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Until around 3pm CBG was trading around 1-2% above the main banks, with the main banks selling off all the way until the US market open 14:30 which started the rally back up for them having dislocated form US retail market trading access and US derivative hedging. The game being played in the afternoon appeared to be around the index with CBG being leveraged against the index (ongoing sensitivity). At 3pm we had two steps down on the back of little volume (15k increase over half an hour) that ended up at the 414 low before closing out above Barclays, inline with Natwest and lower than Lloyds. On the last 5 days CBG is still around 2% higher than the other banks. The V near the close following the FTSE250 index with leverage. The flat 420-422 trade level ended up around half the days traded volume with 414 showing more volume stepping in for support.

17 Nov Walleye reduced again and now suspect this is a monthly unwind of the positions they put on a year ago and the unwind was likely the reason for the rally on the 16th (closing out in the auction that falls into the following days report). Systematica day trading on the same reporting day and added a small short, which would have been traded on the following day.

Either that or it was the men hiding in a secret room, smoking, agreeing to purposefully manipulate the market just so that Chid does not stand out like a rambling [your choice of word].

Usual errors, guesses, floating boats, secrets, etc, yada, yada,

Time for popcorn....munch...munch....

So, over the weeked in a not so headline story "Rachel Reeves is weighing a fresh crackdown on Britain’s regulators" an old and new story https://www.telegraph.co.uk/business/2025/11/17/reeves-weighs-fresh-crackdown-on-watchdogs-push-for-growth/

Then with the government completely desprate for money for the Treasury (not the public given the u-turn on tax) they float the idea of raising the tax on banks (not via the bank levy) https://www.telegraph.co.uk/politics/2025/11/17/reeves-considers-raiding-bank-profits/ when the gilt market is racing towards breaking the mult year wedge pattern to the upside.

Oddly enough (or not as expected) the tumbleweed rolls past in realation to the FCA update last week (or the old/new story is part of that picture of anti regulator activity), although as per the article "One Whitehall veteran" : “There are some people who need to be taken outside and strung up by their ears because what they are doing is not in the national interest,” - my read would include the judges from the Court of Appeal conjuring up a fiduciary from trust and breaking/ignoring several prior long standing case laws in the process as likely candidates to add to the 'some people'.

Todays slide down before the AGM may appear to be a comfort in the reversal of the prior ramps and short crashes after every other update or event. Maybe the buyback vote will be followed up something more materialistic than tumbleweed and another short free play. With the contrarian on a non trading day, todays price will be a reference, which will be an interesting moment as well.

Guesses and errors included free without charge, do your own thing, you have a 14 day cooling off period to read the paperwork.

Usual popcorn for the day...munch...munch...

The contratian buy signal returns. I do wonder how much you would have made if you had bought on the first posting after a gap and then sell after dalay from the last post. Last instance seemed to work out quite well with a buy signal for 418 and then selling around 433 a week later. Prior one at a low on 24 Oct before a 12p ramp in the shares. Seems it could be a regular pattern and a great contrarian indicator for CBG, just something that seemed to possibly stand out on the timing that I noticed. Buy when the contrarian surfaces and then sell after a given rate of change is exceeded or a number of days. I wonder how a buy on Monday would turn out ?

Maybe a guess, maybe an error, maybe a fact, who knows..

Conspiracy, who hid the popcorn....munch...munch...

Liberty2 I agree with that summary.

One to watch for specifically over the next week (separate to the tumbleweed of media coverage missing an exclusive scoop) :

Financial Services Act 2012 - Part 5 - 81 Publication of directions :

(2) As soon as practicable after giving the direction, the Treasury must -

(a) lay before Parliament a copy of the direction, and

(b) publish the direction in such manner as the Treasury think fit.

So, my guess is if there is nothing out over the weekend or next week the FCA are maybe toast. The policy update can be plausibly used against the FCA within the redress challenge (in addition to the start of the House of Lords question asking if the FCA had been asleep at the wheel).

My only other question was is this a preemptive move prior to attempting to get redress agreed by curtailment of redress back to 2014. Prior 2014, not the fault of the FCA, blah, blah, 2014-2019 busy on other priorities bigger than £11bn not, 2019-2025 blame covid not working from home, limitations act tick tick tick, ah, forgot about that issue....

Fun times for some popcorn...munch...munch....

