Money Laundering - The Book-keepers Forum (UK)

benn72 · Veteran Member

Money Laundering

Shamus · Forum Moderator & Expert

Hi,

All bookkeepers must be registered.

Its a legal requirement. Failure to register carries up to two years imprisonment and unlimited fine.

If you work FOR the accountant you do not need to be registered but if you are self employed working WITH the accountant you do need to be registered.

Hope that helps, wasn't trying the shout the for and with at you but felt that they were worth emphasising.

At the end of the day, if you are a freelance bookkeeper then you must be registered for MLR either under your professional body or directly under HMRC.

Hope that helps and welcome to the forum,

kindest regards,

Shaun.

-- Edited by Shamus on Sunday 2nd of February 2014 12:39:34 PM

abacus12345 · Guru

Yes, you need to be registered. If you work in practice you'd have a MLR officer to report to, if not then you'd have to report to SOCA, or, the new NCA.

benn72 · Veteran Member

Hi Shamus

Thanks for this - has all been very confusing when reading about it ie the flow chart ifrom HMRC itself mplied i didnt need to be ie the first question on their flow chart being do you give advise to which my answer is no and the flowchart then says no you dont need to register

I have been looking at the HMRC mlr101 form today etc - as i understand it i have to register each premises

If i plan to work from home and also on their site do i register just my premises (which by the way is my home not an office) or my home and the on site address of the clients business

As i said i dont advise, not a signatory etc and all clients i propose have their own accountant - ie i am not the end point

The accountant must have done MLR forms etc with the client - isnt the client going to get abit p'eed off if they have to go all through it again with me?

I have read that "Regulation 17 allows you to rely on CDD carried out by credit or financial institutions or members of the following professional bodies etc etc" which the accountant would be

It also says that

"The third party must give consent for the CDD to be replied upon and although the Regulations do not define how consent must be evidenced, it is sensible to provide written notification saying that you intend to rely on the third party firm for the purposes of Regulation 17"

so as they will have an accountant who will have already done the MLR with them, if i got a letter giving consent rather than annoy the client by them having to go through it all again??

There are god knows how many businesses out there with a book keeper and an accountant - do they all have to go through MLR separately with both the book keeper and the accountant ??

benn72 · Veteran Member

Thanks Abacus

What is
SOCA, or, the new NCA ??

-- Edited by benn72 on Monday 3rd of February 2014 04:00:52 AM

abacus12345 · Guru

SOCA being serious organised crime agency. NCA national crime agency. HTH

benn72 · Veteran Member

and i have to do MLR process with client even though accountnant will have already done it and also bearing in mind i woldnt be giving any advise etc that would all be done by the accountant?

Shamus · Forum Moderator & Expert

No, you've misunderstood what they mean.

Its each premises that you work from not at.

Could you imagine our clients indignation at finding that we were registering their premises with HMRC.

What is meant is that if you work from home and also have an office then you would neeed to register both, or if you have multiple offices you would need to register all of them.

It does not mean that we ever register clients premises for money launfdering purposes.

Think of the extreme of that where you are working at a clientz that it registered for money laundering and you are trying to register that premises again!

In that instance its simpler than you are reading it.

The key to your other questions is that you are self employed, you are not working for the accountant but rather with them.

The key to whether you need to perform your own CDD or depend upon that performed by the accountant is in the relationship between your business and the accountant.

How does the client see the relationship, do they have a bookkeeper and an accountant, or do they have an accountant who subcontracts work to a bookkeeper. The two are quite different.

In the first case the client relationship is with the accountant and the accountant is responsible for the bookkeeper and by extensdion the CDD.

In the latter it is two seperate business relationhips and both require CDD seperately.

HTH,

Shaun.

benn72 · Veteran Member

Thanks re the premises .. i get that now

Im really confused by the HMRC flowchart as to whether you need to register or not as i answer no to the very first question "do you give advise" which the flowchart then tells me i dont need to register

The accountant wouldnt sub contract the work to me but the client would view it as he would have a book keeper who does the mundane stuff and the accountant is the one who finalises and advises etc

If i were to say tot he potential client i need to go through money laundering process with you - i fully expect him to tell me im mad - as he wouldnt value that the mundane work i would do would give me any right to start asking MLR questions - he would see it that the only the accountant has that right as it is the accountant who finalises, advises etc

Am therefore expecting not to get this client ... and i suspect there will be many other business people out there that would think like that .. ie what right has someone who isnt going to be advising etc got to be asking MLR questions ???

If i were employed by the company to do the same work i wouldnt have to do MLR

Or am i missing something??

abacus12345 · Guru

http://www.hmrc.gov.uk/mlr/getstarted/register/asp.htm

Shamus · Forum Moderator & Expert

You are missing that you are a business employed by another business to do work on their behalf.

Often the bookkeeper is able to spot unusual transactions more easily than the accountant who will be looking at the bigger picture.

