Scottish Widows Complaint: PO-14071

I sent an application form with covering letter by DHL Express Letter, at a cost of about £50. But with the strength of my case, I had every reason to believe that this would lead surely to a successful outcome.

This is the only paper communication with TPO; all other communication was by email. The popup image is of the covering letter only, which contains more useful information than I could supply on the four-page form.

TPO requires documentation (including at least a Final Response) in order to accept the application. I provided links to the full set of documentation on my website, which I hoped they would find a more practical means of supplying this than a sack of paper through the post.

the following day, I sent an email to TPAS advising them of my application to TPO. I also queried how Scottish Widows should best be approached with the questions that I had prepared. They suggested that I put these to Scottish Widows myself before TPO started to investigate, and closed my TPAS application as I had approached TPO.

Having found that my application had been delivered, I sent a follow up email to TPO. I also included the links to my website documentation that I had supplied on my paper covering letter (this time more conveniently as hyperlinks).

On this day, I also sent the list of questions to Scottish Widows; I notified TPO of this in my email, and included a link to this document.

My website is the sole repository of information on this case, and links to it are the only means by which I provided the documentation needed to investigate it. I was relieved to receive nothing to say that they required it in another form, as paper communications between the UK and Mexico are hardly efficient. And my website enables considerably more efficient investigation of my case than would reams of paper.

The next day, I received an acknowledgement, stating that they had requested my papers from TPAS. But the wording made me rather concerned that they might not accept my application (though I clearly fulfil their stated criteria).

A few days later, I received another acknowledgement from Carl Monk (the Assistant Adjudicator who had replied to an enquiry I made a few weeks earlier). He stated that he would contact me again as soon as they are in a position to progress matters.

Having waited for over a month without response from Scottish Widows to my list of questions, I sent an email to TPO to ask whether they would like me to follow it up. I included a link to the part of my website that deals with my sending of these questions.

The next day, I received a reply from Carl Monk suggesting that I wait another month. He also told me that my application was earmarked for an adjudicator, but it may be a few weeks before I hear from them.

Subsequent correspondence (see 15 September 2017) confirmed that my case was assigned to Barry Berkengoff in October 2016. The very early assignment (very shortly after my application was accepted), followed by then having to wait for an unspecified reason for an unspecified period is surely irregular. From what I have heard, the normal course of events would be a possibly lengthy wait for an adjudicator to become available, but for the adjudicator to communicate from then onwards.

It seems clear that TPO must have accessed my website, otherwise they would not have been able to view the documents they require before they will accept a case. And no problem was reported with the link in my above email.

Sent an email to TPO to report the telephone calls received from Scottish Widows, with a link to details including a recording of the calls, and soliciting any advice they might offer.

Again, no problem accessing my website via this email link was reported.

Received a reply to my email of 10 November, suggesting that I email Scottish Widows and ask for a written reply.

It seemed strange that he took nearly two weeks to respond to this simple matter that called for an early response, given the prompt replies at other times (and there was no out-of-office notification). Was this to wait until the TPO deal with Scottish Widows was done?

I replied to the above stating that I had done as suggested, and giving a link to the email I sent Scottish Widows.

This link was the first one reported to be inaccessible (see below).

Received advice of the TPO secure email service.

This does not denote the recent introduction of email encryption by TPO (in fact it was introduced in March 2015).

This is the content of an encrypted email I received the same day, advising me that they could not access the link in my email of 23 November.

I initially assumed that this was a result of the recent introduction of security measures including email encryption, as they reported no problems with previous links to my website, and must have been able to access the documentation needed to evaluate my case. But it now seems that access to websites had always been blocked, and so the Assistant Adjudicator could not have accessed links in any of my emails.

This is the content of a secure email I sent the next day. I tried to ascertain what problems they had accessing my website; in particular whether this was a result of changes to the email service (secure or ordinary), or denial of access to my domain.

This is a PDF document that I sent as both a link and an attachment to my secure email of 4 December 2016, as I was not sure by what means it could be accessed.

It seems clear that the link was not accessible by either secure or normal email, but that the document could be opened as an attachment. This seemed to indicate that access to my domain had been blocked, but was later told that access was only given to a few authorised websites.

This is the email used to convey the above document.

Acknowledgement of my recent emails, stating that my link cannot be opened as it is incompatible. He was presumably able to open the PDF as the attachment to my email, not via a link.

