Legal Letter to Financial Institution

[john10001]

I'm having tremendous problems with BullionVault just to change my bank details they are asking me to do excessive juvenile requests and jump through hoops. The person I am dealing with there is really obnoxious and incompetent and he is the Operations Executive.

I have already provided all of the documentation they requested including statement from old bank, statement from new bank, utility bill to prove address, copy of passport, and a signed declaration.

But they are still not happy and now want me to send selfies and buy a new passport just to prove my identity at great cost.

It is not possible for my identity to change from one passport to the next.

As far as I am aware under UK law the expiration of my current passport doesn't change it's validity. It is still a valid UK-issued passport and testament to my identity. The expiration just means I can't use it to travel anymore until I get a new one. I don't have any plans on going overseas so have not needed to update it.

My statement is a printed signature. I don't have Adobe so am unable to actually do my proper signature and am not about to shelve out on expensive software to do so especially when this guy at BullionVault also said to me in writing that signatures are easy to fabricate yet he is still requesting this from me. I think he is a moron. I'm sorry but I can't think of any other word to describe him. Printed signatures and box ticking is standard practice in the UK for online financial stuff including loans and other agreements. So I don't see what the problem is? The statement I have provided to them is what they requested and the exact same statement I made in 2008 when I last changed my bank.

KYC and AML regulations do not require me to jump through hoops, provide selfies or respond to excessive privacy breaching juvenile requests. Nothing in their terms and conditions say I need to provide selfies but they are quoting their terms and conditions to me as contract law that I agreed to and saying they need selfies and a new passport as part of KYC and AML regulations.

No other institution I am with requires all of this only BullionVault. It is ridiculous.

The UK Government and banks are turning the UK into a Kafkaesque dystopia of regulations and catch 22 situations. But it seems BullionVault is going even further than the UK government, EU and the banks. I am starting to think that they are Ingsoc. I feel like I am talking to a brick wall with them.

I may have to complain about them to the Financial Ombudsman as I am being prevented from buying within my account and they have not credited my usual Pound Cost Averaging (PCA) deposit from the beginning of December despite giving them my new banking details in the middle of November which they did not action.

Is there anything I can ask a Solicitor or Notary to do for me legally in response to this to get them to sort their lives out? E.g. A strongly worded letter, some sort of Statutory declaration attesting to my identity? And how much would those one or two documents cost?

[GoSeigen]

Can you not just walk out the door and shake the dust off your feet as you go?

GS

[RockRabbit]

I'm having tremendous problems with BullionVault just to change my bank details they are asking me to do excessive juvenile requests and jump through hoops. The person I am dealing with there is really obnoxious and incompetent and he is the Operations Executive.

I have already provided all of the documentation they requested including statement from old bank, statement from new bank, utility bill to prove address, copy of passport, and a signed declaration.

But they are still not happy and now want me to send selfies and buy a new passport just to prove my identity at great cost.

It is not possible for my identity to change from one passport to the next.

As far as I am aware under UK law the expiration of my current passport doesn't change it's validity. It is still a valid UK-issued passport and testament to my identity. The expiration just means I can't use it to travel anymore until I get a new one. I don't have any plans on going overseas so have not needed to update it.

My statement is a printed signature. I don't have Adobe so am unable to actually do my proper signature and am not about to shelve out on expensive software to do so especially when this guy at BullionVault also said to me in writing that signatures are easy to fabricate yet he is still requesting this from me. I think he is a moron. I'm sorry but I can't think of any other word to describe him. Printed signatures and box ticking is standard practice in the UK for online financial stuff including loans and other agreements. So I don't see what the problem is? The statement I have provided to them is what they requested and the exact same statement I made in 2008 when I last changed my bank.

KYC and AML regulations do not require me to jump through hoops, provide selfies or respond to excessive privacy breaching juvenile requests. Nothing in their terms and conditions say I need to provide selfies but they are quoting their terms and conditions to me as contract law that I agreed to and saying they need selfies and a new passport as part of KYC and AML regulations.

No other institution I am with requires all of this only BullionVault. It is ridiculous.

The UK Government and banks are turning the UK into a Kafkaesque dystopia of regulations and catch 22 situations. But it seems BullionVault is going even further than the UK government, EU and the banks. I am starting to think that they are Ingsoc. I feel like I am talking to a brick wall with them.

I may have to complain about them to the Financial Ombudsman as I am being prevented from buying within my account and they have not credited my usual Pound Cost Averaging (PCA) deposit from the beginning of December despite giving them my new banking details in the middle of November which they did not action.

Is there anything I can ask a Solicitor or Notary to do for me legally in response to this to get them to sort their lives out? E.g. A strongly worded letter, some sort of Statutory declaration attesting to my identity? And how much would those one or two documents cost?

