In a letter from Russell Moore, I am requested to sign a VREQ that is essentially my agreement to cease all activities. The FCA is insistent upon my signing it.
Yet, had I signed it, SCM's activities and income would stop entirely. It would then be nonsensical to SCM to submit to a s.166 review (and its expense) when SCM had already ceased all of its activities.
A s.166 review would identify weaknesses. I would have none as I would be conducting no business.
Moreover, I was being asked to sign a VREQ to cease all activities before the FCA had (i) provided any evidence of alleged wrongdoings and (ii) ascertained weaknesses in SCM a s.166 review might reveal.
What would have made sense is for SCM to be allowed to continue its business whilst undergoing a s.166 review. That would identify any weaknesses and allow SCM time and opportunity to put them right (as the FCA does for other firms; see, later, the FCA's attestation policy).
Howard Kennedy describe the s.166 as a "fine before the event". More than that, the FCA's actions are contrived. The FCA attempted to bully me into following a nonsensical process that is not in the best interests of SCM or its customers to suit the FCA. It is a breach of process on the part of the FCA.
The FCA simply want to close me, SCM and SCF down.