How UK borrowers’ payments are routed through a web of orphan companies in London and offshore SPVs — tax-written to minimise leakage and shield investors from insolvency, while borrowers are kept in the dark
Banks tell customers: “We’re still your lender.” Behind the scenes the credit has already been sliced, shipped and securitised. The industry manual is blunt: loans become tradable cashflows; SPVs (often orphaned and domiciled in tax-friendly hubs) take the risk; investors are insulated; and borrowers rarely know their payment streams no longer belong to the lender’s balance sheet. This is not theory — it is how modern UK securitisation is engineered.
Why read the exploiters’ own manual?
The Global Guide to Legal Issues in Securitisation wasn’t written for citizens — it was written for the institutions now dominating the private-credit market. It teaches investors how to turn other people’s debts into tax-efficient securities, how to isolate risk inside “bankruptcy-remote” shells, and how to do it all under a cloak of legal compliance. For Citizen Investigators caught up in the private-credit scandal, that makes it invaluable. Understanding how lenders design these structures reveals why accountability vanishes when harm occurs, why regulators struggle to intervene, and how borrowers’ payments are channelled through orphan companies and offshore conduits. Reading the investors’ playbook lets the public see the system from the inside — not to imitate it, but to expose it, challenge it, and reclaim the transparency and justice it hides.
Download The Playbook: A Global Guide to Legal Issues in Securtitisation here.
1. What the playbook does
- Converts ordinary loans into marketable securities. Illiquid retail and SME debt is repackaged into tradable notes so banks can raise capital from investors rather than funding from deposits.
- Creates bankruptcy-remote shells. Orphan SPVs and “limited-recourse” documentation legally isolate assets from the originator’s creditors. That legal insulation is a core design feature.
- Routes value through tax-efficient jurisdictions. Ireland, Luxembourg and the Netherlands are standard domiciles for SPVs buying English assets — chosen for treaty and tax advantages that reduce or eliminate UK withholding and tax friction.
- Keeps borrowers unaware. Instead of serving notice of assignment (which would inform the borrower), the market commonly uses equitable assignments so customers keep paying “their bank” while cash is redirected behind the curtain.
2. The legal and fiscal mechanics (plain English)
- True sale vs synthetic transfer. A true sale transfers legal risk; synthetic structures merely shift economic risk via swaps or guarantees. Both are tools in the toolbox — used depending on accounting, tax and regulatory aims.
- Equitable assignment = silence. Where assignments are equitable (beneficial interest transferred but legal title retained), borrowers are rarely told. That keeps customer relations smooth — but it also hides who ultimately benefits from repayments.
- Tax safe harbour for securitisation vehicles. UK securitisation tax rules and parallel offshore regimes are structured to make SPVs effectively tax-neutral, preserving investor yields and encouraging the use of specific domiciles. This is deliberate policy engineering, not accidental loopholes.
3. The harm: why this matters for ordinary people
- Borrowers think they’re dealing with a single bank — but the economic interest in their loan may be held by remote investors who prioritise repayment over forbearance.
- Profit extraction mechanisms (discounts, excess spread, over-collateralisation) can mean the originator or arrangers capture value while borrowers still shoulder full contractual obligations.
- When insolvency, mis-selling or complaints arise, accountability is blurred across jurisdictions, trustees, servicers and orphaned SPVs — making redress slow, costly and opaque.
4. What Citizen Investigators can do — a practical playbook
The Baker McKenzie guide is a technical blueprint. Use it as evidence, and follow these steps:
A. Identify the likely SPV & route
- Search prospectus and listing registers (Euronext Dublin, Luxembourg Exchange, London/Euronext) for your lender’s “Funding”, “Series” or “Funding plc/DAC/S.A.” names. Many SPVs follow the pattern
BankName Funding [Year]-[Series].
B. Ask the right DSAR / pre-action questions (use this template)
Please provide:
- Copies of any sale/assignment agreements, transfer deeds, trust deeds, prospectus or offering circulars relating to my loan/account number [X].
- Copies of any notices of assignment served (or details of why none were served).
- The identity, domicile and ultimate beneficial ownership of any special purpose vehicle, trustee, or fund that has a beneficial interest in my loan, and the date(s) of any transfer.
