London Stone Securities Limited · DRN-6234216

The complaint Mr F is unhappy, in summary, as he feels that the commission London Stone Securities Limited (‘LSS’) charged significantly reduced his stocks and shares ISA portfolio value. And that LSS didn’t amend the risk level associated with his portfolio, when he was concerned about what was happening with this. What happened I've outlined what I think are the key events and points involved in the complaint below. In May 2023, the transfer of Mr F’s portfolio to a stocks and shares ISA with LSS completed, with a total value around £97,000. And it was agreed LSS would provide Mr F with a discretionary fund management (‘DFM’) service. On 2 May 2023, LSS completed a private client profile (‘PCP’) with Mr F. This recorded his circumstances and objectives and, amongst other things, that: • Mr F wanted to maintain his portfolio value and grow this if possible. He was happy to speculate with a small part but might call upon this when needed, for wedding costs, for example. And he had fund and normal share dealing experience, with his existing stocks and shares ISA also being invested via a DFM account. • He understood LSS’ share dealing investment strategy, which was suitable for him. • Investment would be in the FTSE 100 (low risk) and FTSE 250 (medium risk), small cap (high risk), as well as 5-10% of his portfolio in AIM (high risk). • There was an annual management fee of 2% the first year, and 1% thereafter. • Commission was 1% of the deal size, subject to a minimum of £100 per trade. Given this, the deal size LSS suggested was £10,000 or more. It said that a £5,000 deal, for example, would cost the same £100 commission, so the stock would need to move up by 4.5% (2% to buy, 0.5% stamp duty, 2% to sell) before it generated a profit. • Mr F was flexible to changing his strategy according to the market, which could mean changing how long he might hold a share for or adjusting how much profit or loss he’d typically accept. And, in respect of investment frequency, the PCP said: ‘Our strategy is to trade in and out of blue-chip shares looking for short-term capital appreciation. This means that we might buy and sell the same company within a few days or weeks if it gives a reasonable profit. However there will be other times where we will trade less frequently because we are holding loss-making shares which we may end up holding for several months or even years, in this case we hope to collect dividends as we wait. There will also be some days with a high number of trades executed (e.g. if the market moves up or down significantly in a single day), and on other quieter days there will be no trades executed at all…. … The number of trades that we execute on any given day will depend on the size of

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your portfolio, the amount of cash available, the number of positions you hold that are in profit, and the number of opportunities in the market on any given day.’ Mr F confirmed he was happy with this, along with LSS executing trades as and when it deemed sensible, with a variable frequency of trades depending on market opportunities and it holding shares for any period it deemed sensible. A suitability report summarised some of Mr F’s circumstances, it said he was flexible in terms of investment approach and frequency of dealing, with nothing in mind and that LSS had assessed Mr F as a low to medium risk investor. On 5 May 2023, Mr F signed LSS’ investment strategy document, which said, amongst other things, that: ‘The strategy I would like to implement for my share portfolio with [LLS] is as follows: …4 Buying and selling more frequently where a profit, even if quite small, can be captured. This can be over a short period of days and weeks or over a number of months. 5 Buying and selling less frequently where there is a loss. In other words, I prefer to hold onto ‘losing’ shares for the medium and long term, which have fallen in price, rather than to sell. This is in the expectation that over time the price may recover, and in the meantime, I may receive some dividends. 6 If the losing shares in (5) do not recover over a reasonable period of time, say 12 months, I will discuss with my advisor what the best option may be including whether to sell the shares and crystallise a loss, continue to hold them or even to buy more at the new, lower price. 7 I am open to discussing with my advisor and investing a small proportion of my total share portfolio in more risky shares including penny shares within the AIM market. I will agree with my advisor how much in due course 8 I am open to being flexible in this strategy and will speak to my advisor to make the necessary adjustments if I wish to change anything going forward. … Fees & Strategy I understand that a high frequency trading strategy will incur higher commission fees whilst a low frequency trading strategy will incur less commission fees….’ Mr F signed a separate AIM share investment strategy document, which confirmed he’d agreed to invest in these as part of a larger portfolio, that he understood these are high risk and this superseded his PCP. Seven AIM investments were recommended with around £2,000 to be placed into each. These were purchased in mid-May 2023 and held until the end of March 2024, just before Mr F moved away from LSS as set out below. Mr F was provided with a Risk Warnings Disclaimer and he signed LSS’ discretionary trading account terms of agreement, the latter of which noted, amongst other things, that: • LSS would take charge (until further notice from the client) of all investment decisions and will not require consent for individual transactions and/or strategies.

