Written Testimony for the APPG on Investment Fraud & Fairer Financial Services
Submitted by: Steve Conley, Founder – Academy of Life Planning (AoLP) & Get SAFE
Date: 13 November 2025
1. Background
I am the Founder of the Academy of Life Planning (AoLP), an international network of non-intermediating Holistic Wealth Planners, and the Founder of Get SAFE (Support After Financial Exploitation), a charitable initiative supporting victims of financial exploitation through AI-assisted recovery and citizen investigation.
My background is in mainstream banking. I served as Head of Investments at HSBC, chaired the British Bancassurance Association’s Steering Group during the RDR transition, and held senior posts at RBS Group and Santander. After witnessing first-hand, the structural incentives that produced mis-selling and consumer harm, I left the industry to build alternative, trustworthy systems rooted in transparency and autonomy.
AoLP and Get SAFE work with victims of investment fraud, pension abuse, regulated misconduct, and banking malpractice. We help people rebuild financial stability, emotional resilience, and practical pathways to redress.
This submission reflects evidence gathered through direct casework, whistleblower contributions, citizen-led investigation, and independent analysis using AI.
2. The Structural Problem
2.1. Hopcroft and the Supreme Court’s Confirmation of Structural Untrustworthiness
The 2025 Supreme Court decision in Hopcroft & Anor v Close Brothers Ltd confirmed that:
- Credit brokers owe no fiduciary duty, and
- Hidden commissions may be lawful, undisclosed, and unaccountable.
This ruling does not merely reflect an isolated doctrinal issue — it exposes a systemic truth:
The intermediation architecture of UK retail finance is structurally untrustworthy by design.
For decades the system has relied on:
- Asymmetry of information
- Asymmetry of expertise
- Asymmetry of power
Consumers are expected to trust intermediaries who are legally permitted to conceal material conflicts. This is the opposite of a fiduciary system.
2.2. Consequences for Victims
Through AoLP and Get SAFE, we repeatedly see the same pattern:
- Individuals suffer catastrophic financial harm.
- They send hundreds of emotional emails to MPs, regulators, and journalists.
- Their cases are dismissed as “incoherent,” “unstructured,” or “not proportionately evidenced.”
- Vital signals become noise.
- Genuine harm goes unaddressed.
The system does not fail because consumers are irrational.
The system fails because its design ensures their voices are structurally discounted.
2.3. Evidence of systemic harm
Independent reports, whistleblower evidence, and parliamentary testimony presented to this APPG suggest:
- Large-scale hidden liabilities and concealed credit lines in SME lending
- Widespread mis-selling of swaps and structured products
- Asset-stripping in restructuring units
- Devastating mental health impacts, including thousands of avoidable suicides linked to financial distress
(attribution: investigative modelling; causation requires full parliamentary inquiry)
No credible national mechanism currently exists to assess or prevent these harms.
3. The Emerging Solution: Open, Independent AI
3.1. AI is now the dominant interface for financial guidance
Research by Lloyds Banking Group finds:
- 56% of UK adults used AI in the last 12 months to help manage money,
- Six in ten of those used ChatGPT.
More Britons now rely on AI for financial clarity than on traditional intermediaries.
This is not a future trend — it is already a structural reality.
3.2. Independent AI levels the field
AI now enables citizens to:
- Decode DSARs
- Interpret internal bank product codes
- Reconstruct destroyed timelines
- Spot omissions, contradictions, and concealment
- Understand complex credit structures
- Draft clear correspondence for regulators, MPs, and courts
For many victims, AI is the first tool that has ever allowed them to understand what happened to them.
It replaces confusion with comprehension.
3.3. Evidence: Citizen Investigators Are Exposing What the System Missed
Whistleblower reports such as BankConfidential outline:
- Hidden credit lines attached to loans and swaps
- Manufactured defaults
- Inflated LTVs
- Profit-from-distress business models
- Tens of billions in alleged wrongful extraction
(attribution: whistleblower and investigative estimates)
Citizen investigators have mapped their cases onto these patterns.
AI helped them read documents regulators never translated.
For the first time, structural misconduct is becoming machine-readable.
4. The New Ethical Risk: Closed, Captured AI
4.1. A turning point — and a danger
As citizens begin to use AI to expose systemic patterns of misconduct, major financial institutions have become intensely involved in “AI ethics” initiatives.
Some are now:
- Advising AI developers on “acceptable financial output”
- Seeking collaboration on “sector risk classifications”
- Offering to “co-design guardrails” around financial content
- Funding projects on fairness, bias, and discrimination in finance
On the surface, this appears responsible.
But the conflict of interest is stark:
AI can reveal systemic misconduct. Those implicated now seek to shape the rules that govern what AI is allowed to reveal.
This APPG must treat this as an urgent governance issue.
