High Court dismisses appeal against Financial Services Ombudsman decision regarding investor expertise classification.
Legislator-Zusammenfassung
KI-generiertThe High Court refused the appellant's request to set aside the Financial Services Ombudsman's decision. The appellant argued he was not a sophisticated investor and sought to introduce new evidence, while the Ombudsman classified him as an experienced investor based on his long-term client history and account types. The court held that the Ombudsman's finding was reasonable and that the appellant failed to demonstrate a sufficient basis for judicial intervention.
Legislator-Regeste
KI-generierts. 57 CM (2) (B) and s. 57 CM (2) (C) of the Central Bank Act, 1942; The High Court will not interfere with the Ombudsman's decision unless it is unreasonable, and the appellant's failure to prove he was a sophisticated investor does not justify overturning the finding of an experienced investor status.
Schlagwörter
KI-generiertZitierte Gesetzesbestimmungen
KI-generiertZitierte Rechtsprechung
KI-generiertVerwandte Entscheide
KI-generiertVolltext
Neutral Citation Number: [2011] IEHC 285
THE HIGH COURT
2010 320 MCA
IN THE MATTER OF AN APPEAL PURSUANT TO SECTION 57 CL (1),
PART V11B OF THE CENTRAL BANK ACT, 1942,
(AS INSERTED BY SECTION 16 OF THE CENTRAL BANK AND FINANCIAL SERVICES AUTHORITY OF IRELAND ACT, 2004)
AND ORDER 84 C OF THE RULESOF THE SUPERIOR COURTS
BETWEEN
JOHN CAFFREY
APPELLANT
AND
THE FINANCIAL SERVICES OMBUDSMAN
RESPONDENT
AND
ANGUS MCDONNELL, JOHN MAGUIRE, ARTHUR QUINLAN, DAVID HARLOW, RAYMOND DEASY, PETER COSTIGAN, AIDAN
SHEERIN, ANNE BARRETT, MARTIN HARTE, FBD SECURITIES LIMITED, PRACTISING UNDER THE STYLE AND TITLE OF BLOXHAM
NOTICE PARTIES
JUDGMENT of Mr. Justice Hedigan delivered on the 12th day of July, 2011
1. The appellant resides at 1, La Touche Park, Greystones, County Wicklow. The respondent is a statutory officer who deals
independently with complaints from consumers about their individual dealings with all financial services providers.
2. The appellant seeks the following relief:-
(1) An order pursuant to s. 57CM (2)(B) of the Central Bank Act, 1942, as inserted by s. 16 of the Central Bank and
Financial Services Authority of Ireland Act 2004, setting aside the decision of the Financial Services Ombudsman of 22nd,
November 2010.
(2) Further, or in the alternative, and without prejudice to the foregoing, an Order pursuant to section 57 CM (2) (C) of
the Central Bank Act 1942, as inserted by s.16 of the Central Bank and Financial Services Authority of Ireland Act, 2004,
remitting to the Ombudsman for review in accordance with the directions of this honourable Court the decision of 22nd
November, 2010 for the reasons set out in the notice of motion and any other reasons which may be adduced at the
hearing of this action.
(3) Such further or other order as the honourable Court should deem fit.
(4) An order providing for the costs of and incidental to this application.
3.1 In or about March 2005, the appellant became aware from Bloxham’s Equity Research Quarterly Newsletter the ‘Quarterly
Newsletter’, of what was described as the Dresdner Bond. In the ‘Quarterly Newsletter’, under a section entitled ‘Corporate Bonds’,
the Dresdner Bond was listed as having a 6.25% yield with a maturity date of 2031. The credit rating was described as ‘A’. Further,
the ‘Quarterly Newsletter’ stated: “The Dresdner Bond pays 6.25% per annum for the first five years followed by 4 x (10 yr Euribor –
2yr Euribor). All of the Bonds should benefit from rising yields.” After reading the ‘Quarterly Newsletter’, the appellant contacted Daniel
Kiely of Bloxham Stockbrokers. The content of this conversation is in dispute between the appellant and the notice party. The
appellant claims that he was given the impression that Dresdner Bank AG guaranteed the return of the monies invested. The notice
party claims that it explained the nature of the Bond to the appellant, informing him that total loss was possible, but unlikely. The
conversation between the appellant and Daniel Kiely lasted only a few minutes and the appellant avers, in paragraph 6 of his first
affidavit, that at no time was the true nature or essential features of the Bond and the risks inherent thereto explained to him. The
appellant claims that he was not informed that the Bonds were, in fact, notes issued by Saturn Investments Europe plc. and that the
investment was linked to a US Dollar currency bond. Moreover, the appellant claims that he was not advised that there was a swap
agreement in place with Morgan Stanley.