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• It would select investments it reasonably believed to be suitable for the client, according to the Know Your Customer documentation including the PCP, any other information provided by the client, and any factors it deemed important at the time of the transaction such as, market conditions and tax considerations). • Mr F could cancel the agreement at any time and he was responsible for regularly checking his account to ensure it was being kept in line with his objectives. • In respect of preferred account parameters, which should be fulfilled as closely as possible while still allowing for a degree of flexibility for changing market conditions, Mr F agreed to ‘any’ deal size, as well as ‘any’ number of trades per month in respect of opening new positions (but not in respect of closing out existing positions). And LSS’ account terms and conditions said, in respect of short-term trading and commission, that: ‘Short-term trading will by its very nature involve a very high frequency of dealing which results in single or multiple transactions conducted on a daily, weekly and monthly basis. As a direct result of this increased trading activity, you should expect commission levels to be much higher for this type of trading. Before agreeing to short-term trading, you must carefully consider whether you are prepared to pay the increased level of commission for such trading activity…. Due to the increased trading activity (and therefore increased commission), your investments will need to make larger profits to absorb these increased costs. If you do not wish to incur large commission charges on your account, you should reconsider whether short-term trading is right for you and if you are unsure you should always seek independent financial advice.’ And that: ‘…Whilst we believe that our commission structure is fair, it should be recognised that particularly for short-term trading there are likely to be occasions where the commission generated for the firm is greater than the profit generated for the client. In the case of loss-making trades this will of course always be the case.’ On 4 August 2023, LSS emailed Mr F and said, in summary, that the stock market had become volatile, which meant it was seeing more trading opportunities. LSS reminded Mr F that its general strategy meant a high frequency of transactions and particularly during such conditions, which meant more trading costs. LSS said it wouldn’t trade every day indefinitely but there might be times where it would over a period of time, like a week or two. And that if things calm down it might follow more of a buy and hold approach, which it does in any case usually with losing shares. Mr F was asked to let LSS know if he didn’t want to participate. That it could trade less frequently, which won’t necessarily help improve performance and may negatively impact his portfolio. And, while there are no guarantees, it was confident that over a long enough time the strategy would bear the results it and he were looking for. A few days later, Mr F responded by email and said that following a call with it he was happy to continue with the current short-term trading strategy and recognised this would incur additional trading costs. Then, in a market commentary email to Mr F, dated 18 August 2023, LSS said that due to markets having dropped again the risk is with companies still held. And that it needed to consider whether it’s sensible to continue holding these or if it’s better to sell for more options.

