The Evidence-Based Investor

Tag Archive: Chris Sier

1. How I got the City to come clean on investment costs — Chris Sier

   April 30, 2019 4:22 pm Comments Off on How I got the City to come clean on investment costs — Chris Sier

    

   Statistician, transparency campaigner and former policeman CHRIS SIER was recruited by the Financial Conduct Authority, the UK regulator, to work with asset managers on a template for disclosing investment fees and charges.

   To the surprise of many, they were able to produce a template that both sides were happy with. So, how did Dr Sier manage to persuade the industry to stop dragging its feet and start providing the relevant data? Is he optimistic that the trend towards greater transparency in asset management will continue? And how have his experiences influenced the way that he manages his own money?

   In the third and final part of our three-part interview, he openly discusses his work with the FCA — and expresses his genuine fear at the size of the pension savings gap.

    

   Given how outspoken you are on transparency, and how reluctant asset managers have been to reveal the total cost of investing, some were surprised that you managed to agree on a template for cost disclosure. How did you persuade asset managers to get on board?

   Let’s start with the phrase “total cost”. Bear in mind that the cost of using asset management as a function involves more than just asset managers. Only one of the layers of intermediation is asset management. Now, sometimes asset managers own different parts of the supply chain, because they’re vertically integrated, so yes, they get more money than just asset management fees. But the point is that it’s not just an asset managers’ problem.

   So that’s that’s one of the messages that you give to asset managers to just get on with providing the data. It could help you justify what you do by pointing out clearly and empirically that it’s not just you that’s taking money out of the kitty. You’re not the only slice of the pie. That’s the first thing.

   The major thing I learned at the FCA was how not to be so bloody angry with people saying no. As a policeman, I tended to get quite robust with people who said no to me, so I’m used to people coming round to my point of view. That’s just the nature of who I am. I’m an enforcer. But the one thing I had to be on the FCA panel was collaborative, because the standards were set not just by me, but by the asset owner community, with the help of the asset managers. Both sides of the fence participated.

   It was done in the full glare of the regulator, and my job was to be independent. What I had to do was reach an agreement about what was appropriate, and so the only tools that I could deploy were my expertise and the powers of persuasion to say it’s in your interests to get something that works for both of you.

   Ultimately, I succeeded because I managed to paint a vision of the future where asset managers accepted that it was a good thing for them for a number of reasons. I don’t think anybody disputes that it’s good for the asset owners. Some people may say “Oh, it’s so complicated, they’re going to be confused,” but that’s just rubbish, because you’re underestimating the ability of asset owners to learn things. That’s like telling your children they’re stupid;  it’s the one way in which you’re going to upset them and demean them. Asset owners are not stupid. They are extremely smart. And no one’s ever given them the opportunity to learn this stuff before.

    

   So it’s clearly in the interests of asset owners to have greater clarity on costs. But what are the incentives for asset managers to be more transparent? After all, they’ve done rather well out of being the opposite.

   With asset managers, you have to point out the business case to them, and there are four aspects to it.

   The first aspect is, “Now you have a standard, and it’s your standard. You’re going to be able to put your systems together once and for all to give data to this standard, and quite robustly say no to those who come fussing around you for data other than that standard. There are lots of organisations out there who ask asset managers for data, and say they need to have this data and that data. Asset managers can now say “No, the data has been agreed by the industry, by the FCA and by our clients, so you’ll have this data or you’ll have no data.” I think that’s an entirely reasonable thing to do. We’ve given them a standard, so they can do it once and once only.

   The second thing is, if you give data to this standard, you will be like-for-like comparable once and for all. So the example I will give is of an asset manager that charges an all-in fee, which includes not just their management costs, but everything that goes around the side like custody and legal and distribution and all that stuff. Then there’s an asset manager that only charges management fees but has additional costs that get drawn down by the fund( the other layers of intermediation effectively), that are added on that you don’t see.

   And so an asset manager that charges this much for all-in gets compared unfairly to one that only charges this much for the management fee, and this one is discarded because the other one hasn’t correctly presented its data.

   The third reason is, because we are getting the costs in the supply chain out into the open, asset managers now have something that they can look at and say, “Ah, that’s too expensive, and we can do something about it.” So one of the fundamental reasons for this transparency around costs is to get the asset management industry to take responsibility with innovating for the entire supply chain.