This is the first email I received in respect of the Customer Survey, requesting me to participate, worryingly stating that my case had been closed.

About an hour and a half later, I received a correction to the above. But this stated only that the wrong version of the survey had been sent, and that they would be in touch next week with the correct version.

Being very concerned about this (especially bearing in mind the lack of action on my case, and other circumstances), I sent this email, asking for reassurance.

In the first paragraph, I pointed out that they had sent a correction, but that this simply stated that the wrong version of the form had been sent.

The reply was hardly reassuring. He said that the survey was sent to the wrong people, and hoped that I had received a second email from them indicating that the first should be ignored.

But (as I pointed out in my email), the survey people in their second email stated that the error was in sending the wrong version, and that they would send the correct version later; there was nothing to suggest that they had sent it to the wrong people. And one would hope that they would know better the source of their error than people working in another department.

And the only "reassurance" given over my case was repetition of a statement of 31 October 2016 your application is earmarked for an adjudicator (this time in the present perfect tense: has been). This unfortunately did nothing to affirm that my case had not been closed subsequently.

The "reassurance" wore even thinner on 15 February, when as promised the survey department sent another version of the survey.

1. they had not only sent the wrong version of the form, but also sent it to the wrong people; and furthermore had still not corrected the latter error some four weeks later; or
2. my case had indeed been closed as they stated.

On 31 August, the Casework Manager gave a verbatim repetition of the above "reassurance". However, on 15 September, the Casework Director stated that there are two versions of the survey; one for those whose cases are complete, and another for those whose cases are still open. Whilst this might explain the situation, it seems unlikely; moreover it is inconsistent with not only the previous reassurances, but also information from DWP.

It is now over 5 months since I was told that my application is earmarked for an adjudicator, and I have received not a shred of information on my case since. Bearing in mind this and the worrying circumstances (plus the gravity of the case), it should not be surprising that I was in despair.

So I emailed TPO expressing my concerns, and again asked for reassurance that they would investigate my case, and could deal with it appropriately.

Received a reply stating my that my email had been forwarded to Barry Berkengoff. At last I knew who was supposed to be investigating my case. And the email forwarded to him would give him plenty of information.

It seemed surprising that Carl Monk did not seem able to answer a simple query about the status of my application himself. But at least I could expect to receive information on my case "from the horse's mouth".

Five weeks later, having hoped to hear from Barry Berkengoff, I have still received no response, or any other information on my case.

For some time now, I have been facing serious financial difficulties, and my situation is becoming more perilous with every passing week. All these circumstances have made me despondent.

I sent this to Barry Berkengoff, challenging him to give me some proper reassurance (I had to surmise his email address). I attached the email that he should have received from Carl Monk, and added further content. Again, this gave detailed information on my case, which should have made clear that it was a serious one that warranted urgent investigation.

At last, a response from Barry Berkengoff, denying that my case had been closed. He affirmed that he would be investigating, and stated that he may telephone me to discuss matters in the first instance. Apart from this being difficult for me, I hardly think that it would be an apt way to proceed with this involved case that I have spent so much time documenting.

And it was hardly encouraging to be told that his main role is managing others. Although Carl Monk referred to him on 7 April as Senior Adjudicator, his title is now given as Deputy Casework Manager. Is this a recent change of position?

He stated that he will be in touch shortly, and thanked me for my continued patience. But it appears that he has been sitting on my case for six and half months without having done anything whatever, and only reacted after I emailed him directly (not to the email forwarded to him five weeks ago).

My response to the above, urging him to review carefully the website that I have spent hundreds of hours developing, rather than attempt to obtain an understanding over the telephone. However, I agree to make myself available by telephone should it prove necessary.

I also express concerns over just what TPO can do, but express the hope that a just resolution can be achieved through this organisation.

Received a more extensive response from Barry Berkengoff. He stated that he was scheduled to review my case last week, but was unable to do so as my website was inaccessible; but that he would proceed once the block had been lifted.

He also went into more detail as to what TPO could do, and stated that TPO could only deal with the maladministration event. He then said that I was within my rights to take my own legal action, and that in this case, I would have to withdraw my case with TPO. The preceding comments and the final sentence seemed intended to rush me into doing just this. This would have been imprudent, to say the least, without any clear alternative.

My reply to the email of 22 May.