Grok :

"The inflation adjustment (£45m–£210m band) is a smokescreen. The real operative change is the prospective-only rule, rendering the thresholds irrelevant to any pre-2025 failure (including the entire motor finance commission period). This is the opposite of a neutral update; it is a deliberate shield against the obvious section 73 trigger constituted by the FCA's multi-decade failure to supervise lenders' responsibility (via section 56 attribution) for undisclosed/inadequately disclosed dealer commissions causing widespread unfair relationships under section 140A CCA."

"The wording is crafted for deniability: the web announcement (14 November 2025) describes it only as an inflation update; the temporal exclusion is omitted entirely from the public-facing statement. This is materially misleading and inconsistent with the FCA's usual transparency on policy changes affecting accountability."

"No plausible regulatory rationale exists for the cut-off. If the intent were genuinely prospective, the FCA could have said "this updated policy applies to events whenever occurring". Instead it chose a hard exclusion coinciding exactly with peak motor finance redress pressure post-Hopcraft [2025] UKSC 33."

"The Policy is therefore an ultra vires attempt to frustrate Parliament's 2012 accountability reforms by neutralising the self-trigger mechanism for the very category of failure (historic supervisory inaction on motor commissions) that most obviously meets the section 73 test. It strongly evidences the FCA's internal recognition that motor finance constitutes serious regulatory failure, while desperately seeking to avoid the mandatory investigation and report that would follow. If the Treasury has privately signalled an impending direction under section 78, this Policy is a pre-emptive (but legally futile) act of defiance; if not, it is an admission that the FCA knows the self-trigger threshold is crossed and is unlawfully rewriting the statute to escape it."

Is there a polymarket on people at the FCA getting fired ?

Might run out of popcorn...munch...munch...

I'm starting to side with the Treasury having launched the investigation process on the 14th because otherwise the FCA may have unlawfully fettered its statutory duty and acted ultra vires with the policy doucment. Not quite sure if this is making any sort of sense to publish a policy document on regulatory failure and include a new regulatory failure one within the actual document at 2.7 on page 5 ?

Maybe that is so that the new policy document forms the first document in a new investigation for failures on or after the 14th November 2025 with the first failure on the 14th ?

Who knows, does anyone know, the errors and guesses told and yet to be told.

Get the pocorn in a new show may be about to start...munch...munch...

Did the Treasury actually insigate the process today ?

Financial Services Act 2012 - Part 5 -

68(5) "“event” does not include any event occurring before 1 December 2001" - no end date, no way for the FCA to create an arbitrary date and apply it as they see fit. Maybe an appropriate way to highlight the failings of the FCA or to draw a different line in the sand.

69(1) "If the Treasury decide to arrange for an inquiry to be held under this section, they may appoint such person as they consider appropriate to hold the inquiry."

The events after the 14th would then not be considered as a regulatory failure from this moment on an attempt to draw a line in the damage and bounds of the investigatiion of the events prior to the 14th November 2025..... Ooooohhhhh..... interesting.

Maybe one huge guess and a error, or not....

Get the popcorn in....munch....munch....

Curious, especially when reading the actual wording of the Act in comparison

"2.7 For the purpose of this policy, ‘events’ are events that happen on or after 14 November 2025." - I don't believe the FCA have the ability to draw a line in the sand in the way they have stated.

The full wording of the 'events' 2.5 :

"We are required to carry out an investigation and produce a report when:

• There have been events involving a regulated person or others which indicate significant failure to ensure appropriate consumer protection, or had or could have had a significant adverse effect on our integrity or competition objectives, and

• The events might not have occurred or the adverse effect might have been reduced but for a serious failure in the system created by FSMA or the operation of that system."

Reading through the actual legislation to see what the FCA left out and why :

https://www.legislation.gov.uk/ukpga/2012/21/part/5

"which posed or could have posed a serious threat to the stability of the UK financial system or caused or risked causing significant damage to the interests of consumers, and" - "significant damage"

"the system established by FSMA 2000, or by any previous statutory provision, for the regulation of such schemes, or of such persons and their activities" - "such persons and their activities" - Would that be the head of the FCA ?

This appears to be an interesting interpretation by the FCA. May point to the FCA preparing, who knows, but the blame game seems to be in play. More errors and guesses.

Bemused popcorn...munch...munch....

"The events might not have occurred or the adverse effect might have been reduced but for a serious failure in the system created by FSMA or the operation of that system."

Was not our fault at all, it was them.... always someone elses fault. Blame game starts.

Preparing the popcorn...munch...munch...