   And the final one is trust. Right now, the market is buying on trust. The simple trust metric now is is not what the data is, it’s whether you are willing to give data. And asset managers that say, for whatever reason, that they’re not going to give data soon learn that the client is boss. So I’ve seen asset managers fired for refusing to give data, or prevaricating, or not giving data in the format that’s required by their clients. Trust is pretty much the most important purchasing signal that you can have in any market, but it’s most important in financial services.

    

   Have your experiences of the asset management influenced how you invest your own money?

   I don’t even think of myself as having a risk profile. So, the classic thing that someone asks is, “What’s your risk profile? High risk? Low risk?” I don’t even think of that. What I say to myself is, “I want the majority of my money to be somewhere safe. I don’t want somebody else to take risk for me, I’ll take my own risk.” That’s probably the safest place to start. That means that most of my money goes into simple things — tracker funds, that kind of thing — because I don’t want to have to go through the complexity of dealing with complex decision-making for the vast majority of my money. I want it to be simple.

   If I ask myself, “What is the amount of money that I am willing to lose without ever having a chance of getting it back?”, that amount of money is very small, frankly. So, 5%, 4%… whatever the number is. I never look at the return. It’s all about my capacity for loss. That, to me, is a very personal thing. I think everyone’s different. Some people like to gamble. They like to put their money and think of the potential upside. I don’t think of that. I think about what my capacity for loss is, and anything that isn’t a capacity for loss has to be safe — somewhere that’s not going to have much downside risk. It may not have much upside performance, but whatever upside performance it has has to be linked to inflation. That’s kind of where I’m at.

   What that means is, if I am going to do an equation around capacity for loss, then I want to be the one who was responsible for that loss. I don’t want to give that to somebody else. So I stick that portion of my money into direct investments as an angel investor. Now, I’m fortunate that my role has put me in quite a lot of contact with start-ups that are doing interesting things. So it’s kind of a fun thing, but I’m governed by my capacity for loss, which means I don’t have much to invest.

   So how do I decide where to put that money? The answer is very, very simple for me. It’s about trust. I’ve worked with a lot of asset managers for the past 11 years, and what I know is that I only want to give my money to people that I trust. And there aren’t many of those, because trust has to be won as opposed to me giving it away for free. If they’re willing to give data, it means they’re not frightened about the consequences and that’s got to be a good thing. But there are very few organisations that have given me the opportunity to learn enough about them that I trust them. There’s only one really passive fund manager, and one active fund manager that I ever select when I’m looking at my fund selections, and I’m not going to name them, because I think that would be unfair.

    

   Much has been achieved in the past couple of years in terms of cost transparency in the UK. How hopeful are you that we’ve turned a corner?

   I think we have turned a corner because I think we’ve found a way of talking to asset managers, and the market is also right for them. I think there has to be a moment in time when people realise the game is up. You can no longer say no. Now, I’m not saying that asset managers said no because they were cynically trying to hide the data; but, in terms of their core business, clawing through your data systems and finding the answers to peoples’ questions has got to be low down on their hierarchy of needs.

   Now what’s happened is that the clients — largely the institutional investors — have changed their tune, and they’re saying, “Actually, it is about trust. And if you’re not going to give us your data, then how can we trust you? We might go and choose somebody else who is willing to give us data.”

   So there’s been a simple switch in the minds of the institutional investor to ask, “Are you going to give us data? No, then we’re going to find a way of removing you from our portfolio.” That has shifted the balance of power back to the institutional investor, and forced asset managers to admit that they have to give data.

   So now we have a standard, a standard they agree on, and we have a shift in the understanding of who’s in control. With those two things having happened, I’m very optimistic that we can sort this thing out. It’ll be to the benefit of everybody.  Nobody wants to work with a dishonest asset manager, and no one wants that in the market place… the FCA doesn’t, I don’t, you don’t, no one does. So, finding a way to force that transparency and honesty onto the marketplace was the most important thing, and it has now happened. Have we solved the problem? Time will tell, but I’m very optimistic.

    

   One of the benefits of transparency and genuine competition will presumably be lower fees and charges, and better investor outcomes. But most people in UK and other developed countries are simply not saving enough, are they?

   I think the problem we have is that what people expect to get, and what they will actually get when it comes to the time they retire, will be vastly different. That’s going to be a source of massive discontent, and also a massive problem for the government. It has to be, because it means they’re going to be relying on state benefits to be able to survive.