3.2 A contract note issued to the appellant on 15th April, 2005, recording the purchase price of €50,000. The contract note referred
to “Saturn’s Investment Europe plc 6.25% NTS 05/07/31 EUR 1000”. An accompanying letter confirmed the purchase of the Dresdner
Bond and stated that for “administrative reasons, this appears as Saturn’s in stock description line above”. The letter described this
as a “brand name and in no way effects any of the terms of the Bonds that you have bought.” On 5th December, 2008, the appellant
telephoned Daniel Kiely of Bloxham Stockbrokers to enquire how the Bond was performing. On 29th June, 2009, Bloxham Stockbrokers
wrote to the appellant informing him that Morgan Stanley had terminated the Swap Agreement with Saturn, and that the appellant
would only receive €0.03 per €1 originally invested.
3.3 On 15th February, 2010, the appellant submitted a complaint to the Financial Services Ombudsman. The appellant complained that
at no time during his conversation with Daniel Kiely was the true nature of the Bond and the risks inherent thereto explained to him.
On 14th April, 2010, Bloxham submitted its final response to the complaint. On 30th April, 2010, the appellant set out its response to
that letter. On 23rd August, 2010, the appellant received a copy of the response from Bloxham Stockbrokers to questions put to it by
the Financial Services Ombudsman. On 3rd September, 2010, the appellant responded to the response of Bloxham Stockbrokers by
way of letter addressed to the Financial Services Ombudsman. On 6th October, 2010, Bloxham submitted its response thereto.
3.4 On 22nd November, 2010, the appellant received a letter from the Financial Services Ombudsman stating that the investigation
into the complaint had concluded and enclosing a copy of the finding. In its finding, the Ombudsman held, inter alia, as follows:-
“The Complainant had been a client of Bloxham for over twenty years, and was classified as an advisory retail client. His
portfolio is largely made up of shares, and the Complainant operates a CFD account with Bloxham. Upon receipt of
Bloxham’s Quarterly Newsletter, Bloxham states that the Complainant contacted Mr. Daniel Kiely, a broker employed by
Bloxham. The Complainant indicated that he required a long-term source of income from the funds he wished to invest at
a better rate than was available on deposit. The Bond offered a good level of income.
…
Bloxham portrayed the Complainant as ‘. . . an experienced investor who . . . previously invested in equities through
Bloxham and has also operated a contract for difference account with Bloxham.
...
Bloxham say that it told the Complainant that total loss was possible, but unlikely.
The order to purchase the Bond was made by the Complainant over the telephone.
The Complainant was 72 at the time of making the investment and says that because it could not be encashed until 2031,
it was inherently unsuitable. However, it does not appear to be correct to say that the Bond could not be sold until 2031.
…
The Complainant was an experienced investor. The Bond was purchased by the Complainant in the secondary market
‘below par’. In and of itself, this told the Complainant that the value of the investment might fluctuate.
I consider that the investment was sold in good faith by the Provider, inter alia, on the basis that it provided the
Complainant with the potentially high return that he was seeking. I am satisfied that the Provider reasonably considered
that the investment was relatively secure, but also that the Complainant was advised of and knew of the possibility of
fluctuation in its value.
More fundamentally, I do not perceive in this case the likelihood of any causal link between any fault on the part of the
Provider, and the loss that has been sustained by the Complainant. I perceive there to be quite a degree of artificiality
about a number of the submissions advanced on behalf of the Complainant, when analysing in 2010 the circumstances
surrounding the inception of this investment in March 2005.
In the overall circumstances, I do not consider that it is just to fix the Provider with responsibility for the loss that has
been incurred by the Complainant.
The Complaint is not substantiated.”
