** Serious Confidentiality Breach and Governance Failures**
Dear Mr. Dobrynin,
I am writing this open letter to publicly address a serious breach of confidentiality and apparent governance failure at InvestEngine that occurred under your leadership. While my initial communication was intended to be confidential, InvestEngine’s actions have necessitated making this matter public.
Breach of Confidentiality
On May 11, 2025, I sent an email explicitly marked “CONFIDENTIAL: Concerning Recent Communication - For Andrey Dobrynin Only” which detailed my concerns about customer service representative Paul’s handling of my ISA transfer case and the inconsistent information I had received.
To my profound concern, instead of receiving a response from you as CEO, I received a reply from Paul himself - the very person whose conduct was the subject of my complaint. This represents a fundamental breach of confidentiality and raises serious questions about governance at InvestEngine.
I must note that while Paul was very customer-friendly a few years ago, the current situation has deteriorated to the point where I explicitly request that someone from InvestEngine’s management team—not Paul—communicate with me going forward. What good is a formerly friendly tone when it’s now attached to misleading information, regulatory non-compliance, and intercepting confidential communications meant for the CEO?
Governance Concerns
This extraordinary breach raises alarming questions about InvestEngine’s governance structure and internal controls:
- Is my confidential correspondence to the CEO routinely redirected to the very staff members I am complaining about?
- Does Paul have unrestricted access to communications intended exclusively for the CEO?
- Is Paul effectively operating as the de facto CEO of InvestEngine, intercepting and responding to communications addressed specifically to you?
This incident suggests a fundamental breakdown in InvestEngine’s governance structure. When a customer explicitly attempts to escalate concerns to the CEO level, proper governance requires that:
- The communication be treated with appropriate confidentiality
- The CEO or appropriate senior executive reviews the concerns
- The response comes from the appropriate level of management, not the subject of the complaint
The fact that my confidential email to you was answered by the very person I was complaining about demonstrates either a complete disregard for basic governance principles or an absence of proper leadership oversight at InvestEngine.
I must question whether you, as the CEO, are genuinely engaged in the oversight of customer concerns, particularly when they involve potential regulatory breaches as serious as non-compliance with FCA COBS 6.1H.
Underlying Service Issues
The confidentiality breach compounds my existing concerns about InvestEngine’s practices:
- Misrepresentation of Holdings: InvestEngine incorrectly identified my ETF shareholdings as cash when communicating with Freetrade, which prevented a proper in-specie transfer. This was explicitly confirmed by your representatives multiple times. This misrepresentation has completely destroyed my trust in InvestEngine. If you tell other providers my account holds cash rather than shares, how can I be certain InvestEngine actually purchased and holds the shares I paid for? This raises serious concerns about whether my investments are actually secured as claimed. If InvestEngine were to face financial difficulties, this discrepancy could jeopardize my ability to recover my rightful assets, as InvestEngine claims to hold cash—not shares—making verification impossible. The entire system relies solely on trust between customers and InvestEngine, trust that has been severely undermined by your company actively misrepresenting my holdings to other providers.
- Breach of FCA COBS 6.1H and One-Way Transfer Policy: InvestEngine appears to be in direct violation of FCA COBS 6.1H (COBS 6.1H Platform switching - FCA Handbook), which explicitly mandates that ISA/SIPP/GIA managers must allow customers to transfer their investments in-specie (as shares) out to another provider without forcing liquidation to cash, provided the receiving provider can accept those same investments. Specifically, COBS 6.1H.3 states that platform service providers must “offer the retail client the option to transfer units in investment funds that can be held by both the ceding platform service provider and the acquiring platform service provider…” This regulatory requirement has been in force since 2019. InvestEngine operates what appears to be a deliberately asymmetrical transfer policy—readily accepting in-specie transfers IN to increase assets under management, while obstructing in-specie transfers OUT through misrepresentation and misinformation. On April 14, Paul explicitly stated that InvestEngine “support[s] only cash transfers out at the moment,” a direct contradiction of your regulatory obligations under COBS 6.1H. Only after I threatened to escalate the matter to the Financial Ombudsman Service did InvestEngine reluctantly agree to process an in-specie transfer, and even then, only to Freetrade specifically. I want to transfer out to other providers but at the moment Paul claims I can transfer out in-specie only to Freetrade.