   It’s like a two-order problem. You’ve got to get them to start thinking about what it is they want to have when they retire, and then you’ve got to educate them about what it is that they actually need to do to get there from the point in life that they are, in the light of potential unemployment and wage deflation, or low wage inflation.

   I just think there’s a mismatch in expectations and it’s terrifying, because I’m mismatched myself and I’m supposed to be one of the clever ones. It really scares me.

    

   Missed the rest of our interview with Chris Sier? Catch up here:

   Part 1: The ex-policeman trying to solve the investment cost riddle

   Part 2: See the difference that saving 1% in costs can make

    

2. See the difference that saving 1% in costs can make

   April 17, 2019 8:04 pm Comments Off on See the difference that saving 1% in costs can make

    

   What sort of impact do fees and charges have on the long-term value of our investments? And how can investors ensure that their financial adviser really understands how the costs add up?

   In Part 2 of this three-part interview, the London-based statistician and financial transparency campaigner CHRIS SIER explains why cutting just one per cent from the cost of investing could potentially double the size of your retirement pot. He also points out the warning signs to look out for that might mean you need to change your adviser.

    

   Chris, explain the difference between explicit investment costs and implicit costs. Why is it important to factor in both when calculating the cost of investing?

   Explicit charges are easy. You know how much you’re going to pay, right? So you walk into a shop and you buy a fridge; and the fridge is £200. You shell out £200, your wallet is lighter by £200, and you can see the impact. The implicit cost of a fridge is its running cost. If you’re smart and if you care about the environment, you factor into your purchasing decision how much electricity it’s going to use. Also, you see what the reviews from other customers are like. Will you need to pay for lots of repairs? These are all the implicit costs — things that you don’t pay for upfront, but are like the running costs.

   It’s like buying a car, and choosing a hybrid car in an environment of rapidly inflating petrol cost. It might influence your decision to buy something which is more efficient with petrol if you realise that petrol’s going to be expensive in the future. That’s an implicit cost. The explicit cost is the cost of the car itself.

   So in asset management, and in the world of pension funds, the explicit cost is the fact that you pay an asset manager (x) pounds per year. This is often expressed as a percentage of how much money they’re running for you — 50 basis points, 20 basis points, 2% or whatever the number is. You know what it’s going to be. The implicit costs are the costs that are incurred as a result of the function that you’ve engaged with. So they have to buy and sell stuff, and because they’re buying and selling stuff, it’s very hard for anyone to predict what that cost is going to be. Sometimes that buying and selling has an explicit component — so, every time you buy and sell, it’s going to cost you 2p or 20p or whatever it may be — but sometimes the price of the thing you’re buying varies according to what it is you’re buying and the model by which you buy it. That’s an implicit cost. You don’t know, really, how much it’s going to be. It’s very hard to estimate it. You maybe know it after the fact, but you can’t predict it.

   As you say, transaction costs can be very significant, and yet you don’t know, in advance, how often your manager is going to trade. What can you do to keep the cost down?

   A question to ask when you’re choosing an asset manager is, Do they trade a lot? So my father, as a fund manager, always used to say you can bleed performance by overtrading, so he was very cautious and never really traded. So he would buy and he would hold, and he would be very, very cautious about the things he bought. That was his model, but others don’t have that point of view. They tend to trade upon the volatility of the price — “There’s an opportunity, we should sell it, make some money,”or “We should buy it because it’s cheap and then we should sell it later on.” Those are two very different approaches and you need to be aware, when you buy manager A versus manager B, that one is not going to have lots of trading costs and one might well have because that’s their model. There are a number of different models, but those are two of the typical ones.

   We often hear about the benefits of compounding returns, but it obviously works in the same way with costs as well. Could you explain how paying a seemingly modest percentage each year can have a big impact over time?

   Probably the best way to answer this is to think about the fact that a cost is a negative performance, because it represents the other side of the coin. In this world where people are paid by the assets you own, if you’re paying out from those assets, it means you’re not getting a return. So, in theory, the less you pay, the more return, or surplus return, there is. And there’s evidence from Morningstar that shows that, for a given fund type, the lowest cost yields the highest quartile performance.