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On 18 September 2023, LSS emailed Mr F again and said, in summary, that in recent weeks and months he might have noticed higher frequency short-term trading. It said that now, rather than holding a position where there’s a fall in price which is the position it has traditionally taken, it will mitigate this by selling some of the stock to reduce risk exposure. It said the obvious downside is higher commissions, but if the goal is to adopt the best strategy to mitigate risk in the most effective way this is probably the best way forward. It said this would mean more commission but a lower probability of having an investment that can potentially lose a lot of money. LSS said that based on Mr F’s questionnaires he was suitable for a high frequency trading strategy and this fits his risk profile and objectives, although he should let it know if he didn’t want to follow this. LSS hasn’t provided a copy of any response Mr F made or sent to this email. And the strategy was seemingly adapted. Mr F said that later in August/September 2023, he became unwell and, around the time he was admitted to hospital, his portfolio value dropped to around £82,500. So, when he was recovering in October 2023, he told LSS that he didn’t want to take such risk and was concerned about losses. Mr F has said no changes were made to his portfolio though, so he called LSS again in January/February 2024 and it offered him 18 months with no charge, as it said it would instead take a percentage of any profits from trading activity carried out. In March 2024, Mr F received his 2023 costs and charges statement from the custodian. This said, amongst other things, that his portfolio had incurred service costs of just under £22,300, of which £2,011.97 at 2.43% of his portfolio was intermediary fees and around £20,000 at 24.29% was dealing costs. In April 2024, the FCA issued a first supervisory notice in respect of LSS. And Mr F received a letter from the custodian which said that the FCA had restricted LSS’ permissions, such that LSS was prohibited from managing his portfolio and no more LSS fees would be taken from his account. In June 2024, Mr F become a client of the custodian on an execution only basis. In July 2024, the FCA issued a second supervisory notice against LSS. And, amongst other things, this said that: ‘…4.47 Further, the Authority is concerned about the number of trades executed on some client accounts was not proportionate to a client’s risk level and profile… 4.48 …Despite the large number of trades, some accounts have decreased in value; yet clients have still been charged high levels of commission, thus compounding the client’s loss…’ In or around August 2024, Mr F complained to LSS that, in summary, he moved to it after being worn down by it with promises of lower charges and higher returns. This ISA portfolio is 100% of his available funds and he still has loans and dependents. Mr F said that around £20,000 of the drop in value of his portfolio in less than a year results from commission costs charged to its benefit as part of the short-term trading strategy. Mr F said he hadn’t been involved in such trading before and that no changes were made following his calls to LSS. The following month, LSS sent Mr F its final response letter, which said, in summary, that: • Mr F was made aware of its fees and charges in the PCP and its charges schedule. He was provided with statements, valuations and contract notes detailing trades and commission, and was responsible for checking his account to ensure he was satisfied with fees and stocks purchased. • Mr F’s transition to it didn’t represent an alternative investment strategy. No high risk trades were executed, such as CFDs. And it acted in line with his investment

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objectives, risk profile and market conditions, as per his instructions. • It was explained to Mr F that LSS’ expertise is in short-term trading, which could result in higher commissions, which he agreed to in knowledge of the fees. There’s no evidence LSS executed any unsuitable trades against Mr F’s interests. Instead, some weren’t carried out to avoid excess fees and the stocks were mainly low risk. Mr F referred his complaint to our Service in October 2024. He said the concerns he had about his portfolio falling in value resulted from what he’d been charged in commission. He said he only has a small amount of stock left in this ISA portfolio now – he sold £30,000 of this in June 2024 and put a further £20,000 of this into a cash ISA in October 2024. LSS added that Mr F did reach out to it in August/September 2023 to discuss his portfolio performance, but didn’t raise concerns about fees or the number of transactions. It’s implausible to suggest Mr F was unaware of its short-term high frequency trading approach and commission level compared to a traditional buy and hold strategy. Mr F agreed to some higher risk shares as part of his AIM portfolio, showing he wasn’t just looking for low risk investments. And trades were in line with the agreed mandate. Our Investigator asked LSS for the call it had with Mr F in October 2023, as well as evidence of those it had with him in January/February 2024, but it didn’t provide this. And our Investigator went on to uphold Mr F’s complaint. They said, in summary, that based on the available evidence a less risky approach should have been taken to Mr F’s portfolio by LSS from October 2023 when he got in touch with it. And, in any event, the frequency/level of trades carried out by LSS made it unlikely Mr F’s portfolio would be profitable when bearing in mind the commission it charged for each trade. Commission charges amounted to more than 20% of Mr F’s portfolio value. And we’ve seen nothing to show LSS made him aware of how this could impact the overall return. LSS didn’t agree on the basis it had provided a substantial amount of evidence in support of its position. As no agreement could be reached, the case was passed to me for a decision. And I issued a provisional decision – which is largely set out again below – which explained that I intended to uphold Mr F’s complaint but for expanded upon reasons and amended redress to that set out by our Investigator. While Mr F accepted my provisional decision, with no further comments to add, LSS didn’t accept this. It added, in summary, that: • Much of the capital loss arose from share price depreciation, where positions were held through adverse market movements, rather than from commission. Transaction costs must be distinguished from market-driven capital loss. Commission doesn’t provide significant drawdowns in isolation, market decline does. • We should assess the trading rationale for the actual investments, by undertaking a trade level analysis, before concluding that commission caused the loss. • Its long-term strategy has been short-term trading in profitable positions to crystallise gains, with medium to long-term holding of losing positions where recovery is reasonably anticipated. • The commission wasn’t hidden, ambiguous or unclear. Mr F wasn’t an inexperienced investor and the risks were understood and accepted. The documents completed set out that he didn’t want to be spoken to before each recommendation as he was often unavailable, nor receive risk warnings before each trade. And he didn’t complain when individual trades that he received contract notes for were carried out. That’s despite being told he should monitor the account and could cancel it at any time.