In these proceedings, the appellant seeks to challenge this finding on the basis, inter alia, that the Ombudsman erred in accepting the
notice party’s evidence regarding the crucial telephone conversation, and in finding that the notice party had not misrepresented the
nature of the investment. The appellant also submits that the Ombudsman attached too much weight to the contention that he had
significant investment experience.
Appellant’s Submissions
4.1 The appellant submits that the Financial Services Ombudsman erred in law and in fact, so that his decision is vitiated by a serious
and significant error by accepting the evidence of the notice party at face value in respect of the information allegedly given to the
appellant at the point of sale i.e. the telephone conversation with Daniel Kiely of Bloxham Stockbrokers. The dispute between the
parties made it imperative that the Ombudsman investigate this conflict. A blanket acceptance of the notice party’s evidence,
submitted by a person not a party to the telephone conversation, was a manifest error that undermines the entirety of the
Ombudsman’s finding.
4.2 The appellant further submits that the decision of the Ombudsman is vitiated by a serious and significant error by reason of the
failure to find that the notice party had misrepresented the nature of the investment to the appellant by describing it as “Dresdner
6.25%, 2031 bond, with a credit rating of A”, and by failing to inform the appellant that the instrument was, in fact, issued by Saturn
Investment Europe plc. In addition, the notice party did not inform the appellant that his investment was subject to a complex swap
agreement susceptible to termination by Morgan Stanley. There was a complete deficit of disclosure on behalf of the notice party as
regards the negative features of the Dresdner Bond. The Ombudsman failed to appreciate the significance of the non-disclosure of
this information and failed to attach the appropriate weight thereto.
4.3 The Ombudsman erred by attaching too much weight to Bloxham’s contention that the appellant had significant investment
experience. The Ombudsman further erred by placing undue emphasis on the fact that the appellant had a ‘Contracts for Difference’
(“CFD”) account with Bloxham. The appellant was not a sophisticated investor, and had only one CFD account, on the advice of
Bloxham, in respect of a company with which he had been a shareholder; the vast majority of his investments were in managed funds.
4.4 The appellant submits that the conflicting evidence surrounding the information allegedly given to the appellant at the point of
sale made it imperative that the Ombudsman investigate the conflict of detail by way of oral hearing rather than simply relying on
written submissions. In J&E Davy T/A Davy v Financial Services Ombudsman [2010] IESC 30, the issue of when the Ombudsman
should hold an oral hearing was addressed by Finnegan J. in the Supreme Court as follows:-
“Assuming, as conceded by the Ombudsman, that there is a power to direct an oral hearing, then it would be appropriate
to consider directing an oral hearing in the interests of fairness where there is a conflict of material fact. There is here
such conflict in relation to the oral evidence given by Davy to the Credit Union and also in relation to the expert evidence
as to the nature of the bonds . . .
What I have to decide . . . is whether the dispute between the parties as to (a) the reliability of the evidence before the
Appeals Officer was the Applicant’s and Mr. Higgins, on the one hand, and (b) on the accuracy of the departmental
records on the other, made it imperative that the witness be examined (and if necessary cross-examined under oath
before the Appeals Officer).
I have come to the conclusion that without an oral hearing it would be extremely difficult if not impossible to arrive at a
true judgment of the issues which arose in this case.”
The Ombudsman accepted, without investigation, Bloxham’s version of the telephone conversation that took place between the
appellant and Daniel Kiely of Bloxham’s on the 14th April, 2005. In paragraph 3 of his second affidavit, the appellant avers that the
claim by the notice party that he received a detailed description during the telephone conversation of the Dresdner Bond and the
level of risk attaching thereto is false. Bloxham’s response to the schedule of questions of August 2010, contrasts radically with the
appellant’s recollection of the telephone conversation with Daniel Kiely. There is no requirement on the appellant to request an oral
hearing of his own accord. The Ombudsman, in order to fulfil its statutory obligations, ought to have acknowledged that this
unequivocal dispute of fact required an oral hearing in order to be appropriately resolved.
4.5 In the notice party’s final response of 14th April, 2010, it states as follows:
“It was explained to Mr. Caffrey prior to his decision to invest, that the Dresdner Bond is a Dollar denominated bond.
Morgan Stanley set up Saturn’s to purchase the Dollar Dresdner Bond. Saturn’s then entered into an agreement for the
swapping of the Dollar income from the Dresdner Bond to a Euro amount which resulted in the fixed payment to Mr.