   That doesn’t mean you should always pick cheap. What it means is that if you’re going to pick a fund of whatever type, statistically you’re more likely to get a better return from one that charges you less, because it’s two sides of the same coin. By the same token therefore, if you can claw back some of that cost, it automatically goes on the performance sheet.

   So, this is where the issue of negotiation with your asset manager comes in. If you are able, you can go to your asset manager one year to the next and say: “I’m not paying you (x), I’m paying you 20% less than (x),” and if you recoup that 20%, you can stick it on as a performance fee.”

   Now the impact of that can be considerable. If you reduce the total cost from 3-4% to 2-3%, you’re adding 1% on to the performance of the fund — each year, every year. So, think about it from the point of view of just adding up without compounding. Over a 47-year lifespan, 3% taken down to 2% means that you’ve got 1% of extra performance incrementally each year. So at the end of 47 years, you’ve got 47 years of uplift in performance. But because the funds are growing — because they’re compounding, because each year they’re growing faster than the money you put in — 1% doesn’t become 47%. 1% could become 100%. It depends on the growth you apply, but if you reduce your costs by 1%, and increase your performance by 1%, you’re going to uplift the value of your fund by a huge amount. You could double the size of it.

   Now, that’s an extreme example, because I don’t think you’re going to get 1% back. But you may get ten basis points, or 0.1%, and the same thing applies. Every single penny of cost that you reduce on a like-for-like basis becomes a penny of performance, and it adds up year on year on year, all the way to the end of the lifespan of the product. And it grows faster than just the simple arithmetic addition; it has a geometric progression factored into it, too. It’s so important to watch your costs.

   The cost of investing is clearly a minefield, and some of the data is hard to find. You have a PhD in statistics and, after years of trying, only now are you starting to work out the total cost. How do investors be sure that their financial adviser properly understands this issue?

   If you ask them for a schedule of costs — “Please could you give me a breakdown?” — there are some things that they should definitely talk about. They should talk about more than their own costs, They should talk about explicit versus implicit cost, the platform costs and the costs of the underlying funds in which the platform is investing.

   So, if you’ve got a pension platform that offers you a choice of products, you should definitely be looking for somebody who understands that it’s not just the platform costs you’re paying. Underneath that you’ve got the cost of the funds and the asset managers. Advisers should talk about more than the AMC and the TER; they should talk about the OCF. They should be able to explain to you about MiFID and slippage costs. These are all the things that people should be aware of now.

   If you’ve got someone who doesn’t get into that detail, then you probably want to go and find somebody else. It means they don’t have the required level of understanding. I have to be fair, it’s a complex issue. But you’re paying them to deal with that complexity, aren’t you? So you should have a rational expectation that they understand this stuff.

    

   Did you miss Part 1 of this interview with Chris Sier? You can catch up here:

   The ex-policeman trying to solve the investment cost riddle

3. The ex-policeman trying to solve the investment cost riddle

   April 4, 2019 6:43 pm Comments Off on The ex-policeman trying to solve the investment cost riddle

    

   Few people have done more to raise awareness of the cost of investing than CHRIS SIER. A trained statistician and former Edinburgh policeman, he’s spent more than a decade trying to calculate how much investors pay in fees and charges.

   He’s already shown how the true amount is typically two or three times the explicit cost. But such is the complexity of the asset management industry and the different layers of intermediation involved that he’s still trying to calculate the exact figures.

   In the first part of a three-part interview, Chris talks about his background and explains why it’s become his mission to get to the bottom of how much investors really pay.

    

   Chris, tell us about your background and how you first became interested in the cost of investing.

   I’ve actually got a lot of history in the world of asset management. My father was a fund manager, and then a pension fund manager, for his whole career.

   I did my degree, my PhD, and then ended up in the police with a kind of strong vocational mindset. It started me asking questions about what is the value of the job you do. And it really came home to me when I left the police after seven years and came to the City of London.

   My first job was as a derivatives analyst, and my salary doubled overnight for a fraction of the responsibility and I couldn’t get it! As a police officer, you’re dealing with people’s lives, you’re dealing with some really horrible things, and seeing some terrible things, and you have to bear the emotional burden of those, and you get paid a very small amount of money. Then I came to the City, and I had no line responsibility, no people to look after, no people to care about and was just fiddling with numbers, and my salary nearly doubled overnight.

