On Enhancement

We have a bevy of unusual appeals in this morning, mainly a bit too specific to discuss here. 2 of them have a wider interest element.

The 3rd is another CDS enhancement argument. It is a bit of a mess as we are at the PoP stage and the firms representations, the LSC’s assessment and the ICA determination are all a bit too vague to allow detailed consideration of a point of general principal. (We have a standard way round this however).

We think it is essential that in the initial CDS7 you make very clear which of the Broudie factors justify enhancement and how they do so – rather than asserting that it is a “complex case” in however much detail. (We have some pro-formas you can have on request). This, at least, should lead the ICA to provide a detailed determination against which a PoP application can be considered.

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