I firstly gave more information on my website. I also explained certain aspects of my case, in particular that Scottish Widows was imposing draconian "verification" requirements under the false pretence that these are required under UK legislation.

Response by Barry Berkengoff to the above, again stating that his jurisdiction is limited to instances of maladministration (although this in fact appears to be a broad term). He stated again that he hoped to have access to my website shortly and would review my case then.

After a paragraph stating that TPO is impartial and does not take sides, he then stated that he expected my case to be the result of Scottish Widows having slightly different processes for overseas customers to ensure appropriate ID checks are made.

After the numerous clear statements I had made (including in my email of two days ago), the above comment is absurd. It is to leap to the side of Scottish Widows, and dismiss everything I had said as either lies or the inane rantings of a lunatic. And I could have no optimism that he would change this position, even when faced with the cogent evidence on my website.

If Mr Berkengoff had not obtained access to my website by now, he most likely never would, so I sent an email with a ZIP of most of my website, to be followed by another email with the remaining files. This would enable my website to be installed locally, thus bypassing the access issues. But my ZIP file was rejected by their delivery system, so I sent another email without the attachment.

I explained the concerns I had over these inordinate delays plus the evident lack of regard for my position, and the difficulties and distress that this was causing me.

This was an attempt to send the individual files, which I aborted when I received a message from their mail delivery system that my ZIP file had been rejected on account of its size. I had intended to send multiple attachments, but abandoned my attempts to provide an offline solution, and sent only a single attachment (the letter from SW rejecting my documents).

A reply emphasising that access to my website had been denied. I never questioned this; on the contrary, it is why I attempted to send the ZIP file. But he did offer to review my website on a non-secure connection at home or on the office Wi-Fi (although this was only after I had "threatened" him with a solution that he could use offline in the office).

He said he could not comment on whether there was access to my website at the time of my application. But the evidence indicates that my website was accessible up to around 10 November and blocked by around 23 November. If there were any (inappropriate) general blocking of websites (.mx and presumably numerous other countries) introduced around this time, he would surely know about it and have mentioned this as the reason. So it seems that my website was specifically targeted.

My reply, acknowledging his willingness to use a non-secure connection, and encouraging him to review the website soon.

Apology for the security restrictions, but he hoped that I would understand the reasons why. I do not. If my website has been blocked simply on the basis of its domain name extension, this is arbitrary and inappropriate; most undesirable websites will have common extensions. A more sensible scheme would be to maintain a list of sites known to be undesirable, with the provision to update this list with new sites as they are encountered; I suspect that this has been applied to my domain.

He stated that he would much prefer to view my case online (seemingly not wanting to use an offline solution that would work in the office). But he did state (or at least imply) that he would review my case early next week.

After nearly another month, it seems that Barry Berkengoff has still done nothing. So I sent another email to chase up - this time expressing my concerns more bluntly, and challenging him to give me some answers. I made plain that I would not be satisfied with anything less than evidence that he had an understanding of my case, and was taking it seriously.

I put it to him that he had been sitting on my case since the end of October 2016, without having offered any explanation for this; and that it was clear that, had I not surmised his email address and contacted him directly on 14 May, I would still have heard nothing.

I also put to him directly that the evidence indicated that my case had been buried, and that this was most probably at the behest of Scottish Widows. I again made plain the gravity of my case, and that this involves a blatant false pretence that Scottish Widows would have a strong incentive to cover up.

I asked whether he would be willing to put the list of questions I had prepared for Scottish Widows, under legislation compelling them to respond or be in a situation tantamount to contempt of court. This would easily show whether Scottish Widows is making appropriate ID checks.

As expected, a prompt reaction to my email. Unfortunately, it does nothing to address any of the points that I put to him; nor does it offer any evidence that he has done anything to investigate my case. He did nothing to counter my implications that he had done nothing on my case since it was assigned to him at the end of October 2016; and that, had I not emailed him directly, I would still have heard nothing.

Instead, he simply denied any wrongdoing, and made excuses for the delays. He assured me that my case has not been buried... at the behest of Scottish Widows. This may be true - I think it more likely that it was he who initiated the deal. He justified the delays in terms of resourcing issues and a heavy workload, and that he can do investigations only one day a week. This can hardly explain the complete inaction since October 2016.

He also indicated that progress was further delayed by security issues with my website (and he clearly did not want an offline solution). These are of their invention (and probably contrivance), not of my creation.