   And my question was, Where does the money come from? And how does it fuel everything that we see outside the window? All the buildings and all the companies and all the people are funded somehow. And it got me thinking about where the money came from, and I reached the conclusion that it came from the consumer, and the consumer pays for everything. That’s been my journey since then — figuring out how much the consumer pays.

   What did you discover when you started to look into how much consumers actually pay to invest in different products? 

   The kind of quantitative part of this started when I had been in the City for a number of years. I’d been a management consultant: my job had been to work with asset managers to help them put their operations together. In industry jargon, I had been part of the process of manufacturing funds. I knew how funds were manufactured, but I’d never thought about the other part of the equation, which is how they reach the consumer.

   Then I moved into this quasi-governmental role, and the question which I asked myself was, How much does it cost the consumer to invest? And I did a project, back in 2008. I wrote a report for the Government Office for Science and it was distributed to the Treasury, and to the FSA at the time. It concluded that, when one looked in the round, the cost of investing in just a simple simple retail financial product, was some two or three times what the consumer was told when they bought it.

   So bluntly speaking, the annual management charge was 1%, but if you added up all the costs of all the intermediaries, I reached the conclusion that it could be 3 to 4%. And so the purchasing decision that the consumer made was based upon only a third of the information they needed to make an adequate judgment. And I felt this was wrong. I don’t think there is a single purchasing decision that we make in real life that happens without us first turning the tab over and looking at the price. Yet you can’t do that for a financial product; and I mean that for most financial products, but I definitely mean it for fund management.

   Explain in simple terms the different layers of intermediation involved in asset management. 

   The other thing we did for the project I mentioned just now was that we calculated the layers of intermediaries there were between the consumer and the marketplace, and we counted 16 layers of intermediation. There are a whole bunch of things that the consumer won’t recognise. They recognise a fund manager, or maybe if they don’t recognise the fund manager, they’ll recognise the platform or the distributor. Or in the pension fund world, they’ll recognise their pension fund provider. But they probably don’t know about things like custodians and brokers and transfer agents and all of these many, many intermediaries that exist in the process that actually, every time the money touches them and passes through their hands, they get paid for.

   Now I’m not saying that that’s wrong for people to get paid. But what I am saying is that the industry could be so much more efficient. Every layer of intermediation that sits in that journey takes some money, and the classic issue is that someone invents a new way of doing something and slips themselves between two layers of intermediation. Let’s say a new piece of regulatory policy requires people to check data between themselves, and a company springs up that that helps to do that. When they slip into that process, they add a layer of cost. The people on either side of that organisation, on either side of that extra layer, will say, “Well, actually, our costs have gone up because we have to pay this organisation, so therefore we have to charge more.” And because they charge more, the other people adjacent to them, either side of them, go: “Actually, our costs have gone up because we now pay you more, so our charges have to go up.” And so what happens is, the industry just gets bigger and bigger and bigger, until you reach a point where the cost goes up for the consumer.

   So what we’ve built up over time is an industry that is immensely complex —16 layers for a simple equity ISA at the time (there are more now). Think about it from the point of view of a pension fund where you have lots and lots of different products. And they’re not all equities. Some are fixed income, some are property, some are private equity, some are hedge funds. And that complexity needs to be managed by lots of other layers of intermediation. So you end up with something that you cannot describe the complexity or cost of. But it exists. And the point is, how do you sort it out?

   How has this situation has been allowed to develop? Has there been an element of deception or conspiracy? Or has it just been down to incentives and human nature?

   You know, proving a conspiracy is impossible, and I really don’t think it’s worked out that way. I just think that what happens is is that people feel so far away from the ultimate purchaser, they don’t recognise them as the customer. If you go and talk to an asset manager and you ask them who their customers are, they’ll say it’s an institutional investor. Not a consumer, but an institutional investor. Another way of expressing that is a pension fund: pension funds serve people, but an asset manager doesn’t recognise the consumer. If you ask a custodian, Who’s your customer?, they’ll say an institutional investor, or another bank, or an asset manager. Will they recognise the consumer? No.

   But we’ve already pointed out that everything is funded by the consumer. What I think needs to happen to sort it out is a recognition that all of the organisations in the middle ultimately report to the consumer. It’s when you recognise that that you start to do things for the consumer, not for the companies that sit alongside you.