- Non-compliance with FCA Transfer Standards and Dear CEO Letter: The FCA issued a clear “Dear CEO letter” dated September 28, 2023 (https://www.fca.org.uk/publication/correspondence/platforms-supervision-strategy-portfolio-letter-2023.pdf), specifically addressed to platform CEOs like yourself, which stated: “As a vehicle to standardise and demonstrate reasonable industry transfer times, we expect firms to engage with, (if not already) and continue to, support the principles and actions endorsed by STAR initiative. Where firms are reporting poor transfer times in comparison with peers and do not already engage with STAR, we will be enquiring about their justification for non-engagement and will act in the absence of progress on transfer times.” Despite this direct regulatory guidance, your representative Paul explicitly confirmed on May 6, 2025: “No, I can not say that what you have shared is anything we are regulated by or specifically follow.” This demonstrates a conscious decision to ignore clear FCA expectations. While providers like Fidelity complete transfers in an average of 10 days, InvestEngine insists on a 30-day timeframe—three times longer than industry leaders. This extended timeframe serves no purpose but to keep customer assets under management longer and potentially leaves customers out of the market during periods of volatility, creating risk of financial loss. The ISA Guidance and Industry-Agreed Good Practice document (ISAGIA) Section 7.2 “In-Specie Transfer/Re-Registration” on page 40-41 (https://www.joinstar.co.uk/wp-content/uploads/2025/03/ISAGIA-Full-MI-V1.5.pdf) clearly defines the transfer process and timeframes:
| Step | Description | Owner | SLA |
|---|---|---|---|
| 1 | Acquiring Party receives, validates, and processes Customer’s Transfer request | AP | 2 Business Days |
| 2 | Ceding Provider receives, validates and processes request for information | CP (InvestEngine) | 2 Business Days |
| 3 | Acquiring Provider instructs Ceding Party to re-register assets/funds | AP | 2 Business Days |
| 4A | Ceding Provider instructs sale of assets/re-registration | CP (InvestEngine) | 2 Business Days |
| 6 | Ceding Provider confirms sales/re-registration complete and initiates payment | CP (InvestEngine) | 2 Business Days |
| 7 | Acquiring Provider allocates monies to Customer Account and confirms completion | AP | 2 Business Days |
4.Total expected timeline: 12 Business Days* When I directly asked Paul on May 6, 2025 whether InvestEngine follows these specific timeframes, he explicitly stated: “No, I can not say that what you have shared is anything we are regulated by or specifically follow.” Instead, InvestEngine insists on a blanket 30-day timeframe, which is clearly not aligned with industry standards. For comparison, Fidelity completes similar transfers in an average of just 8 business days—less than one-third of InvestEngine’s claimed timeframe. This disparity further demonstrates how InvestEngine’s practices fall well outside acceptable industry norms.
5. Inconsistent and Misleading Information: Throughout this process, I have received wildly contradictory information from InvestEngine representatives. After initially being told in-specie transfers were impossible, later communications confirmed they were indeed possible. When asked about compliance with FCA-endorsed STAR initiative standards for transfers, I received incompatible responses from different representatives—sometimes in the same day. Your representative Sebastian wrote on May 7, 2025: “Please allow me to clarify that, although we are not legally obligated to adhere to the STAR initiative standards, we choose to participate voluntarily.” Yet that same day, Paul contradicted this completely, stating: “Our Compliance team have confirmed that we are not legally mandated to adhere to the STAR initiative standards and participation is voluntary, but we do follow reasonable industry standards.” According to Paul, reasonable industry standard is 30 days while according to Fidelity and STAR it is in average around 10 days. This pattern of inconsistency appears designed to confuse and delay, forcing customers to either abandon transfer attempts or accept less favorable cash transfers.