- Details of any servicing, repurchase (put-back) or indemnity arrangements linked to my loan.
(If refused, point out equitable assignment is common market practice — cite the industry guide — and request the documents as necessary for your complaint.)
C. Read the prospectus for red flags
- Look for repurchase/put-back clauses, originator guarantees, clean-up calls, and subordination language. These reveal whether the “sale” really transferred risk or merely funded the originator.
D. Map the cashflow
- Trace who receives interest and residual payments, and whether those receipts benefit an offshore SPV or the originator. If taxes are unusually low or there is treaty language in the prospectus, you’ve found a likely offshore route.
E. Use the report as evidence
- Quote the guide in letters to banks, FCA complaints, MPs and journalists: this is the market’s own description of the model. It strengthens the case that the practice is systemic, not anecdotal.
5. Policy asks AoLP will push for
- Mandatory public registers showing when consumer loans are used in securitisations and naming the SPV/beneficial owner.
- Automatic borrower notification of assignment and the rights that flow with it.
- Transparency requirements in prospectuses and servicing agreements when consumer loans are in the pool (loan-level disclosure, redaction-limited).
- A tax-fairness review of securitisation special regimes to ensure public revenue and consumer protections are not undermined in the name of market efficiency.
6. Final word
Securitisation began as a useful tool to extend credit and allocate risk. Over time it has evolved into a sophisticated machine that moves capital — and shields it — across borders. The Baker McKenzie guide doesn’t hide this; it documents it. That documentation is our starting point: an evidence base to expose, explain and reform. Get SAFE’s Citizen Investigator playbook will use these same instructions — but in the service of victims and citizens, not extractors.
SECURITISATION 101 FOR BORROWERS
How your loan can be sold, sliced and hidden in plain sight
1. What securitisation means
Securitisation turns ordinary loans (like mortgages or credit cards) into tradeable investments.
Your monthly payments become part of a large pool of loans, packaged and sold to investors through a Special Purpose Vehicle (SPV) — a company created purely to hold those loans and issue bonds backed by them.
Think of it as:
You → Bank → SPV → Investors.
2. What actually happens
| Step | Process | What you see | What really happens |
|---|---|---|---|
| 1 | You borrow from a bank. | You owe the bank. | The bank plans to sell your loan. |
| 2 | Bank sells the rights to your payments. | No change to your statements. | Ownership moves to an SPV (often offshore). |
| 3 | SPV raises money from investors. | You keep paying the bank. | Your payments flow through trustees to investors. |
| 4 | Profits are extracted via “excess spread.” | You pay as agreed. | Originator and arrangers take margins and fees. |
3. Why SPVs are used
- Isolation: keeps assets “bankruptcy-remote” if the bank collapses.
- Tax efficiency: Ireland, Luxembourg and the Netherlands offer near-zero tax regimes for these entities.
- Opacity: the borrower is usually not told because assignments are “equitable” (beneficial ownership transfers but legal title stays with the bank).
4. Signs your loan may be securitised
- Your lender has “Funding,” “Securities,” “Capital,” or “2020-1 PLC/DAC” companies listed online.
- Prospectuses on Euronext Dublin, Luxembourg Stock Exchange, or London Stock Exchange mention your bank’s name.
- Servicing or correspondence suddenly changes hands.
- Bank accounts for repayments are in the name of a trustee or servicing agent, not the original lender.
5. What you can ask
Under the Data Protection Act and UK GDPR, you have the right to know who holds your data and on what legal basis.
Send a Data Subject Access Request (DSAR) asking for:
- Copies of any sale, assignment or transfer agreements relating to your account.
- Names, jurisdictions, and contact details of any SPVs or trustees with a beneficial interest.
- Copies of any notices of assignment prepared or served.
- Details of any guarantees, repurchase, or servicing arrangements affecting your loan.
6. Why it matters
- Accountability: hidden transfers blur who is responsible if things go wrong.
- Fairness: investors, not your local bank, may control repayment behaviour and hardship decisions.
- Transparency: borrowers are excluded from information that regulators and investors receive routinely.