Caffrey for the first five years of 6.25% and the floating rate thereafter in accordance with the terms of the investment.
The effect of this swap agreement was to remove currency risk for Mr. Caffrey in respect of the annual income and the
planned repayment on maturity.
Further, Mr. Caffrey was told by Bloxham that there was a risk that he might lose some or all of his investment. Indeed, at
the time of Mr Caffrey’s purchase of the Dresdner/Saturn Bond, it was, in fact, trading below par, clearly indicating that
the value of the capital investment could decrease during the lifetime of the Bond. However, it was, of course, also
explained to him that in Bloxham’s view, at that time, having regard to the underlining collateral, namely Dresdner, that
total loss was unlikely, but nevertheless still possible.”
With regard to the phone call between the appellant and Mr Kiely, Bloxham’s reply states:
“Mr. Caffrey contacted Mr. Kiely and discussed with him verbally a number of corporate bonds, including the Bond and
decided to invest in the Bond. Specifically, he would have discussed the fundamentals of the Dresdner Bank and the
rating attached to the Bank at that time. That was the usual practice; the order to purchase the Bond was made by Mr.
Caffrey by telephone. Bloxham duly executed Mr. Caffrey’s instruction to purchase the Bond and a Contract Note issued
to Mr. Caffrey.”
The appellant complains that this information was accepted by the Ombudsman and points out that the information came from a
person who was not even party to the telephone conversation. The appellant submits that the Ombudsman should have sought a
recording of the telephone conversation or he should have sought evidence directly from Daniel Kiely. Instead, the Ombudsman
accepted at face value a third party account of the telephone conversation. It is further submitted that this is an infirmity in the
reasoning of the Ombudsman which can only be cured by setting aside the decision of 22nd November, 2010.
4.6 In the affidavit of William Prasifka, the Ombudsman avers that the appellant has no legal entitlement to introduce new evidence as
to the appellant’s investment history. The appellant submits that the investment history formed part of the material before the
Ombudsman. Bloxham’s submission of August 2010 depicts that appellant as a sophisticated investor. It is submitted that the
Ombudsman drew an erroneous inference from the assertions that the appellant was a sophisticated investor. It is submitted that, for
all the above mentioned reasons, the finding of the Ombudsman of 22nd November, 2010, should be set aside.
Respondent’s Submissions
5.1 The appellant herein seeks to challenge the finding of 22nd November, 2010, in which the Ombudsman decided not to uphold his
complaint against the notice party. The main procedural complaint is to the effect that the Ombudsman erred in failing to require
Bloxham to produce a recording of a telephone conversation, or by not requiring them to give evidence on oath of the contents of the
call. The Ombudsman submits that the appellant has failed to establish that the finding was vitiated by serious error. While a
statutory appeal is not a judicial review, it nevertheless bears many of the features of a judicial review. In particular, it is clear that
there can be an error within jurisdiction insofar as there may be an error that falls short of being a “serious and significant error”.
5.2 Section 57 BB of the Central Bank and Financial Services Ombudsman Act 2004, provides that the Ombudsman’s purpose is to
enable complaints to be dealt with in an informal and expeditious manner. The Oireachtas has provided for an informal, expeditious and
independent mechanism for the resolution of complaints. The function performed by the Ombudsman is different to the function
traditionally performed by the courts as he is specially enjoined not to have regard to technicality or legal form. The Ombudsman also
resolves disputes using criteria that would not normally be used by the courts. It is submitted that this Court should not review the
finding made by the Ombudsman as though it were reviewing the procedures adopted by an inferior court and should not apply the
same standards of procedure as it would to a court.
5.3 The appellant submitted a detailed and well-argued compliant. However, Bloxham put in an equally detailed and well-argued
response in which it addressed each of the points made. Thus, this was not a case where the financial service provider was unable to
answer the criticisms made of it. The Ombudsman had to come down on one side or the other, and having considered all the
submissions of the appellant and the notice party, he came down on the side of the notice party. That was a matter that was within
the jurisdiction of the Ombudsman to do. During the investigation, the appellant declined the opportunity to mediate the complaint,
declined the offer from Bloxham to join him to its case in the English courts against Morgan Stanley and declined a without prejudice
offer from Bloxham.
