Compliance & Client Protection

But where were all of these new houses going to go? This was the catalyst for the biggest shake-up and revision of Britain’s planning laws in recent history. As a result of this, more investors began speculating on Greenbelt land knowing that if the government were to meet its targets, investors would be in a very strong position as they would have title to this much-needed land. With this in mind, Tullett Brown was founded to offer land without planning permission (including Greenbelt) as a speculative investment. All our material had the following disclaimer (SEE HERE).

So when the Insolvency Service and media made claims that our clients did not know the land was Greenbelt this was untrue. Any self-respecting investigator or journalist only had to pick up one of our brochures to see that this was not the case. A glance at page 19 dispels that myth. This couldn’t be any clearer, in that we openly traded in Greenbelt land.

If you look at the page from the brochure below, you will see that the page is headed

The double-spread centre pages of our brochure discuss land without planning and the potential for re-zoning. It is made transparent that Tullett Brown was originally set up for this very purpose. We offered Greenbelt land as a speculative investment to our clients.

Nowhere in the brochure (or the training manual or sales scripts) does it say that planning is guaranteed or even probable. By way of example, in the FAQ’s section (“DN1” pages ) under the heading “ Will Planning Consent be Granted?” it states the following:

“It is not possible to give any guarantee as to when or whether you will receive planning consent. We always ensure that the sites and plots that we source are in areas where there is a demand for new housing”

Our brochures and sales material make this very clear. On the same page under the heading “ Disclaimer and Risk Warning ” , it states:

“……….we do not guarantee that planning consent will be granted……”

The interpretation placed on the selective parts of the brochures highlighted in the Insolvency Service evidence is misleading and taken out of context. When read as a whole, it is plain that prospective customers were properly informed before deciding to proceed with the purchase.

The argument put forward by the media appears quite damning when reading a mainstream newspaper article about three Nigerian brothers breaking the law but utterly stupid when placed in the correct context. To drive home the point again, if you call your local planning office and ask them to GUARANTEE IN WRITING that a particular Greenbelt site will NEVER BE DEVELOPED, they won’t do it.

• Brochures design & printing

Now everything has been placed in the correct context, it’s plain to see that our business model was based on the findings of the Barker Review. Greenbelt land is constantly re-zoned for development. We offered freehold Greenbelt land to our clients for speculative investment. Our client fully understood the investment including the fact that the land was Greenbelt. They signed contracts and land purchase agreements.

The newspapers won’t tell you any of this. If this was our business model and our clients were fully aware and signed contracts and received full title deeds, then where is the scam?

Contrary to the government and media reports, there is a secondary market for carbon credits as companies and individuals all over the world are voluntarily offsetting their carbon emissions. To achieve this they are purchasing carbon credits. Tullett Brown was in the process of building out an infrastructure to create a viable secondary market for our clients and the wider market. See Carvier here . As I mentioned earlier, transparency is the key. Our clients were aware that the carbon credits were illiquid and the market would need to develop.

No. Our clients were fully aware of the nature of the product and the risks that the investment posed. Our clients were also aware that the investments in carbon credits were illiquid and would require further development in the marketplace to resell. Had we been around today, our infrastructure would have been built out and I am in no doubt that our clients would have made a profit.

We made great efforts to explain this to our investors as well as including a risk-warning page.

On the very first page of our brochure, it clearly states that VER credits are illiquid. Please take the time to read the warning page. Also, note that this was not hidden on an obscure back page with tiny barely legible small print. It is clearly shown on the VERY FIRST page so that it would be unmissable and easily seen.

Summing up the carbon argument, when placed in its correct context it’s easy to see what we were trying to achieve. In 2012, carbon credits were a new and exciting market. Every client signed (either manually or electronically) our Terms Of Business before engaging in any sales activity. Our clients were fully aware of the nature of the product and the associated risks. This was made absolutely clear. Contracts were signed and we delivered the full title to every single client.