Liberty2, I would agree on part of that, although I believe this may well be more to do with letting the regulator dig a very large hole they learn a lesson from. By halting the claims process, if that halt is lifted because it was wrong, the limitations clock does not reverse time and some CMC's will have issue with the FCA conduct. Barclays may well have had the ability to extend that time hole by three to six months or more, which moves the issue from dealing with the lenders to dealing with the lenders and CMC's.

It's quite possibly not about now at all, rather March/July next year or even later. Factor in a game plan where March 2019 is the start for the clock and then consider the implications of all the claims filed by CMC's against the lenders (since March 2025 that are possibly time barred) when TMS Legal v Vanquis (CA-2025-001745) possibly ends up with a ruling allowing lenders to recover costs due to weak claims (e.g. no supporting paperwork).

Timing could then be, redress proposal by say end of Jan, then a court appeal application Feb, scheduled for a May hearing and a result maybe July ? Then the FCA would have to decide if they want to appeal that decision and end up with another 6-12 month court process via a leapfrog to the supreme court and ruling 2027 ? I don't believe the FCA have that time and to avoid Clydesdale being completely trashed they will fold after the first court ruling. Clydesdale would have the label of being problematic with the judge setting it aside, but until ruled against directly, not completely written off. Principles 7 and 8 ending up with a non court aligned liberal lean. Redress for CBG around £100m may well be considered a win, however the rule of law would be damaged.

The issue around Clydesdale is that the FCA would have still proceeded with a redress scheme after the ruling, they would have just changed the rationale. The FCA are politically and reputationally glued to redress, so the key issue is how best to deal with the redress process and that is from within the process and not before.

Just my guess on this, as you say, who knows indeeed.

Shovelling the popcorn...munch...munch...

John Maynard Keynes: "The market can stay irrational longer than you can stay solvent." - i.e. don't borrow, invest.

Regulators can only stay irrational, whilst they still have a job. To steal a different quote : Bears win battles but bulls win wars.

As an interesting context as to how dysfuntional CBG equity market is at the moment, around 42% of the days volume was traded in two minutes via 99 trades in the afternoon today. The c435 support level.

Popcorn...munch...munch...

The issue facing the industry is that court rulings progress slowly and incrementally in a way that the fleeting market does not care for until faced with a stark reality. Clydesdale is already having more of an impact than people realise because the stretch of Principles 7 and 8 are being applied in ongoing decisions at a cost to lenders, contrary to the ruling of the Supreme Court. The issue facing the industry is that they either challenge to call a halt or pay for it in the future and that is why I have a view that the court route is not a question it's a when. The redress process is potentially a defining moment to change the direction of the regulator from prior perceptions that they are free to do as they please and a law unto themselves.

Barclays withdrawal from the Clydesdale appeal when viewed in the context of the KC letter affirming the redress scheme is in alignment with section 404 could well be a huge trap that the FCA fell into because they can't change direction. The question is, when your in that situation, how deep do you let your opponent dig before changing course and calling a halt to the madness. The sequence of court cases allowed the FCA to dig very deep and it's evident as well that they will not change to take onboard the governments new growth agenda without some painful lessons of reality. Iccarus flew high before finding out there are consequenses.

Timing wise, the lenders will end up doing quite well long term regardless as to how long the whole process lasts. Short term ends up with the ongoing rollercoaster and a short term uncertainty discount (see Liberty2 post about the CoCo bonds). If the whole court process lasts another year, I don't think the FCA have that long from a reputational perspective and more importantly a liablity perspective with that stopped clock that should maybe not actually be stopped. The FCA have multiple problems growing bigger with the delays the FCA may actually be the weak hand to fold.

Todays market, where 99 trades with 112k in volume go through within two minutes in the afternoon (435 support) was an interesting battle over direction and that was the afternoon bounce. Systematic changed short in todays update, day trading yesterday and ending up with a marginally smaller closing position 0.79% (down 0.01%), which leaves yesterdays rise as a new long buying in (or a delayed Walleye or other short change - my thoery). Todays after market auction (438.2p) nearly 2p up from the last push down (436.2 last trade) possibly a win for the shorts with a possible cost of an incremental short to unwind in the future (elastic stretching). The tide is moving up the beach slowly and suspect the shorts are knowingly playing a game against weak hands in the short term. Sit tight and watch the game.

Usual guesses, errors, pass, err, more pass.