These onerous steps to change your bank account with BV are clearly set out when you open an account with them and are actually promoted as a security feature. They are designed to be as difficult as possible in order to protect your assets. If someone gets into your online account, it makes it very difficult for them to change your bank account details and withdraw your assets. This is a feature not a bug, and I think it is quite sensible. If you don't want this level of security, why not simply close your account?

[stevensfo]

I'm having tremendous problems with BullionVault just to change my bank details they are asking me to do excessive juvenile requests and jump through hoops. The person I am dealing with there is really obnoxious and incompetent and he is the Operations Executive.

I have already provided all of the documentation they requested including statement from old bank, statement from new bank, utility bill to prove address, copy of passport, and a signed declaration.

But they are still not happy and now want me to send selfies and buy a new passport just to prove my identity at great cost.

It is not possible for my identity to change from one passport to the next.

As far as I am aware under UK law the expiration of my current passport doesn't change it's validity. It is still a valid UK-issued passport and testament to my identity. The expiration just means I can't use it to travel anymore until I get a new one. I don't have any plans on going overseas so have not needed to update it.

My statement is a printed signature. I don't have Adobe so am unable to actually do my proper signature and am not about to shelve out on expensive software to do so especially when this guy at BullionVault also said to me in writing that signatures are easy to fabricate yet he is still requesting this from me. I think he is a moron. I'm sorry but I can't think of any other word to describe him. Printed signatures and box ticking is standard practice in the UK for online financial stuff including loans and other agreements. So I don't see what the problem is? The statement I have provided to them is what they requested and the exact same statement I made in 2008 when I last changed my bank.

KYC and AML regulations do not require me to jump through hoops, provide selfies or respond to excessive privacy breaching juvenile requests. Nothing in their terms and conditions say I need to provide selfies but they are quoting their terms and conditions to me as contract law that I agreed to and saying they need selfies and a new passport as part of KYC and AML regulations.

No other institution I am with requires all of this only BullionVault. It is ridiculous.

The UK Government and banks are turning the UK into a Kafkaesque dystopia of regulations and catch 22 situations. But it seems BullionVault is going even further than the UK government, EU and the banks. I am starting to think that they are Ingsoc. I feel like I am talking to a brick wall with them.

I may have to complain about them to the Financial Ombudsman as I am being prevented from buying within my account and they have not credited my usual Pound Cost Averaging (PCA) deposit from the beginning of December despite giving them my new banking details in the middle of November which they did not action.

Is there anything I can ask a Solicitor or Notary to do for me legally in response to this to get them to sort their lives out? E.g. A strongly worded letter, some sort of Statutory declaration attesting to my identity? And how much would those one or two documents cost?

I really sympathise with you, but can see this from both sides. As Rockrabbit said, the security is a pain in the proverbial, but is there to protect you, and also them. They will be audited and have to show their security procedures are being followed. On the other hand, I dislike the way that these requests are often sent with no explanation, no name or contact details. The lack of a person's name in emails is becoming more widespread and really p*sses me off. Especially when they are asking for documents that could be used for I.D. fraud.

Are you sure that an old passport is still valid? I believe that the problem is the photo being out-of-date. Our youngest son couldn't use the e-gates last year and the lady at the desk said it was because the software couldn't recognise him from the photo. Luckily he was planning on renewing it anyway. For this reason, I would be wary about accepting an old passport.

If they will not accept a driving licence, I'd be inclined to bite the bullet and get a new passport. Peace of mind and less stress for another 10 years!

Whenever I am asked to take a photo of my passport or any document , I print out the date, reason for the request, name of bank, privacy warning etc in a very tiny font and stick the thin sliver of paper somewhere in the text, so that if they surface somewhere else, I would know where they're from.

But yes, all this is becoming a pain!

Steve

[scrumpyjack]

An old passport isn't valid and nor is a new one that has not been signed (my wife's was rejected by Hargreaves Lansdown for that reason).

It is understandable that they want a current valid UK passport to confirm identity as that would, I guess, give them protection from any negligence claims later on.

Far far worse things have happened in this whole 'know your client' saga!

[john10001]

My recent experience with Bullion Vault has left me perplexed and frustrated as they seem to have taken these precautions to extreme and seemingly unnecessary lengths.

While I understand the importance of ensuring I am who I say I am, the demands made by Bullion Vault extend beyond industry norms and standards. Despite possessing a recently expired, yet legally valid, UK-issued passport a document that should suffice as proof of identity, they insist on additional, arguably intrusive, measures.