At basic level your MLR procedures are determining who the client is, do they haver the right to act for the business, how are the funds of the company derived.

Don't make a big thing to the client about MLR but rather shrug it off as having to dot the i's and cross the t's for legal compliance. You are in business now and you need to be as much of a sales person as you are a technician.

That client wants to work with you. The accountant wants to work with you. Every other bookkeeper that wanted the work would need to build the same client permanent record. Why would the client want to go anywhere else unless they are attempting to hide something?

The key to your own question is in that you are thinking of yourself as part of the work of the accountant rather than a totally seperate business. In some instances that sort of relationship would be true but in the one that you describe where there is no physical link between the bookkeeper and the accountant then they are two seperate services both requiring CDD.

abacus12345 · Guru

Note that the regulations apply even to very small businesses, or where a business only does one part of a transaction. So you'd still need to register with HMRC if you were a bookkeeper with just one client, for example, or if you only kept a client's business records from which their accountant prepared the accounts.

Shamus · Forum Moderator & Expert

Hi John,

Good link but I think that it would still leave the poster confused as the issue is getting her head around the concept of being totally seperate from the ASP as she is working for the client, not for the ASP.

benn72 · Veteran Member

Hi

thanks for that - see what you are saying re thinking of myself as part of the work of the accountant rather than a totally separate business ... is evident that i am a newbie to all this !!!

not thought of myself really as being a totally separate business in all of this ... but see now i wouldnt be just "part of the work of the accountant"

What are your views on my earlier post re what i ahve read re regulation 17 re relying on the CDD carried out by the accountant ???

This would be my first client ... would a wise option be to speak to the accountant and initally at least rely on their CDD ??

All thoughts negative and positive welcome

abacus12345 · Guru

Hi shamus. It just boils down to, you could notice something untoward within the books, and being part of machine, (regulated profession) no matter how big or small a cog we are, we must be covered. Its law. The accountant should be expecting you to ask for due diligence on client X. Whether the work is outsourced to you, me or KPMG, the exact protocols are the same.

benn72 · Veteran Member

Hi

Thanks to all for their help so far on this - am understanding it better now - certainly that my role in in it isnt maybe as minor as i thought

The client has used the accountant for many years - neither he client or accountant has mentioned MLR to me in the meetings i have had with them for them to decide if they want me

I want to make sure i have everything in place right before i committ ... i have sorted insurance and am looking into data protection (though that seems as confusing as this!) though i'll keep that separate issue for now

I just dont want to appear as if im being too big for my boots etc, give the impression i think im more important than i am

Think i have got confused along the way by the fact my services are at the lower end with no involvement with the bigger issues re advise, owners taxes, fialising accounts etc

I will send an email to the accountant and keep you updated

would be interested on comments re my early post in this thread re regulation 17 though - wondering if i could rely on accountants for now and 6 months down the line register myself for money laundering and not make a big thing of it to client by saying i need to do it then as my business is growing (whether it is or not)

benn72 · Veteran Member

and thanks re comment "The accountant should be expecting you to ask for due diligence on client X"

i wanted to ask accountant but was nervous that accountant would think i was trying to take over, thought my role was more important than it is etc

abacus12345 · Guru

Always cover your own behind. Always.

benn72 · Veteran Member

I do understand this beter than i did this morning but am stil confused by the HMRC flowchart to follow if you are unsure if you need to register

"I provide tax advice, do I need to register as an ASP?"

I dont provide tax advice or any advice

Comments welcome!!

benn72 · Veteran Member

please help!!!

am trying to compose an email to the accountant but fear looking stupid as i wouldnt be giving tax advise and dont want the accountant to say to the client "they are getting too involved in money laundering when they dont need to be, so dont employ them as they clearly dont know their behind from their elbow!!!"

Shamus · Forum Moderator & Expert

Define advice.

in doing the bookkeeping you will find yourself making decisions on behalf of the client. You decide whether to capitalise or expense, whether to allow or pass to the DLA. Decisions made are not always the all encompassing ones such as whether to incorporate or how to reduce tax liability. Its also the little things, the minor decisions made whilst completing a clients books.

No matter whether you believe now whether you will be advising the client or not, I would have money on it that it would not take long before the client is asking you things that you would have expected them to be asking the accountant. Some things you will quite rightly need to pass to the accountant but others you should be able to field yourself as they will be related to how something is to be recorded through the books.

Before writing off the importance of your contribution to this, always consider that the smallest cog in a precision timepeice is no less important than the largest one.

benn72 · Veteran Member

Ok ... am seeing what you say but before i get to the point where i have no hair left as ive pulled it all out trying to get my head round this

As this would be my first client ... and i dont want to appear like im taking over before i even start by asking about money laundering

Could i rely on the accountants MLR under regulation to start, but be in the processing of registering myself for MLR and when the registration comes through say to the client its because my business is now growing ??? and in the mean time make sure i dont give advise get ie cover my behind by emailing the accountant ???