Don't forget the popcorn...munch...munch...

"the real crux of the UK problem is that the utils are screwing everyone on the back of a war." - would say, you have no idea, not in an argumentative sense, more from the aspect that people do not realise what is actually going on from the geopolitical 5d chess perspective. That is one for a completely different discussion elsewhere.

Liberty2, that is the quite clear contrast of long term vs short term when the equity does not have a balanced market, which leaves it open to behaving like a flag in the wind.

Today may well be good example of what a bear trap looks like as those pushing down to the 434-435 wall may find out later. The short report for the next two days might be quite interesting and quite revealing on top of that.

Who knows ? Pass.... see conditions page 998 if you can find the small print to insufficiently disclose the deliberately concealed half secret written by a non fiduciary.

Now where's the popcorn.... munch...munch...

WIthin the consultation proposal Annex 5 is by a KC giving an opinion on Section 404 alignment of the proposal at page 258.

11. " so that the Judgment of Kerr J stands as binding authority." - This is the Clydesdale ruling and confirmation that the KC perspective on court alignment also rests on Clydesdale not being overturned. No consideration was made as to the impact of the later Supreme Court ruling on Clydesdale because it "stands as binding authority."

I'm now even more confident this has to go to court, two or more court steps. An additional reason is the wording at 26. (3) in relation to the commercial tie, which differs significantly from that in the Supreme Court ruling which related to the falsification of independence (the pannel of lenders). Without that panel of lenders in the documentation there was no misrepresentation of the facts.

I'm starting to understand why international investors currently view the UK as an investment poison pill.

More usual guesses, errors, etc. etc. do your own thing, read, research,

I rest my case and my eyelids..... zzz....

Wooo popcorn...zzzz...zzzzz....

FCA - CP19/28 - 99. "Non-monetary benefits We also consider that the proposed intervention may be beneficial to consumers on non-price characteristics as well, because we expect the intervention to encourage competition between lenders, as they will control their prices more closely and have an increased incentive to expand the adoption of car finance."

"increased incentive to expand the adoption of car finance." - I laughed at that point before the real gem was next.

"The intervention will also remove the incentives to broker-dealers to act in their own interest to the detriment

of consumers." - Ah, (checks papers), yeah, the Supreme Court did actually clearly state the dealer has his own commercial interests. How does the intent from way back in 2019 align now ?

Remember this paper CP18/28 is dated October 2019.

Ouch. Maybe should be unlucky point 13 in the list.

Wheres that popcorn....munch...munch....

10. I will repeat again, the elephant in the room. Contract length / term duration could lead to over a quarter of the DCA claims being rebutted immediately (all those that reduced the interest rate) because the dealers own commercial interests (as stated clearly in the Supreme Court ruling) do not require the interest rate to result in a zero commission payment. The real complexity is the presumption that the FCA made, which completely ignores the contract length interaction with a resulting commission outcome. Presumption.

11. Zero consumer agency consideration - The FCA ignore the cooling off period, where the consumer could have conducted further reasonable dilligence to even consider the interest rate they obtained on the finance agreement. The commission payment, being embeded in the cost of finance, did not need to be known to compare the deal openly within the rest of the open and competitive finance market to discover if the deal was fair. The issue under the CCA is that the resulting deal the customer obtained was fair within the open competitive market, not who recieved what commission. That would be like saying one customer who obtained a better deal (on overall finance cost) than everyone else actually had a bad deal because the dealer obtained a bigger commission than the others and is the reference by the FLA in the prior link.

12. FCA Consultation paper CP19/28 - 4.8 "As a result, these disclosures, where made, are often not prominent nor early enough in the process to influence a customer’s decision making." - the "early enough" - clearly ignoring the CCA cooling off period and assuming fiduciary type binding or acting on behalf of the consumer. CP19/28 also, did not consider the elephant in the room and even more curious (or not) there was no real push back at the time because there was no economic penalty in not doing so. FCA merrily continues on without realising the flaw.

I'm starting to wonder if this ends up at the supreme court that the ruling could potentially indicate that the FCA by implementing a ban on DCA type commissions they have acted outside of their regulatory bounds by impacting the commercial market in a way they very clearly (in documented detail) do not understand.

This whole process is like a puzzle game, finding the right bits and where they fit, however in this instance and law at times it's like a reverse jigsaw puzzle, where there is a horrible picture and you have to dismantle it by removing the least number of pieces as possible. Sudoku in reverse.