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• Where there’s a loss complaints arise alleging overcharging, when loss doesn’t equal misconduct. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. And, having done so, I’m upholding Mr F’s complaint for largely the same reasons as those set out in my provisional decision, which I’ve repeated again below. In deciding this complaint I’ve taken into account the law and regulations; regulatory rules, guidance and standards; codes of practice; and (where appropriate) what I consider to have been good industry practice at the relevant time. While I’ve carefully considered the entirety of the submissions the parties have provided, my decision focuses on what I consider to be the central issues. The purpose of my decision isn’t to comment on every point or question made, rather it’s to set out my decision and reasons for reaching it. I’ve looked at the available evidence to decide what I think is likely to, or should, have happened. And should I decide something has gone wrong I’d ask the business to put things right by placing the consumer, as far as possible, in the position I think they’d likely have otherwise been in. I think the crux of Mr F’s complaint is there was a high quantity of trades in which associated fees significantly reduced the value of the part of his portfolio that was following the short- term trading strategy. And that LSS then didn’t act on his instructions to amend the risk level associated with this, when he was concerned with what was happening. Upon Mr F moving his ISA portfolio to LSS in May 2023, its value was around £97,000. Mr F has said that by April 2024 though, this was now valued at around £73,000. And I can see that around £19,000 of the reduction resulted from commission charged by LSS on around 190 trades, including around 90 buys and 100 sells, across around 11 months from mid-May 2023. It isn’t in dispute that the investment strategy agreed between Mr F and LSS at the outset, in May 2023, was to carry out short-term trading, which could include high frequency trading, designed mainly to time and chase the markets and to be reactive, in the short-term, to news, events and trends in those to achieve profits on individual shares. No performance guarantees were given and Mr F declared he understood he’d incur higher commission. However, the terms of the DFM arrangement needed to be clear, fair and not misleading. And LSS’ had to ensure Mr F’s portfolio was and continued to be suitable when bearing in mind the originally agreed investment mandate in respect of how LSS would operate, which included things like Mr F’s risk profile, objectives and trading frequency set out. In addition, at this point, I should explain that the Financial Conduct Authority Handbook (in its Conduct of Business Rules), defines ‘churning’ as follows in COBS 9.3.2: “A series of transactions that are each suitable when viewed in isolation may be unsuitable if the recommendation or the decisions to trade are made with a frequency that is not in the best interests of the client.” And it says that:

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“A firm should have regard to the client's agreed investment strategy in determining the frequency of transactions...” The focus is on the frequency with which a firm carries out transactions for its client and on the client’s best interests. And I think that frequent transactions in a client’s portfolio ought not to be carried out only, or mainly, for the purpose of generating commission for the firm, these should instead be carried out in the client’s best interests and when bearing in mind the agreed DFM mandate. LSS has said it let Mr F know about the increased frequency of short-term trading in its August and September 2023 emails. And it has defended its discretion in terms of compliance with its model and in reaction to performance and the market. While LSS had discretion in the portfolio management and I note that the discretionary trading agreement, for example, gave LSS flexibility, this wasn’t unlimited. It’s still the case in the way I’ve set out above that LSS’ discretion was limited by its mandate for Mr F – which appears to have never changed, as discussed further below. And, in reality, I think the approach LSS took to short-term trading in Mr F’s particular case was out of line with his risk profile and the agreed strategy from almost the outset of the relationship, for reasons set out below. LSS classed Mr F as a retail customer with a low to medium risk profile and I understand he had normal, rather than short term, trading experience and that the shares he’d invested via his previous DFM were longer term. And, as set out above, while the PCP set out that Mr F was happy with a trading frequency that fluctuated based on market conditions and was flexible to changing the trading strategy, LSS also said in this that: ‘…we might buy and sell the same company within a few days or weeks if it gives a reasonable profit. However there will be other times where we will trade less frequently because we are holding loss-making shares which we may end up holding for several months or even years…’. And that: ‘The number of trades that we execute on any given day will depend on the size of your portfolio, the amount of cash available, the number of positions you hold that are in profit, and the number of opportunities in the market on any given day.’. The investment strategy document recorded, amongst other things, that LSS would buy and sell more frequently where a profit, even if quite small, can be captured. And that Mr F preferred to hold on to ‘losing’ shares for the medium to long term, rather than sell these, and a period of around 12 months for that was set out. And, while the discretionary trading agreement said that the preferred parameters of the discretionary account was that Mr F agreed to ‘any’ number of trades per month, I can see that it also specifically said that this was in respect of opening new positions rather than closing out existing positions i.e. that discretion was in respect of buys rather than sells. So I think that the strategy originally agreed to, and likely understood by Mr F in the circumstances, was that the short term and high frequency trading was in respect of positions in profit and LSS would usually hold, and deal with, loss making shares in the way I’ve set out above. And that, based on a Key Information Document that LSS has referenced in its responses to us, albeit I can’t see that it has provided us with a full copy in Mr F’s case, it would only sell losing positions ‘if it’s deemed absolutely necessary and where the research suggests the risk of the stock price continuing to fall is significant’. As mentioned, LSS has said it let Mr F know about its increased frequency approach to short-term trading in its August 2023 and September 2023 emails. But, while its 4 August