6. Refusal to Provide Personal Financial Information: Despite multiple requests starting April 11, 2025, InvestEngine initially refused to provide me with a copy of the valuation sent to Freetrade regarding my account. This is my personal financial information that I am legally entitled to access. After persistent requests, a minimal screenshot was finally provided on April 14, 2025. This lack of transparency raises serious concerns about what other information InvestEngine might be withholding from customers about their own accounts.
7. Potential Violation of FCA Principles 6 and 7: These practices appear to breach FCA Principles 6 (Customers’ interests) and 7 (Communications with clients), which require firms to pay due regard to customers’ interests and provide information that is clear, fair, and not misleading. The Consumer Duty further requires firms to enable customers to pursue their financial objectives without unreasonable barriers.
Action Being Taken
I want to make it clear that I am already in the process of filing formal complaints with both the Financial Ombudsman Service (FOS) and the Financial Conduct Authority (FCA) regarding these issues. However, I believe other InvestEngine customers deserve to know what is happening when they attempt to exercise their legal right to transfer investments.
I strongly encourage any other InvestEngine customers who have experienced similar issues—particularly those who have been told they can only transfer in cash when they have legal rights to in-specie transfers, or who have received inconsistent information—to also file complaints with the FOS and FCA. Only through collective action can we ensure that these regulatory breaches and governance failures are properly addressed.
The public needs to be aware that what appears to be happening at InvestEngine is not just poor customer service, but potentially a systematic approach to impeding customers from exercising their rights under FCA regulations. The more customers who come forward, the more difficult it will be for these practices to continue.
Warning to Shareholders
Shareholders and potential investors in InvestEngine should be deeply concerned about the practices outlined in this letter, as they pose significant risks to the company’s financial stability and future:
- Regulatory Risk: The FCA has made it clear in their “Dear CEO letter” that they expect platforms to engage with the STAR initiative and will “act in the absence of progress on transfer times.” InvestEngine’s conscious decision to maintain 30-day transfer periods despite industry standards of 8-12 days invites regulatory scrutiny and potential enforcement action, which could result in significant financial penalties.
- Legal Liability: The systematic misrepresentation of customer holdings as cash rather than shares, combined with the obstruction of in-specie transfers, appears to violate COBS 6.1H regulations. This exposes InvestEngine to substantial legal liability through Financial Ombudsman Service complaints, which cost firms £750 per case regardless of outcome, plus potential compensation awards.
- Reputational Damage: As more customers experience these obstructive practices and share their experiences online, InvestEngine’s reputation will inevitably suffer. The financial services industry is built on trust, and once that trust is eroded, customer acquisition costs rise dramatically while retention plummets.
- Unsustainable Business Model: A business strategy that relies on making it difficult for customers to leave rather than providing superior service to encourage them to stay is fundamentally unsustainable. Companies employing such tactics typically experience higher customer acquisition costs, lower satisfaction scores, and ultimately, declining market share.
- Governance Concerns: The fact that confidential communications addressed to the CEO are being intercepted and responded to by the very staff members being complained about suggests serious governance failures. Poor corporate governance is strongly correlated with increased shareholder risk and lower valuations.
The combination of these factors creates significant downside risk for InvestEngine shareholders. Companies with regulatory violations, poor governance, and customer-hostile practices historically underperform the market and are more vulnerable to competitive disruption and regulatory intervention. These practices may temporarily preserve assets under management, but the long-term damage to the company’s reputation, regulatory standing, and customer trust will likely far outweigh any short-term benefits.
Formal Request
I formally request a personal response from you, Mr. Dobrynin, addressing:
- How my confidential email intended solely for you came to be answered by Paul
- What steps you will take to ensure proper handling of confidential communications
- Whether InvestEngine deliberately misrepresents shareholdings as cash when communicating with receiving providers to make transfers out more difficult
- Your personal position on InvestEngine’s compliance with FCA COBS 6.1H regarding in-specie transfers, which has been in force since 2019
- Evidence that my investments were actually placed in the ETFs I selected rather than other instruments
If I do not receive a substantive response within five business days, I will continue to pursue this matter with the Financial Ombudsman Service and the Financial Conduct Authority, while also sharing this letter and the concerning pattern of behavior it describes with financial media outlets and investor forums.
Sincerely,
Dan