He offered no evidence of any progress on my case, saying only that he would be in touch shortly. This is exactly what he said in his email of 15 May. I can have no expectation of anything further from him other than more delaying tactics; I will therefore no longer jeopardise my health and well-being in fruitless attempts to chase up this matter with him.

In an effort to try to determine whether or not the strong indication from the survey department that my case had been closed was correct, I sent this.

I hoped for either a clear "No" (with confirmation that they had indeed sent the survey to the wrong people) or "Yes" (this would confirm what I had suspected for some time). The worst outcome for me would be an equivocal response; I just want to know the truth.

The response was very prompt, but simply referred the matter back to the adjudicator. This was the worst possible outcome. Whilst details of my case were presumably available, it did nothing to confirm that they had sent the survey to the wrong people, and that therefore my case was presumably open at that time. Had I had such confirmation, I would have accepted that my case had not been closed. And I will not hold my breath waiting for the status report, nor chase the matter up.

Having failed to get any answers to the question over the customer survey, and dutifully waited for the status report, I sent a follow up; this time with a full discussion of the issues.

Apart from the questions over the customer survey, I tried to get information on whether my domain name had been specifically blocked; it was only necessary to try the links I supplied.

My email was simply forwarded to Jane Stephens (Casework Manager), thankfully not Barry Berkengoff, from whom I received this response. There was a repetition of the "assurance" over the customer survey, with a patently erroneous statement that my case has been actively investigated since being allocated to Mr Berkengoff in May 2017.
Carl Monk stated that Barry Berkengoff was the Senior Adjudicator investigating my case in his email of 7 April. And he reported that my case was assigned to an adjudicator in his email of 31 October 2016, and this adjudicator must clearly have been Barry Berkengoff. If their database indicates that my case was allocated to him in May, it must be because my case was reopened or updated in response to my email of 14 May.

Whilst it was stated that my concerns had been passed on to Fiona Nicol (Casework Director), the information sent appears to exclude the points that were "dealt with" above. This would deny the complete inaction since October 2016, and thus negate the core of my complaint. I hoped that this was not the start of a whitewash, indicating that Barry Berkengoff was able to act with the same degree of impunity as Scottish Widows.

If Fiona Nicol was given the impression that my case had been actively investigated by Barry Berkengoff since being allocated to him in May 2017, this would be a gross misrepresentation, to say the least. So I thought it prudent to send this email in an attempt to dispel such an impression. I attached PDF documents of my email of 30 August, plus the reply of 31 August to ensure that full information was provided.

I hoped that there would be database transaction logs that would confirm what updates there had been to my case since October 2016, although I have little optimism that they could or would check this. I also reproduced the links to check whether my website had been specifically targeted; to do this would take only take a few seconds.

An acknowledgement from Fiona Nicol, stating that I could expect a reply to my complaint by 15 September.

Fearing that my case had still not been adequately represented, I sent a follow up to my previous email in an effort to avert a whitewash.

I stated that it was practically certain that my case was assigned to Barry Berkengoff in October 2016, mentioned the oddity in the way my case was handled (seemingly rapid assignment, followed by complete inaction), and made clear my belief that most likely Mr Berkengoff had initiated a deal with Scottish Widows to bury my evidence.

This first and final complaint response from Fiona Nicol not only whitewashes Mr Berkengoff; it also blackens my integrity with false statements that I had made allegations against TPO and had no evidence.

In the first instance, I did not actually raise a complaint; I simply attempted to get information on two sets of circumstances that would indicate burial of my case (over the customer survey, and the apparent blocking of my website). However, this was not forthcoming, and the matter was referred to the Casework Manager, then the Casework Director.

As Jane Stephens had clearly grossly misrepresented my situation with a false statement that my case had been actively investigated by Barry Berkengoff since it was assigned to him in May 2017, I found it necessary to send two emails to Fiona Nicol to correct and clarify.

It will be clear on perusal of my emails that I merely voiced my suspicions; nowhere did I make an allegation. On the contrary, I urged investigation into my concerns that Barry Berkengoff may be colluding with Scottish Widows, and stated that this might either confirm or refute my suspicions.

This stunning email confirms what I had suspected for some time; that Barry Berkengoff will not investigate my complaint. Instead, he is attempting to push me into a pragmatic solution with Scottish Widows.

