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The origins of this litigation lay in the over‐selling of personal pensions that took place after April 1988. On 25th October, 1994, the Securities and Investments Board (SIB) published a long‐awaited statement, which it described as ‘guidance’. This statement was adopted on 5th November, 1994, by the Insurance Brokers Registration Council (IBRC), a recognised self‐regulating organisation (SRO) for the purposes of the Financial Services Act 1986.

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