   So, is there any kind of conspiracy? No, I don’t think so. Has it built up over time just because people keep doing extra things to be helpful for their clients? Yes. Is there an inertia that stops it from being sorted out? Well, yes. Because you make money if you sit in the middle. If the whole thing is sorted out end-to-end, then you’re gone, right? So where’s the incentive to sort it out? Everyone’s really comfortable at the moment. Everybody makes lots of money. No one recognises the impact of that, other than the fact that they have a viable company that pays their employees well and pays tax.

   But what people don’t recognise is that every layer of cost impacts the performance of the assets held by the consumer, and so we need either someone or something, some entity, to take responsibility for that journey and the significant economic impact that a poor performing pension environment has on the UK economy at the level of the consumer.

   That’s interesting, because we’re often told how crucial the financial sector is to the UK economy. We don’t hear about the harm it does.

   All the intermediaries pay tax. The government loves tax, and it’s easy to tax individuals who earn lots of money. But the journey impacts the consumer, not just wealthy people. It impacts everybody in that process. And it’s much harder and less tangible to deal with a 47-year-outcome than it is to deal with tax next year from a wealthy person who works in the middle office of an asset manager.

   So, it’s a really, really tough thing to sort out. I’m not sure I have the answers. What I know is that, if we can express clearly how much it costs end-to-end, we can demonstrate to people just how much impact they have on the consumer and that’s kind of my goal. Only then can we make some decisions about what we do about it.

    

   Next time: In Part 2 of this interview, Chris Sier explains what investors can learn from the work that he’s done.

    

    

4. BBC reveals scale of hidden costs in UK public pensions

   December 13, 2018 6:25 pm Comments Off on BBC reveals scale of hidden costs in UK public pensions

    

   All around the world, public pensions schemes are finally working out how much they’ve been paying in investment fees and charges over the years — and many trustees are horrified.

   There was an excellent edition of the Money Box programme on BBC Radio 4 yesterday about public pensions in the UK.

   Reporter Lesley Curwen explained how investment costs are rather like an iceberg. The explicit cost, effectively the annual management charge, is only part of the total. Underneath are a whole range of implicit costs — transaction charges, custody charges, brokerage fees, foreign exchange fees and so on — some of which are very hard to identify.

   The most startling revelation on the programme came from Jeff Houston, Secretary to the Local Government Pension Scheme Advisory Board. He explained how, in 2015, the West Midlands Public fund conducted a “deep dive” to find out how much their fees and charges added up to.

   “They thought they were paying £11 million a year,” he said. “They were actually paying nearly £90 million a year. Since that time they have reduced that by £30 million. Local authorities haven’t got £30 million they can just throw away.

   “In the Local Government Pension Scheme, we paid asset managers around £1 billion last year. That’s probably still not the full iceberg. This is public money. Local authorities can’t afford not to look at this.”

   Also interviewed was Dr Chris Sier from Newcastle University Business School. Sier is a former policeman who carried out detailed forensic work on pension costs more than a decade ago.

   “(I started by looking at) a simple equity ISA,” he recalled, “and I found 16 layers of intermediation, (or 16) companies sitting between you and investing your money. Every one of those companies takes a piece of the pie as it passes through. The total it added up to was over 3.5%.”

   Dr Sier was so appalled at what he found that he started to ask asset management companies for information on exactly how much consumers were paying.

   “When I asked for it,” he said, “the rebuttal I had initially was, Don’t ask, you’re damaging a fragile savings culture. They weren’t happy with me at all.”

   Of course, asset managers in the UK and the rest of Europe are now required to provide a figure for total fees and charges under the EU directive MiFID II, although the directive doesn’t include workplace pensions or pensions provided by insurers.

   Transparency campaigner Gina Miller told the programme how, in the UK at least, MiFID II is being largely flouted and how the regulator, the Financial conduct Authority is showing a dusting lack of urgency in forcing firms to comply.

   “It is an utter disgrace,” said Miller. “The law came in on 3rd January, but we did an audit and found that over 90% of the industry is not complying with this law.

   “The only thing that investors can do is to write directly to the FCA and say, why are you not protecting me? One of your overarching principles is to ensure that customers are treated fairly.”

   If you’re in the UK, you can listen to Lesley Curwen’s exploration of hidden charges here:

   Hidden costs and charges, Money Box, BBC Radio 4, 12th December 2018