Moreover, the email header indicates that it was copied to Fiona Nicol, who must therefore be (at least) in agreement with this arrangement (which grossly violates the Pension Schemes Act 1993/2017).

I am asked whether I hold a current UK passport or photo-ID driving licence as an alternative to my Permanent Resident ID card (Scottish Widows had previously offered to accept the latter document alone). This request is not relevant to the reason my documents were rejected, which is my inability to fulfil their proof of Address requirements.

My reply made very plain that a pragmatic solution was unacceptable, especially bearing in mind the very serious nature of my complaint.

I copied it to both Fiona Nicol and the Pensions Ombudsman (Anthony Arter, who I hoped would be above this clear misconduct).

I sent a follow up email for clarification to Anthony Arter alone. I gave an overview of my case against Scottish Widows, and urged a thorough investigation.

I received no reply to this, but held out the hope that there was an undercover investigation, in which he had considered it best to operate in total secrecy, including not communicating with me.

Another outrageous email from Mr Berkengoff, this time pushing me into his pragmatic solution as an ultimatum. He ridiculously asks whether I hold a signed Mexican passport, stating that this was requested by SW.

He claims that he has the discretion to find solutions to problems where the case has become entrenched (even though he made no attempt whatever to investigate; he would not even send SW my list of questions). Moreover, he has the audacity to assert that this is his decision as I brought the case before TPO (in contradiction of TPO's own information on its remit). And he certainly has no discretion to do this under the Pension Schemes Act 1993/2017 either; this gives the complainant a statutory right to investigation, followed by a determination made by either the Pensions Ombudsman or his deputy. Arbitration is a function of TPAS, not of TPO.

He then counteracts the above by claiming that if his pragmatic solution is not achievable, the case would be resolved by the proper process of investigation and determination (which obviously would not happen, as his endeavours to evade it could not be clearer).

I am required to either confirm that I will accept his imposed pragmatic solution, or withdraw my case. I will do neither.

Rather than reply to Mr Berkengoff, I forwarded his email to Anthony Arter, stating my position, and explicitly asking him whether he was in agreement with Mr Berkengoff's stance.

It is of very serious concern that again, I received no reply. Firstly, Barry Berkengoff's efforts to force me into his pragmatic solution contravenes the Pension Schemes Act in at least two ways. Worse, given the nature of Scottish Widows' misconduct, it also amounts to perversion of the course of justice amid strong suggestions of collusion. And I could now be in little doubt that Mr Arter himself is complicit in this.

The list of declared interests for senior TPO staff shows that Anthony Arter holds shares in no fewer than 22 pension companies. This, together with his background as a solicitor acting for such companies, makes one wonder how he could possibly be considered impartial.

However, it also shows that Claire Ryan (the Legal Director) is a fellow Scottish Widows personal pension holder. So I sent this in the hope that there may be a sympathetic ear within TPO. It seems that there is not; or certainly not the moral fibre to speak out. In the face of its unlawful (probably criminal) conduct, this unscrupulous organisation will just close ranks and protect its own.

An extraordinary email from Jane Stephens, which over a year later essentially continues the ridiculous charade of Barry Berkengoff in requiring additional verification; now a Mexican passport (even though I am a British citizen and have never given any indication to the contrary).

It was now clear that the SW/TPO charade is founded on a supposed lack of satisfactory verification of Name (this became significant in the following Opinion), even though this is absolutely contradictory to the documented facts.

The reason SW gave for refusing my application was lack of proof of Address (which is not present on a passport). And I supplied SW with both my ID card as permanent resident (giving the same details as a passport), plus a birth certificate. After I challenged SW, they made two "offers" that might have led to acceptance of my existing documents.

This email states that they received an email from SW in November 2017, but were unclear from their papers whether this email was forwarded to me. I am not sure what "papers" they have to record emails: surely, these are retained on their mail server?

If this extraordinary situation is to be believed, then why was the email from SW not forwarded now? The embedded text (apparently copied and pasted from the source) hardly gives good evidence of it. And am I to believe that Barry Berkengoff, who at that time was pressing me into a deal with SW (and by his account negotiating with them directly) neglected to send me this email at the time?

But whatever the truth, this email serves as yet more evidence that TPO is flagrantly violating the Pension Schemes Act by refusing to investigate and determine this case. TPO has no business to negotiate with pension providers; and the reasons for this should be obvious. In fact, there is clear circumstantial evidence that TPO did a deal with SW around the middle of November 2016; and that this involved a substantial payment by SW.

