact-us/unacce...

Our Ref: FOI11476

Dear Mr Cornell,

Freedom of Information: Right to know request

I refer to your email dated 29 November asking the Financial Conduct
Authority (“FCA”) to review its decision provided in response to the
information you requested FOI11476 under the Freedom of Information Act
2000, which we have considered under the FCA reference. Please find
attached the outcome of the FCA's review.

Thanking you.

Yours sincerely

Information Disclosure Team / Communications / Operations Directorate

Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

Tel:    +44 (0)20 7066 1000

[1]www.fca.org.uk

Follow us:

[2]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

Please be polite to our people when requesting information, as we don’t
allow abusive behaviour towards them and it may impact how well we are
able to communicate with you on your request. Abusive language is a factor
in considering whether a request is vexatious (which can form a basis for
refusing a request). Find out [4]more.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(https://www.fca.org.uk/site-info/legal/f...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site https://www.fca.org.uk (FCA); https://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. http://www.fca.org.uk/
2. https://twitter.com/TheFCA
3. https://www.linkedin.com/company/financi...
4. https://www.fca.org.uk/contact-us/unacce...