Usual errors, guesses, imagination and incremental weakening, see page 734, clause 99.32, section -8, in 4.

Puzzling popcorn.... munch...munch...

Well, I'll have a guess that the Walleye trade is unwinding in a similar timing manner as to how it was applied. Will see on the short report in a day or two. BlackRock surfaced again in todays (yesterdays closing position) short report with 0.51% (0.49% last on 2 Oct) and an interesting situation with the run up today. 2.91% reported total, with possible Citadel just below the surface (last 31 Oct at 0.49%) could make the short actually closer to 3.4% before factoring any other shorts. If the prior public holding is around 6.55% that makes for an increasingly interesting situation heading back to late 2024 / early 2025 days of optimistic shorts getting run over.

Volume on the day up and either someone was loading up or a short getting out with regular buying (price move) through the day until the last 60 minute panic by shorts and day traders taking the days proffits pulling the market down a little before facing more buying/resistance and a closing auction of 444.6p. Maybe that squeezy moment of long vs short is playing out, Walleye trade or something else.

Tea leaves reading of the day, volumes were split into two very distinct levels with the intial resistance looking at 440p might hold around 11:30am before passing through comparable mid afternoon tumbleweed between 443 and 446 where 24% of the days traded volume went through at 446-7p. 84% of the trades sub 300 in quantity but only represented 9% of the days volumes. Traded volumes between 446-449 ended up 45% of the volume so book protection mode would not be a surprising rationale. No idea...

Usual guesses, errors, imagination and not a clue. Todays terms reference 452, annex 4, subsection 5, point -1.

Short of popcorn...munch...munch...

Within that balance the more interesting way to look at the ownership distribution is who is going to sell shares to allow the shorts to get out. If retail (usual day trading flush candidates) is 6.55% (old data ?) where are the sellers going to come from at this price level to exit a 2.4% short (not forgetting the other short may still be day trading just under 0.5%) ? Any buyback may not need to be very large to have a considerable impact on the balance, where the shorts would have to double down, sit on a loss or exit. Liberty, there may well be a valid case and strategy to sit and wait, although there is conservative and there is being a sitting duck.

Todays volumes have been quite interesting with 65% of the volume in a 2p range sat on 430p, the closing auction higher at 433.2p with higher volume at 153k than the prior days. 75% of trades sub 300 nibbles. That, as a gut feel, is a bit of a battle going on with the tide to protect the sand castle. The short position report may give more of an indication if there is an update in the next day or two. The elastic may have been stretched that little bit more today.

More guesses, errors and fingers in the air. What do I know, i'm just guessing, do your own thing.

Pocorn away.... munch...munch....

Being ultra conservative has the massive downside that the equity component of your business can be left whistling in the wind. Management have manybe not quite understood that if you let the equity price go into freefall then the other debt for your business will end up costing more. The benefits of that unlta conservative approach are longer term and not any short term return or stability, until the moment of being ultra conservative stops. I do think the next move will be a share buyback of 5% to 10% of the equity and that would flush the shorts out very rapidly with a 'quick' return to around 600p because closing out a 3% short is at least 100p and maybe being ultra conservatively on that 100p as well.

With the budget possibly increaseing dividend taxes significantly that may move more of UK equity into buybacks, which is just logical in my mind for non pension holders who don't need that type of forced regular income stream. The suspension of the dividend by CBG has arguably changed the type of average holder and that prior demand for dividends may well just not be there anymore to push for dividends.

Summary - it's not just one reason, dividends are not the be all and end all solution to making an equity price attractive. You could argue that having the share price down at 430p makes it a very attractive long term proposition and a way to migrate to a buy back focused investor base.

At the moment my perspective is that 430p is being defended by one particular short, who has (like most of the other shorts) misunderstood the nature of the shares. They built a position and now trying to defend a position at 430p, which may well be a sand castle on the beach where you can only hold the tide back for so long. I'm also still waiting for the moment one of the other prior shorts to go long against the other because the equity of CBG is just as exposed to a short squeeze as shorts flushing people out. At the moment the elastic is stretched.

Just my guesses, errors and finger waving in the wind, see details and conditions in annex D page 453 section 44, throw a dice next.

Dividend popcorn...munch...munch...

10. Contract length. The real elephant in the room. In the Simpsons Bart named him Stompy.

Wonder if I will get up to 20 before the final scheme is out..... drip.... drip....

Ongoing popcorn.... munch...munch....