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2023 email – that Mr F responded agreeing to – discussed that this meant higher trading costs, LSS also said that ‘…Things may then calm down, and we follow more of a buy and hold approach (we do that in any case, usually with losing shares)’ (my emphasis), I think reinforcing that this hold approach had and would still apply to losing shares. I think that LSS’ market commentary emailed, dated 18 August 2023, only suggested that it was considering the position in respect of whether it’s sensible to continue holding losing positions or if it’s better to sell for more options. And that it wasn’t until LSS’ email to Mr F on 18 September 2023 that it communicated that it would no longer take this approach when it said that now, rather than holding a position with losing shares, which it said is that which it had traditionally taken, it would mitigate this by, for example, selling some of the stock to reduce risk exposure. So, I think these emails further support that part of Mr F’s agreed strategy had been for LSS to usually hold loss making shares. The 18 September 2023 email also said that, based on Mr F’s questionnaires, it was satisfied he was suitable for the above increased frequency trading strategy – the one it seemingly also now intended to take to loss making shares – that it fitted his risk profile and investment objectives, he qualified for this approach and it felt this was the best way forward for the foreseeable future. But I can’t see that Mr F’s agreed low to medium risk profile had changed, nor that LSS had any reasonable cause to think it had – such as a change in his circumstances – for what I think was this higher risk approach that involved removal of its holding of losses to be suitable for him and in line with the agreed mandate in the particular circumstances of this case. And I can’t see that any new investment strategy document was completed to reflect this. I think the above is particularly important in the circumstances of Mr F’s case. I say this because, while LSS’ emails gave the impression that the above changes would only be from mid-September 2023, I can see numerous examples where trades which weren’t in line with the agreed mandate of usually holding losses had already begun to happen within days and weeks of Mr F’s move to LSS in May 2023, causing me to question whether the email was attempting to legitimise such trade activity after the fact. To provide more context, around half of the fifty sells that LSS carried out in the four months before mid-September 2023 were of losing positions based on the unit price, before even considering its commission costs. And these sells often took place within days or weeks of the shares being purchased. I don’t have enough information to consider the rationale behind each individual trade LSS carried out. And, despite it having had the opportunity to do so in response to my provisional decision – and me having pointed out some examples of sells to it – LSS hasn’t provided a reasonable explanation behind what I think was the higher risk approach it took to losing positions in Mr F’s case. It hasn’t provided any evidence or research it carried out from the time which reasonably explains the frequency and necessity of these sales and why it didn’t hold these losing positions in the way it agreed it usually would. And so, I am not satisfied that LSS’ actions weren’t carried out mainly for the purposes of generating commission here. Based on the available evidence I think LSS carried out trades, and from early on, which might appear suitable in isolation but were made with a frequency that wasn’t in Mr F’s best interests and which also therefore met the regulator’s definition of churning. And that the impact of such actions and the significant commission costs on Mr F’s portfolio value was, or should have been, foreseeable in the circumstances. While I recognise Mr F was provided with warnings about the risks associated with short term trading and commission costs and trade confirmations, the provision of these did not, in itself, relieve LSS of its obligation to act in Mr F’s – who was a retail customer – best interests and in line with the agreed mandate. I should also add that it seems Mr F was in hospital around the time I think LSS first clearly communicated changes in its approach to