My reply again repeated that I would not be party to TPO's unlawful (indeed criminal) conduct.

I demanded that my case be investigated and determined as required under the Pension Schemes Act 1993/2017.

I received an automatic notification that Jane Stephens would be out of the office until 21 November, but have not mustered the enthusiasm to add this here.

This is the covering letter for the Opinion, retrieved from mimecast. I am required to respond by 30 January, or the Opinion will become the final resolution.

There was an introductory email plus two further emails containing user ID and password and explaining how to recover the email and document; these contain no information on this case, and so are not reproduced here.

This is the Opinion itself, which was pretty easy to demolish. It contains some quite astounding falsehoods, in a very clear attempt to sustain the SW/TPO position, especially over their request for documents to verify Name (maladroitly attempting to negate the difficulty that my documents were rejected as it was impossible for me to prove my Address, thus demonstrating the invalidity of their demands). Upholding SW's demands for documentation also required that it was reasonable to carry out both customer Identification and Verification of that Identity at the same time.

Please read my rejection of this Opinion below for full details.

This is simply to remind me that I must respond to the Opinion by 30 January or it will be assumed that I have accepted it.

This is the covering letter of my rejection, with a PDF document attached. I sent this to both Tunde Adenubi and Jane Stephens.

This is the Opinion rejection itself.

I firstly debunk some gross misrepresentations about AML requirements (in particular the implication that both Identification and Verification of Identity are required), secondly some ridiculous statements that are said to be Scottish Widows' position, then some of the remaining issues.

This is an out-of-office notification from Jane Stephens, who it is stated will return on 29 January.

This is an acknowledgement of the Opinion rejection I sent on 27 January. On 29 January, the Department for Work & Pensions accessed web links from my Opinion Rejection over several hours, and there were further accesses (also clearly from this document) on 5 March - see the Access Log Reports.

This is simply a notification that I have received an Amended Opinion via mimecast. I am asked to respond if possible by 25 March (it was sent on Friday, and a response is expected the following Monday).

This is the page from mimecast to access the secure message, which contained the Amended Opinion. I had no problems accessing this using the supplied details.

This is the Amended Opinion itself, which is stated to arise from discussions with the Pensions Ombudsman.

This basically accepts some failings in Scottish Widows' communication surrounding the verification requirements (these were commented on in the Original Opinion, though not considered maladminstration). However, the requirements themselves are fully sustained,while doing nothing whatever to address some awkward facts that I expressed in my Opinion rejection, which directly contradict this position.

It states that Scottish Widows has agreed to pay £1000 in respect of the communications failings, even though the Pension Schemes Act authorises TPO only to investigate and determine complaints - negotiation of any kind is not a legitimate TPO function (and it should be obvious that to allow this would be conducive to corruption). Nonetheless, TPO did a lot worse than this in forcing its "pragmatic solution" upon the complainant (I was given the option of accepting this, or withdrawing my case).

This is the covering email for my rejection of the Amended Opinion, which I obligingly sent before 25 March as requested. The document below is attached.

This is my rejection of the Amended Opinion. It is essentially a revised version of my rejection of the Original Opinion, with a section added to deal with a few points in the Amended Opinion.

This is the page for another mimecast message (in fact it contains the Final Determination, although I had no means of knowing this at the time). But although the browser had saved the user ID and password, I was unable to access the message, even after resetting my password.

My response to the above, requesting that future correspondence be by ordinary email.

Response from the adjudicator, attaching the two documents below (Final Determination and Information) in unencrypted form.

Final Determination from the Pensions Ombudsman (Anthony Arter), sent as a attachment to the above email.

It is a travesty that does not withstand scrutiny, with gross misstatements, both in relation to the facts of my case, and in relation to Anti-money laundering regulations. It also contains serious internal inconsistencies. These are inherited from the Opinion, even though I explained the errrors fully in my Opinion Rejection, which Mr Arter stated that he considered.

I subsequently created documentation that will be used to promulgate my case as appropriate, and in particular dispatch what should be a highly self-incriminating document:

Key Facts (Determination)

presents a concise overview in the form of numbered paragraphs.

Analysis of Determination

gives more details, with references to material in the Opinion Rejection.

Factsheet accompanying the Final Determination. It appears that, being resident in Mexico, I have no chance of bringing this case before the High Court.