7. How to trace it
- Search online for your lender + “Funding plc/DAC/S.A.”
- Look in the Euronext Dublin or Luxembourg Stock Exchange prospectus libraries.
- Match pool details (loan type, region, origination year) with your own loan.
- Save documents as evidence for complaints or media investigations.
8. In plain words
“Securitisation” means your loan may have been sold to an invisible owner.
The law allows this — but it also gives you the right to ask who profits from your payments.
Transparency is not a privilege; it’s your protection.
Produced by the Academy of Life Planning (AoLP) – empowering citizens to understand where their money really goes.
Join the movement for structural trust.
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Get SAFE: A Fellowship for Those Walking Through Fire
Get SAFE is becoming what people are desperately searching for —
a structured, ethical, trauma-informed community for:
- victims of financial exploitation
- whistleblowers
- bereaved families
- citizen investigators
- advocates and moral leaders
The Fellowship is simple but profound:
We gather to recover agency, share truth, deepen courage, and support one another in the long path from harm to justice.
We are not aligned with any regulator, political system, or institution.
Our strength is our independence.
People came alive when they heard it:
“A Fellowship of truth, justice, and recovery — not a bureaucracy.”
“A place where victims are finally believed.”
“A community rooted in courage, not compliance.”
And because of the AI frameworks we’ve introduced, this Fellowship is not just emotional support — it is practical empowerment.
For the first time, ordinary people can:
- build digital dossiers
- reconstruct timelines
- detect patterns of institutional misconduct
- write letters with authority
- expose evidence regulators overlooked
- collaborate safely across cases
- turn pain into purpose
This is how movements begin.
Planning My Life: Preventing Exploitation Before It Starts
What the event also confirmed is this:
People fall into financial exploitation when they fall out of sovereignty.
Planning My Life sits exactly at this junction.
It teaches people:
- how to think independently
- how to plan their lives before planning their money
- how to identify institutional risk
- how to spot predatory sales patterns
- how to avoid product-led advice
- how to stay structurally trustworthy
- how to build a life where no adviser can mislead, confuse, or coerce them
Prevention and recovery are two halves of the same circle.
Get SAFE rescues those already harmed.
Planning My Life equips people so it never happens again.
Together, they form a complete empowerment system.
A New Model of Justice Is Emerging — Built by the People Themselves
The collective energy of the event revealed a truth that no institution dares speak:
When regulators fail, citizens take up the role of regulator.
When governance collapses, the governed take up the role of governance.
When truth is buried, truth-tellers become archivists of justice.
The movement we are seeing now is not political.
It is human.
It is built on:
- transparency
- dignity
- courage
- integrity
- collective intelligence
- and the healing power of community
These are the values Paul Moore lived and died for.
This event honoured him not by remembering his warnings —
but by continuing his fight.
Where We Go From Here
The Academy of Life Planning now carries a responsibility that is both moral and strategic:
To give people the tools to understand their lives,
their finances,
and their evidence —
so exploitation no longer survives in the shadows.
Through:
- Planning My Life (self-sovereignty)
- Get SAFE (justice and recovery)
- AI-as-co-pilot (pattern recognition, empowerment, clarity)
- The Fellowship (community and courage)
- The GAME Plan (a universal cycle of intention-to-manifestation)
…we are building the world that institutions promised but failed to deliver.
A world where truth has a home.
A world where victims are lifted, not shunned.
A world where ordinary people can finally stand equal to the powers that harmed them.
A world where transparency is not a slogan —
it is a lived practice that restores dignity, agency, and hope.
This is the movement Paul Moore began.
This is the movement that rose in that meeting.
This is the movement we now carry forward.
And we will not stop until every victim finds their voice,
every truth comes to light,
and every life stolen by exploitation is honoured through justice.
In One Sentence
Goliathon turns victims of financial exploitation into confident, capable citizen investigators who can build professional-grade cases using structured training, emotional support, and independent AI.
Instant Access
Purchase today for £2.99 and get your secure link to:
- the training video, and
- the downloadable workbook.
Link to Goliathon Taster £2.99.
If the session resonates, you can upgrade to the full Goliathon Programme for £29 and continue your journey toward clarity, justice, and recovery.
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 