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him in its mid-September 2023 email. And I understand that Mr F then got in touch with LSS when first reasonably able to upon recovery in October 2023 to raise concerns about his portfolio value, which he has said he now thinks is due to its trading strategy and resulting commission. Overall, I’m not persuaded that the trading activity undertaken by LSS was in Mr F’s best interests and in line with the agreed mandate. I think that the trading costs produced by that amounts to churning. And I think LSS should put matters right in the way I’ve set out below. In addition, it seems LSS didn’t act on Mr F’s concerns when he contacted it in October 2023 and January/February 2024 wanting to make changes to his portfolio as a result – LSS hasn’t provided us with evidence in the form of call notes and recordings from the time in support of its position that Mr F didn’t raise such concerns with it, despite it having had the opportunity to do so. And I think this matter has been frustrating and worrying for Mr F, also during a time when he was unwell and recovering. So, I think LSS should pay Mr F £400 in compensation – I think this is a fair and reasonable amount in the circumstances to make up for this. Fair compensation In assessing what would be fair and reasonable compensation in the circumstances, my aim is to put Mr F as closely as possible back in the position he’d likely now be in if the above hadn’t happened. That is, in respect of the part of his ISA portfolio which followed the short- term trading strategy (not including that which followed the AIM strategy, which doesn’t appear to be in dispute). Mr F hasn’t just lost out on the commission deducted by LSS from the value of the trades, he has also lost out on investment growth he might have otherwise achieved on this part of his portfolio if not for the excessive trades which weren’t in his best interests. In the circumstances, given LSS is no longer Mr F’s DFM and I think this type of trading began to take place very early on in his relationship with it, I think the fairest and most straightforward way to put things right in the circumstances is to use the benchmark I’ve set out below, from when the transfer of his portfolio to LSS completed at the start of May 2023. I am satisfied this is fair and reasonable, given Mr F's circumstances and objectives when he invested. Putting things right To compensate Mr F fairly, LSS must: • Compare the performance of Mr F's ISA portfolio that followed the short-term trading strategy with that of the benchmark shown below and pay the difference between the fair value and the actual value of the investment. If the actual value is greater than the fair value, no compensation is payable. • LSS should also add any interest set out below to the compensation payable. • Pay Mr F £400 in compensation, for the reasons set out above. Income tax may be payable on any interest awarded. Portfolio name Status Benchmark From ("start date") To ("end date") Additional interest

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Stocks and shares ISA portfolio that followed the short-term trading strategy. Still exists and liquid FTSE UK Private Investors Income Total Return Index Start of May 2023 Date of my final decision Not applicable Actual value This means the actual amount payable from the investment at the end date. Fair value This is what the portfolio would have been worth at the end date had it produced a return using the benchmark. Any withdrawal from the ISA should be deducted from the fair value calculation at the point it was actually paid so it ceases to accrue any return in the calculation from that point on. If there is a large number of regular payments, to keep calculations simpler, I’ll accept if LSS totals all those payments and deducts that figure at the end to determine the fair value instead of deducting periodically. LSS must pay the compensation within 28 calendar days of the date on which we tell it Mr F accepts my final decision. If LSS fails to pay the compensation by this date, it should pay 8% simple interest per year on the loss, for the period following the deadline to the date of settlement. Why is this remedy suitable? I have chosen this method of compensation because: • Mr F wanted capital growth and was willing to accept some investment risk. • The FTSE UK Private Investors Income Total Return index (prior to 1 March 2017, the FTSE WMA Stock Market Income total return index) is a mix of diversified indices representing different asset classes, mainly UK equities and government bonds. It would be a fair measure for someone who was prepared to take some risk to get a higher return. • Although it is called income index, the mix and diversification provided within the index is close enough to allow me to use it as a reasonable measure of comparison given Mr F's circumstances and risk attitude. My final decision For the reasons given, I uphold Mr F’s complaint and require London Stone Securities Limited to put matters right in the way I’ve set out above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr F to accept or reject my decision before 24 April 2026.

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Holly Jackson Ombudsman

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