5.4 In its submissions to the Ombudsman, Bloxham stated that Mr. Caffrey is an experienced investor who previously invested in
equities through Bloxham and has also operated CFD accounts with Bloxham. This is an accurate statement of the position and the
appellant has not adduced anything to suggest that it is incorrect. The appellant was an experienced investor who had been a client
of Bloxham for over twenty years. A CFD is not an instrument that one would expect an ordinary inexperienced investor to invest in.
Anyone who has invested in a CFD must know, or must be deemed to know, that whilst the rewards of investing can be great,
equally, so can the losses. I n the present case, he bought a bond on the open market at below par. Indeed, Bloxham submitted a
form signed by the appellant in what appears to be mid-2006 for a CFD transaction in which :
(i) It confirms that he understands the nature and risks of margined (geared) transactions, and
(ii) it confirms that he has experience of trading margined (or geared) products e.g. spot, FX futures, options, warrants,
CFDs or spread betting.
5.5 The appellant learnt about the bond from a quarterly review newsletter that clearly stated:-
“The publication is solely for information purposes and cannot be construed as a representation by Bloxham. The views in
this report are expressions of opinion and are given in good faith, but are not guaranteed. These are subject to change
without notice.”
Mr. Kiely only met with Mr. Caffrey once, in July 2009, following the termination of the agreement by Morgan Stanley. It was Mr
Caffrey’s usual practice to give instructions in relation to his account by telephone. Mr. Caffrey discussed with Bloxham the possibility
of selling the bond in 2008 (when it traded at approximately 83), but decided that, given the attractive coupon attached to the bond
and the perceived likelihood of the Bond being called at its first call date, that he would retain the bond. In all the circumstances,
based on the materials that were submitted to him, the Ombudsman was entitled to conclude that this investment was sold in good
faith by the notice party and that the complainant was advised of and knew of the possibility of fluctuation in its value.
5.6 The appellant complains that the Ombudsman erred in failing to require the notice party to produce a recording of the telephone
conversation in which the impugned bond was sold. In his letter to the Ombudsman dated 3rd September, 2010, Mr Moynihan, acting
on behalf of the appellant, stated that:-
“My offer to donate €1,000 to a charity of the FSO’s choice if Bloxham could produce a tape recording or any other
evidence substantiating their claim still stands.” (Page 462 of the hearing booklet)
In its letter to the Ombudsman of 6th October, 2010 the notice party indicated that it did not retain a tape recording from the time in
question:
“It is suggested that ‘all 2005 tapes were destroyed as soon as [Bloxham] realised they had a problem with the Saturn
investment’. This statement is untrue. Bloxham is required to retain recordings of telephone calls for a period of six months
only. In practice, it may have tapes for a longer period but has not had tapes from 2005 since 2007. ,We believe that Mr
Moynihan is so aware, having regard to knowledge gleaned in other cases with which he is involved, wherein Bloxham has
confirmed that it does not have recordings from what is now over five years ago.” (Page 653 of the hearing booklet)
There is nothing to suggest that the notice party was not being truthful when it stated this.
5.7 The respondent submits that the Ombudsman acted within jurisdiction in making his finding without holding an oral hearing. In
paragraph 45 of his affidavit, the Ombudsman addressed the issue and explained that:
“I say that I did not believe that an oral hearing was necessary for me in order to make my Finding and I exercised my
discretion not to hold one. At no stage during the investigation did the appellant, or indeed the notice party, request an
oral hearing or suggest that one was necessary. Whilst a formal request is not a prerequisite to the holding of an oral
hearing, I say that the fact that one was never requested or suggested supports the manner in which I exercised my
discretion on the issue.”
It is submitted that the appellant has not pointed to anything that would lead one to the conclusion that the FSO made a manifest
error in not directing an oral hearing in the present case. One might question what account persons would have been able to give of a
telephone conversation that had happened some five years previously. For example, at page 320 of the hearing booklets, the
appellant states that, “I have no memory of any reference at that stage to a US Dollar bond or currency hedges.”