The request for selfies, alongside a plethora of documents including utility bills, bank statements, and signed declarations, has proven not only burdensome but also raises concerns about the professionalism and rationale behind such demands. The individual managing my case has displayed a lack of courtesy and professionalism, failing to acknowledge documents previously submitted while continually shifting the goalposts of acceptability. A lot of the requests being made I consider beyond reasonable and normal industry standards, they are excessive, Orwellian and an invasion of privacy. Bullion Vault is the only financial organisation that has made all these excessive and Orwellian demands of me.

The irony lies in the assertion that bank statements and signatures are easily forged, a statement seemingly contradicted by their initial request for these documents. In contrast, a passport, a document acknowledged for its security features, remains dismissed as insufficient. The passport contains both my photo and signature. This begs the question: Why subject clients to this exhaustive process, especially when considering the potential manipulation of photos in photoshop, and videos, with deep fakes?

The insistence on re-submission of already provided documents, coupled with contradictory statements, has led me to question the motivations behind these stringent measures. The demand for updated identification at the cost of £90 for a new passport appears exorbitant and unnecessary, given that I am not planning on travel overseas, and identity is a constant and does not expire or transform between passport renewals.

In response to these frustrations, I have sent a comprehensive letter of complaint addressed to the CEO of Bullion Vault along with copies of all the documentation I already provided printed out and the email exchange with their employee. However, the lack of oversight by the UK regulator, the Financial Conduct Authority, leaves me with limited avenues for formal complaints.

Regrettably, this experience highlights a broader issue in the financial sector, where KYC and AML regulations, instead of targeting criminals, seemingly hinder the everyday operations of law-abiding citizens and businesses. As I contemplate seeking legal advice and potentially pursuing court action to rectify this situation, I am left pondering the evolving landscape of financial regulations in the UK, which, in my view, appears to be moving towards increased inconvenience for law-abiding citizens without necessarily enhancing security or deterring illicit activities.

I am still waiting to hear back from Bullion Vault and had been a happy client for the last 20 years until now. I sent the complaint last week by first class recorded delivery.

[john10001]

An old passport isn't valid and nor is a new one that has not been signed (my wife's was rejected by Hargreaves Lansdown for that reason).

It is understandable that they want a current valid UK passport to confirm identity as that would, I guess, give them protection from any negligence claims later on.

Far far worse things have happened in this whole 'know your client' saga!

This is incorrect. A passport even if it is expired is still legally a valid UK-issued passport and testament to your identity.

[john10001]

I'm having tremendous problems with BullionVault just to change my bank details they are asking me to do excessive juvenile requests and jump through hoops. The person I am dealing with there is really obnoxious and incompetent and he is the Operations Executive.

I have already provided all of the documentation they requested including statement from old bank, statement from new bank, utility bill to prove address, copy of passport, and a signed declaration.

But they are still not happy and now want me to send selfies and buy a new passport just to prove my identity at great cost.

It is not possible for my identity to change from one passport to the next.

As far as I am aware under UK law the expiration of my current passport doesn't change it's validity. It is still a valid UK-issued passport and testament to my identity. The expiration just means I can't use it to travel anymore until I get a new one. I don't have any plans on going overseas so have not needed to update it.

My statement is a printed signature. I don't have Adobe so am unable to actually do my proper signature and am not about to shelve out on expensive software to do so especially when this guy at BullionVault also said to me in writing that signatures are easy to fabricate yet he is still requesting this from me. I think he is a moron. I'm sorry but I can't think of any other word to describe him. Printed signatures and box ticking is standard practice in the UK for online financial stuff including loans and other agreements. So I don't see what the problem is? The statement I have provided to them is what they requested and the exact same statement I made in 2008 when I last changed my bank.

KYC and AML regulations do not require me to jump through hoops, provide selfies or respond to excessive privacy breaching juvenile requests. Nothing in their terms and conditions say I need to provide selfies but they are quoting their terms and conditions to me as contract law that I agreed to and saying they need selfies and a new passport as part of KYC and AML regulations.

No other institution I am with requires all of this only BullionVault. It is ridiculous.

The UK Government and banks are turning the UK into a Kafkaesque dystopia of regulations and catch 22 situations. But it seems BullionVault is going even further than the UK government, EU and the banks. I am starting to think that they are Ingsoc. I feel like I am talking to a brick wall with them.

I may have to complain about them to the Financial Ombudsman as I am being prevented from buying within my account and they have not credited my usual Pound Cost Averaging (PCA) deposit from the beginning of December despite giving them my new banking details in the middle of November which they did not action.

Is there anything I can ask a Solicitor or Notary to do for me legally in response to this to get them to sort their lives out? E.g. A strongly worded letter, some sort of Statutory declaration attesting to my identity? And how much would those one or two documents cost?