4.2. What closed AI could become
If banks and industry bodies dominate AI guardrail design, we may see:
- AI refusing to analyse DSARs
- AI avoiding commentary on mis-selling
- AI advising victims to “contact the bank directly”
- DSAR decoding labelled “legal advice” and suppressed
- Securitisation, derivatives, and hidden liabilities treated as “restricted content”
This is not theoretical.
Professional bodies have already expressed concern (anonymised) that large firms are developing exclusive, closed AI ecosystems to consolidate advantage and limit transparency.
4.3. Ethical AI vs Captured AI
The ACCA–CISI report AI Monitor: Shining a Light on Ethical Threats for Finance Professionals is an important contribution to the debate.
It identifies risks of bias, discrimination, and opacity.
It affirms that AI must be governed ethically.
AoLP fully supports this.
But ethical AI cannot become industry-owned AI.
True ethics require independence.
The distinction the APPG must recognise is:
Ethical AI
= AI that enhances transparency and empowers citizens.
Captured AI
= AI that protects institutional interests at the expense of the public.
5. Our Work: Structurally Trustworthy Empowerment Systems
5.1. AoLP: Non-intermediating planning professionals
AoLP trains planners to operate:
- Without product commissions
- Without hidden incentives
- Without intermediation conflicts
- With full transparency
We call this Structural Trustworthiness.
This model replaces dependency with autonomy.
5.2. Get SAFE: AI-assisted victim recovery & justice
Get SAFE helps victims:
- Organise evidence
- Decode DSARs
- Bundle documents
- Draft structured regulatory submissions
- Escalate cases effectively
- Rebuild financial stability and emotional resilience
Citizen investigators using AI through Get SAFE have already produced work of a quality once limited to specialist litigators — at zero cost to the taxpayer.
This assists MPs, journalists, and regulators by transforming chaotic, emotional emails into clear, evidence-based submissions.
6. The Ethical Imperative
Some say AI “has the morals of a calculator.”
Our position:
The morals of an enabling calculator outperform the outcomes of conflicted intermediation systems.
AI does not lie, conceal, deflect, or profit from distress.
When co-piloted by ethical, conflict-free professionals, AI becomes a conduit for truth and comprehension.
If Parliament wants justice, AI must remain open.
7. Recommendations to Parliament
7.1. Statutory Protection for Independent AI Use
Parliament should legislate to:
- Protect the right of individuals to use AI to analyse their own financial data
- Prevent monopolistic control of financial AI guardrails
- Require transparency about any financial-sector influence on AI governance
7.2. Independent Public-Interest AI Governance
Establish an AI governance body:
- Independent of financial institutions
- Transparent in funding and oversight
- Focused on the public interest and structural trust
7.3. Inquiry into Harm and Avoidable Suicides
Commission a parliamentary inquiry into:
- The mental health impacts of systemic financial misconduct
- Whether regulatory structures contributed to avoidable deaths
7.4. Recognition of Structural Trustworthiness
Adopt structural trustworthiness as a core test:
Systems should be judged not by stated intent, but by measurable outcomes for consumers.
7.5. Support Citizen Investigators
Back initiatives like Get SAFE that:
- Lower the administrative burden on Parliament
- Improve the quality of submissions
- Reduce harm
- Produce justice at scale
8. Closing Statement
The UK faces a choice.
One path leads to captured AI, closed governance, and a return to institutional impunity.
The old asymmetries will simply be automated.
The other leads to open AI, structural trustworthiness, and a justice system finally able to hear the people it was built to serve.
This APPG stands at the frontier of that choice.
I urge Parliament to safeguard the tools that empower the public, not the tools that shield institutions.
9. Contact
Steve Conley
Founder, Academy of Life Planning & Get SAFE
📍 9 Franklin Way, Spilsby, Lincolnshire, PE23 5GG
📧 steve.conley@aolp.co.uk
📞 +44 (0)7850 102070
🌐 www.academyoflifeplanning.com
10. Call to Action — Help Us Build the UK’s First Citizen-Led Justice & Recovery Network
Every year, thousands across the UK lose their savings, pensions, and peace of mind to corporate financial exploitation — and are left to face the aftermath alone.
Get SAFE (Support After Financial Exploitation) exists to change that.
We’re creating a national lifeline for victims — offering free emotional recovery, life-planning, and justice support through our Fellowship, Witnessing Service, and Citizen Investigator training.
We’re now raising £20,000 to:
✅ Register Get SAFE as a Charity (CIO)
✅ Build our website, CRM, and outreach platform
✅ Fund our first year of free support and recovery programmes
Every £50 donation provides a bursary for one survivor — giving access to the tools, training, and community needed to rebuild life and pursue justice with confidence.
Your contribution doesn’t just fund a project — it fuels a movement.
Support the Crowdfunder today and help us rebuild lives and restore justice.
🌐 Join us at: http://www.aolp.info/getsafe
📧 steve.conley@aolp.co.uk | 📞 +44 (0)7850 102070
Academy of Life Planning 