5.8 The appellant has referred to various matters in his affidavit, such as particular details of his investment history, which were not
before the Ombudsman. Self-evidently, the Ombudsman could only make a decision based on the evidence that had been forwarded
to him. No leave has been sought by the appellant to adduce any fresh evidence and it is submitted that the Ombudsman’s finding
can only be reviewed by the appellant on the basis of the evidence that was submitted to the Ombudsman. In Ulster Bank v. Financial
Services Ombudsman & Ors [2006] IEHC 323, Finnegan P. (as he then was) stated:
“Having regard to my decision on the standard of review, it is appropriate that the appeal should proceed on the basis of
the materials which were before the Financial Services Ombudsman only. The Court, however, has a discretion on
application to permit further evidence to be introduced where it is satisfied that this is necessary or appropriate in the
interests of justice.”
The test postulated by Finnegan P. requires this Court to take the adjudicative process as a whole to see if the decision made was
vitiated by a serious and significant error. It is submitted that when one considers the present case as a whole, there is no sufficient
basis made out for this Court to intervene in respect of the decision made. For all of the above mentioned reasons, it is respectfully
submitted that the appellant’s appeal should stand refused.
Decision of the Court
6.1 In March 2005, the appellant became aware from Bloxham’s ‘Quarterly Newsletter’ of the Dresdner Bond. The newsletter stated,
“The Dresdner Bond pays 6.25% per annum for the first five years followed by 4 x (10 yr Euriborn, - 2yr Euribor). All f the Bonds
should benefit from rising yields”. After reading the newsletter, the appellant contacted Daniel Kiely of Bloxham Stockbrokers. The
appellant claims that he was not informed that the Bonds were, in fact, notes issued by Saturn Investments Europe plc. and that
there was a swap agreement in place with Morgan Stanley. The notice party claims that it explained the nature of the bond and that
total loss was possible, but unlikely. A contract note issued to the appellant in April, 2005, which referred to “Saturn’s Investment
Europe plc 6.25% NTS 05/07/31 EUR 1000”. An accompanying letter confirmed the purchase of the Dresdner Bond and stated that for
“administrative reasons, this appears as Saturn’s in stock description line above”. In December, 2008, the appellant telephoned Daniel
Kiely to enquire how the Bond was performing. In June, 2009, Bloxham Stockbrokers wrote to the appellant, informing him that Morgan
Stanley had terminated the Swap Agreement with Saturn, and that the appellant would only receive €0.03 per €1 originally invested.
In February, 2010, the appellant complained to the Financial Services Ombudsman that during his conversation with Daniel Kiely, the
true nature of the Bond was not explained to him. Bloxham denied this in its response. On 22nd November, 2010, the Ombudsman
issued its finding holding that the complaint was not substantiated.
6.2 To succeed in his appeal, the appellant must satisfy the test laid down in Ulster Bank v. Financial Services Ombudsman & Ors
[2006] IEHC 323 where Finnegan P. stated at 9:-
“… the plaintiff must establish as a matter of probability that, taking the adjudicative process as a whole, the decision
reached was vitiated by a serious and significant error or a series of such errors.”
The applicant submits that the Financial Services Ombudsman’s decision is vitiated by a serious and significant error because the
dispute between the parties made it imperative that the Ombudsman investigate the conflict by way of oral hearing, which he failed
to do.
6.3 It is clear that Ombudsman enjoys a broad discretion as to whether or not to hold an oral hearing. In Davy v. Financial Services
Ombudsman [2010] IESC 30, reference was made to the judgment of Galvin v. Chief Appeals Officer [1997] 3 I.R. 240, where Costello
P. said:
“There are no hard and fast rules to the guide appeals officer, or on an application for judicial review, this Court, as to
when the dictates of fairness require the holding of an oral hearing. The case, like others, must be decided on the
circumstances pertaining, the nature of the inquiry being undertaken by the decision-maker, the rules under which the
decision-maker is acting and the subject matter with which he is dealing.”
In Davy, the Court had to decide whether the dispute between the parties made it imperative that an oral hearing be held. In that
case, the court concluded that a hearing was necessary.
6.4 In paragraph 45 of his affidavit, the Ombudsman addressed the issue of an oral hearing and explained that:
“I say that I did not believe that an oral hearing was necessary for me in order to make my Finding, and I exercised my
discretion not to hold one. At no stage during the investigation did the appellant, or indeed the notice party, request an
oral hearing or suggest that one was necessary. Whilst a formal request is not a prerequisite to the holding of an oral
hearing, I say that the fact that one was never requested or suggested supports the manner in which I exercised my
discretion on the issue.”