These onerous steps to change your bank account with BV are clearly set out when you open an account with them and are actually promoted as a security feature. They are designed to be as difficult as possible in order to protect your assets. If someone gets into your online account, it makes it very difficult for them to change your bank account details and withdraw your assets. This is a feature not a bug, and I think it is quite sensible. If you don't want this level of security, why not simply close your account?

The only individual who can get into my account is me. How else would I have been able to upload all these documents they have been requesting to them? Yet despite all this they still refuse to credit my account or update my bank details. I told them I was switching banks in the middle of November but they ignored all the documents and proof I provided. My old account is still listed in there but it was shut and closed down on 21st November. They have also not credited my account with the funds I deposited and have stolen them as far as I am concerned! So at the moment I am not actually able to add to any of my assets due to Bullion Vault going full Hitler and none of my papers satisfying them!

The documentation they are requesting now is beyond what was requested and was in the terms and conditions when I first signed up. It is excessive and beyond reasonable and industry norms.

[scrumpyjack]

An old passport isn't valid and nor is a new one that has not been signed (my wife's was rejected by Hargreaves Lansdown for that reason).

It is understandable that they want a current valid UK passport to confirm identity as that would, I guess, give them protection from any negligence claims later on.

Far far worse things have happened in this whole 'know your client' saga!

This is incorrect. A passport even if it is expired is still legally a valid UK-issued passport and testament to your identity.

"Can an expired passport be used as an ID? The short answer is no; an expired passport or photo ID is officially an invalid form of identification and cannot be used to verify identity when setting up a bank account, taking out a loan, buying a house or getting legal advice, for example. It can, however, be used to identify the person's country of origin or verify their age."

https://validient.com/kyc/can-an-expire ... %20example.

[gryffron]

"Can an expired passport be used as an ID? The short answer is no; an expired passport or photo ID is officially an invalid form of identification and cannot be used to verify identity when setting up a bank account, taking out a loan, buying a house or getting legal advice, for example. It can, however, be used to identify the person's country of origin or verify their age."
https://validient.com/kyc/can-an-expire ... %20example.

I don't know if this is correct or not. But I wouldn't generally consider the website of a commercial company attempting to sell an expensive alternative to be a valid reference.

[gryffron]

Further note: I note the "Validient" website is the first return on google for this question. Being the best match in google still doesn't make it definitive. Not like they are neutral or disinterested.

In fact, other sites seem very vague on the question. Indeed, the specific laws on identity checking are also surprisingly vague as to exactly HOW companies are supposed to verify your identity.

An alternative answer from a rather more neutral source, Citizens Advice: "you can’t use a document that’s expired unless it’s a British or Irish passport"

Gryff

[scrumpyjack]

Shelter says the passport must be 'current'.

https://england.shelter.org.uk/professi ... %20current.

[gryffron]

Shelter says the passport must be 'current'.
https://england.shelter.org.uk/professi ... %20current.

Yes, and many other organisations may have different requirements. I think you're probably right that most banks require a passport to be current. But not because the law says so. Because it doesn't. As I said, the law is notably vague. The law says that financial organisations must "Satisfy themselves as to the identity of their clients", nothing more. You seem to be trying very hard to convince us that your definition is "right". But there isn't any right answer. Even the banks themselves have complained about the lack of clear methodology provided by the law. They can be prosecuted if they get it wrong. But there is a distinct lack of govt guidance on how to do it right!

Gryff

[scrumpyjack]

Shelter says the passport must be 'current'.
https://england.shelter.org.uk/professi ... %20current.

Yes, and many other organisations may have different requirements. I think you're probably right that most banks require a passport to be current. But not because the law says so. Because it doesn't. As I said, the law is notably vague. The law says that financial organisations must "Satisfy themselves as to the identity of their clients", nothing more. You seem to be trying very hard to convince us that your definition is "right". But there isn't any right answer. Even the banks themselves have complained about the lack of clear methodology provided by the law. They can be prosecuted if they get it wrong. But there is a distinct lack of govt guidance on how to do it right!

Gryff

I'm not trying to convince anyone that 'my definition is right'. But I think it is not unreasonable for banks and financial institutions to have strict rules, like insisting on documents that are current. There have been a lot of problems with this whole 'know your client' stuff because it is all so vague and institutions vary significantly on what they require, some ludicrously so (Selftrade as I recall went completely OTT!). But insisting that their staff must be given certain documents (eg a passport) that have not gone past their expiry date is not OTT, I think.

[UncleEbenezer]

I had to prove my identity just a couple of weeks back (in connection with dealing with my late father's estate).

I produced a brand new passport, with some lighthearted comment on my previous one having expired this year. I was told the old one would have been acceptable.