Open Letter to the PFS Board

Read the response to the letter from Don MacIntyre, Interim CEO of the Personal Finance Society

27th October 2023

To: The Board of the Personal Finance Society

I am writing the following as an open letter, and have asked for members who share my concerns to add their names as signatories.

I/we request that the PFS board take the following urgent steps:

  1. Seek an immediate transfer of all PFS funds to an account in the sole name and control of PFS.
  2. Provide an undertaking not to allow PFS funds to be ‘re-charged’, or ‘re-addressed’, or invoices for ‘past adjustments’ to be accepted, on the basis that these could well be seen to be fraudulent.
  3. If CII are unable to transfer funds immediately, as they should if they are acting as bona fide and competent trustees, to initiate proceedings for recovery of the funds via the courts.
  4. Make immediate amendments to the articles of association to clarify the position of PFS funds in the event of wind-up, and to protect the body against further threats from CII.

I first wrote to the board with my concerns on 1st February 2023, and explained that I intended to publish the letter I wrote a week later if a substantive response had not been received.

I have, to date, not received a response. I chose not to publish the letter at the request of people close to the board, on the promise that a substantive response would arrive. It did not

I attended the AGM on 19th September 2023 and was assured by the Interim Chair, Andy Briscoe, that the letter would be re-circulated and a response would be given. To date, that has still not happened.

At the AGM, a series of unsatisfactory answers were provided to members, including myself, who asked serious questions about their concerns.

As of 26th October, it appears that CII Interim CEO Alan Vallance will leave for another professional body – one that apparently has its own challenges and controversies.

I understand that the substantive changes since the letter published in full below was written are as follows:

  • The CII have “flooded the board”, appointing seven institute directors with little justification and in spite of previous assurances that they would not take this course of action.
  • Following the resignation of two long-serving member directors, two new member directors have been appointed and ratified by member vote at the AGM. There is only one member director with a working understanding of the situation between the bodies over the past two years.
  • This brings the balance of the board to 7/3 with a single lay director, with the chair of the board appointed by the CII.
  • PFS “took control” of the £10M of member funds. This leaves around £20M still outstanding, and as far as I can tell, entirely unaccounted for by either CII or PFS.

The last point is the crux of the scandal:

£10M of funds that are constitutionally required to be used for the exclusive benefit of PFS members are missing, and despite asking for the better part of a year, nobody can tell me where they are.

Full body of original letter:

I am writing as a member of the society for over a decade. For much of that time I have volunteered, both with the Insurance Institute of Leicester, a CII local institute, and the PFS directly via its Financial Planning Panel. I stepped down from the panel this month as a result of the behaviour of the CII in respect of PFS member director.

Along with many other members that I have spoken to, I am deeply concerned about the risks Personal Finance Society members face from the CII.

The last month has shown me that the CII have no intention to be held to account for their shocking behaviour, and that their executive and board are prepared to:

  • Make repeated statements on record that are verifiably untrue, and refuse to retract them.
  • Defame volunteer member-directors with unsubstantiated accusations, risking impairment of their professional reputations and careers, and depriving them of natural justice.
  • Confirm publicly that they will seek to “readdress historic cost sharing” with PFS – an action that I believe, and that legal advice I have received also suggests, amounts to corporate fraud.

This position seems even more clear following the email sent by CII’s CEO Alan Vallance on 27th January.

CII executives have, on record, stated that PFS is a wholly owned subsidiary. I don’t believe this is structurally possible, as there is no share capital for CII to own.

PFS is a member organisation limited by guarantee. Whilst CII has special status as a PFS member by virtue of the articles of association, it cannot ‘own’ the organisation, because there is nothing to own.

I believe the current mess stems entirely from this fundamental misunderstanding.

My understanding is that the CII is close to running out of liquid funds as a result of operational overspend for at least the last five years.

In contrast, the PFS has made operational surpluses year on year, whilst paying (as I understand it) above market rates for all services provided by the CII.

As a result, the PFS has around £20M in member reserves. I understand that the PFS has “sight” of £10M of this, but the funds are held in an account requiring joint signatories from PFS and CII. The other £10M is apparently held on trust for PFS members by CII. My primary concern is that these funds may have already been spent, and obsfucated by CII.

Furthermore, I understand from news reporting ( that the PFS board received advice that there was significant threat of insolvency at CII.

Under Companies Act 2006, all directors, including those appointed by CII, owe an exclusive duty to PFS, and this duty is of a fiduciary nature.

The duty is to promote the success of the company – for the avoidance of doubt, that means promoting the success of PFS, not CII.

To act in accordance with this duty, I believe the following needs to happen immediately:
1: The PFS board must seek an immediate transfer of PFS funds to an account in the sole name and control of PFS.
2: an undertaking by PFS’s board not to allow PFS funds to be ‘re-charged’, or ‘re-addressed’, or invoices for ‘past adjustments’ to be accepted, on the basis that these could well be seen to be fraudulent.
3:If CII are unable to transfer funds immediately, as they should if they are acting as bona fide and competent trustees, to initiate proceedings for recovery of the funds via the courts.

Under the 2006 Act, members have the right to bring a derivative action on behalf of the company, if the directors are in breach of their duty.

I am led to understand that third-party legal funders who have heard the substance of the situation believe there is a case to answer, and therefore funding available.

If the board refuse to take reasonable steps to protect the interests of PFS given what is known about CII then I believe they leave themselves open, in a personal capacity, to such an action.