The Ombudsman exercised his discretion not to hold an oral hearing. It is doubtful that the parties would have been in a position to
give an accurate and detailed description as to the contents of a short telephone conversation that occurred five years previously.
This is borne out by page three of the appellant’s responding submission of 30th April, 2010, where he states:-
“I have no memory of any reference at that stage to ‘a US Dollar bond’ or ‘currency hedges.’
In the case of Molloy v. Financial Services Ombudsman (Unreported, High Court 15th April, 2011), a respondent sought an oral
hearing five years after the events complained of. McMenamin J held as follows at 13:-
“It is necessary to bear in mind that what was before the FSO were matters which had taken place five years previously
in 2005. Thus, other than looking at the documents, it is now unclear what effect an oral hearing would have had other
than to demonstrate that Ms. Finn had no recollection of what happened and/or that the documents at least indicated
that Mr Cantwell had drawn the applicant’s attention to some parts of Section C. An inference from all this that an oral
hearing would not have progressed matters further was not unreasonable and was within the FSO’s statutory remit. It is
not reasonably established, even taking into account the case at its height, and accepting that the appellant could have
shown that Bank officials had imperfect recollections, even different recollections, that an oral hearing would have
affected the outcome.”
It seems to me that in this case, the fact that no oral hearing was requested is a factor that should be weighed in the balance. I am
satisfied that it was reasonable for the Ombudsman to determine that an oral hearing was unnecessary. This was a decision made
within jurisdiction.
6.5 An issue has been raised in this case as to whether the Ombudsman should have made an order requiring the notice party to
produce a recording of the disputed telephone conversation. The appellant’s representative, Mr. Moynihan, wrote to the Ombudsman
on the 3rd September, 2010, stating that:-
“My offer to donate €1,000 to a charity of the FSO’s choice if Bloxham could produce a tape recording or any other
evidence substantiating their claim still stands.” (Page 462 of the hearing booklet).
The notice party wrote to the Ombudsman on the 6th October, 2010, stating that:-
“Bloxham … has not had tapes from 2005 since 2007. We believe that Mr Moynihan is so aware having regard to
knowledge gleaned in other cases with which he is involved . . .”
It seems to me that it was clear to all that no such tape recording existed, and in these circumstances, it would have been futile for
the Ombudsman to make a production order in this case.
6.6 The appellant submits that Bloxhams wrongly depicted him as a sophisticated investor. In his affidavit, the appellant seeks to
contradict this portrayal by giving a detailed account of his investment history. The respondent argues that no leave has been sought
by the appellant to adduce any fresh evidence, and it is submitted that the Ombudsman’s finding can only be reviewed by the
appellant on the basis of the evidence that was submitted to the Ombudsman. At the heart of this issue is the question of what level
of expertise was attributed to the appellant. In his finding, the Ombudsman stated that:-
“The Complainant had been a client of Bloxham for over twenty years and was classified as an advisory retail client. His
portfolio is largely made up of shares, and the Complainant operates a CFD account with Bloxham . . .
...
Bloxham portrayed the Complainant as ‘… an experienced investor who . . . previously invested in equities through Bloxham
and has also operated a contract for difference account with Bloxham.
...
The Complainant was an experienced investor. The Bond was purchased by the Complainant in the secondary market
‘below par’. In and of itself, this told the Complainant that the value of the investment might fluctuate.”
To describe the complainant as a sophisticated investor would be to attribute a high level of expertise in financial instruments to the
appellant. The Ombudsman never described the appellant as being a “sophisticated investor” in his finding. What the Ombudsman, in
fact, said, was that the appellant was an “experienced investor”- this is a very different thing. It was reasonable for the Ombudsman
to conclude that, based on the length of time the appellant was a client of Bloxham and the type of accounts that he held with them,
that he was an experienced investor and this was a factor which the Ombudsman was entitled to weigh in the balance in making his
decision. It seems to me that whether or not the appellant was entitled to introduce new evidence to show he was not a
sophisticated investor is largely irrelevant, as he was not found to be a sophisticated investor by the Ombudsman. I am not satisfied
that there is a sufficient basis for the Court to intervene in the decision made by the Ombudsman. For all the above mentioned
reasons, I must refuse the relief sought herein.