Alasdair Walker FPFS

Additional signatories: 268

Alan Mellor
Aigul Tuck
Andrea Petrie
Justin Tuck
Luke James
Heather Bendall
Anna Sofat
Keely Woods
Scott Atkinson
Nick Rogers
Michael I Holden
Robert caplan
Gillian Goosen
George Cooksley
Ben Fowler
Steven Rowe
Jon-Paul Rougeolle
Amanda Mayes
James de Lisle Wells
Andrew Walker
Michael Burgess Rowson
Chris Longman
Laura Blyth
Joseph Gordon
Timothy Framp
Peter Bolton
Ani Tanna
George Critchley
David Stone
Scott Robinson
Amy E Crulley
Robert Bray
Adam Hildred
Jaskarn Johal
Hayley Jarvis
Phil McGovern
Matthew Bowen
Jon-Paul Ellis
Emily Pool
Matthew Duncan
Sharon Sutton
Paul McCoubrey
Michael Rendell
Mike Edie
Peter wallin
Julie Calvert
Andrew Hillier
George Agan
Jason Barefoot
Scott Gallacher
Stephanie Potter
Jonathan Knight
Andrew Grant Johnston
Mike Norman
Tom parkinson
Paolo Joseph Rosolek
Warren Shute
Louise Sagar
Rebecca Andrew
Samuel Harley
Jonathan Holdaway
Kerry Houghton
Paul Anthony Carl Melvin
Philip Gillett
David John Ingram
Carol Nobes
Ross Cramb
Jo Little
Tobias Evans
Eliot Gibson
Harjeet Heer
Tamsin Caine
Gordon Wilson
James Granville Smith
David Crozier
Simon Rees
Jiten Varsani
Daniel morson
Carly Dunningham
Jonathan Willis
Daniel Francis
Howard Morris
Bhavika Patel
Ed Dymott
Grant Hughes
Paul Jones
Matthew Walne
Eileen Murphy
John George Sangster
Nathan Fryer
Grant Connell
Matthew Pitcher
Kaz Downing
Anne Rose-Smith
Zoe Dagless
Kevin Chalk
Mel Latham
Michelle Lambell
Ilan Eardley
Mark Raybould
Louise Worsfold
Matthew Lammas
Paul Cheriton Wreford
Julian Gilbert
Paul Cleworth
Hiren Panchal
Simon Glazier
Ed Green
Timothy John Walsham
Clive Smith
Dom Spalding
John Surgenor
Ashleigh Harrison
Richard Moodey
Steven McBurnie
Christopher John Bowmer
Samuel Bryans
Steven Williams
Anthony Villis
Kimberley Sare
Patryk Dyjecinski
Tim Page
Ben Alves
Anthony Phillips
Martin Ruskin
Bob Walne
Robert Todd Jeffries
Bryan J Hollingsworth
Helen Thomas
Dawn Jones
Ruth Sturkey
Nicholas Heslin Lawson
Richard Wilson
Adrian Quick
Jamie ellis
Lisa Shepherd
Simon Albright
Colin Devereux
Tamlin Russell
Neil Parker
Dennis Stuart Osman
Christopher Parkin
Robbie Campbell
Mrs Shireen Fernie
Matthew Lynch
Mark Hicks
Katherine Brown
Christopher Pond
Samuel Colby Butcher
Gary Wright
Bradley Muncie
Eugenie Cameron
Robert Jackson
Nick Parkes
Suzanna Beck
Daniel Jones
Jon Stevens
Jon Elkins
Anne Morgan
Samantha Secomb
Keith Boyes
Jeremy Brett
David Craik
Susan Hill
Thomas Orchard
Ian Penberthy
Edward Brian Edgar Gibson
Huw Jones
Nick Evans
Christian markwick
Tom Lloyd-Read
Victor Sacks
Bill Muammar
John William Marshall
Gregory Deer
Harish Patel
Colin Pritchard
James Curry
Clemence Chatelin
Ian Robert Carlton
Anne Ratnam
Kat Mock
Charlotte Wood
Matthew Odell
Rebecca Jones
Darren Cooke
Grahame Hopper
Andy Boyt
Paul John Fox
Peter B. Matthew
Kevin Neil
Keith Butten
Matthew John Brooks
Steven Hennessy
Dean Poulson
Jamie Bogle
Kevin Hamblin
Phil Billingham
Ed Davies
Lewis Easter
Graham Foster
Alex Pearce
Mark Richardson
Benjamin Fabi
Fotis Joannou
Dean McFarlane
Bhavisha Soni
Anick Sharma
Rob Mansfield
Dan Brent
Shannon Currie
Mr Geoff White
Jason Mountjoy
Jeremy Askew
Scott Snedden
William Annison
Richard Fyfe
Owen Williams
Andrew Hart
Matthew Vosper
Matthew Aitchison
Svenja Keller
Tim Blowers
Simon Drake FPFS FCSI
Geoff Wright
Peter Best
Conor O’Sullivan
Martyn Bulman
Tim Morris
Katharine Ross
Michelle Boakes
David Patrickson
Kris Amliwala
Andrew Neligan
Alan Bird
Chris Broome
Joel Adams
Maxine Parris
Dave Lewis
Elliot Guthrie
Felix Milton
Kraig Baldwin
Paresh Valji
Richard Pickering
David McElhoney
Tracy Crookes
Martin O’Callaghan
Julie Flynn
Adam Downes
Ian Robert Porter
Catherine Esland
Derek Baillie
Jeremy Squibb
Simon Booth
Daniel Gornall
Garry Hale
Sean Banks
Andrew Reynolds
Jonathan brown
Ben Hewitt
Kate Evans
Frederick Winter
James Mousley
James Wallis
Christopher White
James Beck
Fabian Taylor