Shamus · Forum Moderator & Expert

Shamus wrote:
always consider that the smallest cog in a precision timepeice is no less important than the largest one.

p.s. and thats the basic premise of this site in that we have contributors here from the highest levels of accountancy who treat fledgling bookkeepers as equals rather than being in any way condescending.

Its a difficult and confusing profession in which you will often get conflicting advice... Especially from HMRC where there is the old joke that if you want a different answer just phone back and ask a different person!

The key though as indicated by John above is to always err on the side of caution... Be prudent if you like... And for this one in particular is it really worth the potential of a two year jail sentence, unlimited fine and losing all professional memberships, ability to get MLR cover in the future, ability to get PII cover, etc. for not registering.

The only bookkeepers who need not register are those working for accountants or other bookkeepers or employed by the end client basically as sales / purchase ledger data entry clerks.

Anyone working on a self employed basis as a bookkeeper (bookkeeping to trial balance, VAT and Payroll) must be registered for MLR.

benn72 · Veteran Member

and whats this fit and proper test im reading about ???

and exactely would i have to do with the client directly? ie is it an annual thing and throughout the year be observant to all that goes on?

Im really nervous about asking more questions about money laundering than the accountant has before ive even started!!!

abacus12345 · Guru

Well you can not be partially registered, or practice whilst being in waiting for mlr cover. You either get the go ahead from HMRC, or you don't. You can not, legally practice without it. That is just how the system works. No grey area. If your not in employment, you must be registered. Must.

benn72 · Veteran Member

regulation 17 says that you can rely on the external accountants MLR checks ??

benn72 · Veteran Member

ive been speaking the last month to someone i know who is a book keeper on a self employed basis to get some knowledge of setting up on your own as this is all new to me - it was them who pointed me in the direction of regulation 17 - which i now feel has just confused me further !!!!!!!!!!!

benn72 · Veteran Member

they have something called a 648 or something form with customs meaning they can speak to customs but customs wont discuss anything key about the business with them as they arent involved in decision making

They also dont do anything without the accountant confirming its ok to do even down to setting up a new nominal code

so they rely on regulation 17

are they doing it wrong?? and misadvising me or am i being really stupid here ????!!!!!

benn72 · Veteran Member

and how quick do customs grant this to you - this client wants me to start next few weeks ... looks like i cant????

abacus12345 · Guru

Form 64-8 is a form a client fills in yo give you authorisation to deal with hmrc on their behalf.

benn72 · Veteran Member

Thanks re 64-8 ( i was almost right with the name!!!)

Have i been misadvised re regulation 17???

benn72 · Veteran Member

and as client wants someone quick im not going to be able to do this client am i - as i doubt customs grant these quickly

abacus12345 · Guru

I'm not sure what your friend or acquaintance has told you. I can assure you, you have to be registered for MLR. If not, it is a grave possibility you will land yourself in serious trouble. You have to be registered. HMRC will check your name against it's database for the likes of money laundering against you. To ensure your not barred from registering. Seriously, you have to register. All the best.

benn72 · Veteran Member

It is someone i know on a business level - have worked with and they have set up on their own

They are now self employed have two clients

Both clients have accountants who do the advise etc

He does purchase ledger and sale ledger inputting.

Business owners do debt chasing

He write cheque for supplier payments but the owner signs them, he is not a cheque signatory

He submits the vat return and payroll realtime with the owner having signed it off and is there when he submits

he has this 64-8 to contact customs re online help re submitting data - customs will not speak to him re monies due etc

Acountants do finalisation of accounts, advise etc etc

He told me that reulation 17 of the money laundering act allows hi to rely on the MLR by the external accountants - having read it is seems to say he can

He signs nothing on behalf of the companies

im going to loose this client arent i as i cant see customs being quick to grant MLR to me and client needs someone really soon

am very very sad - worked so hard to get that client - speant hours on it

abacus12345 · Guru

I'm unsure of the current turn around. Time of the application submitted. The mlr is not just covering advise. You, as a finance professional have an eye to potentially spot bogus transactions, or hot transactions, therefore you fall within the group of regulated professionals. Therefore, by proxy, directly or indirectly you can be held responsible for failing to inform the authorities of suspicious activity, or even on the subject of terrorism financing. Whether it be a pound or, a million pound. There is no de minimis. This subject, area, topic is not to be taken lightly. I would also suggest you acquire personal indemnity insurance also, ifyou have not already acquired cover.

benn72 · Veteran Member

HMRC describes the Money Laundering Regulations as: "Money Laundering Regulations are designed to protect the UK financial system. If your business is covered by the regulations you must put in place certain controls to prevent it being used for money laundering by criminals and terrorists. "

im wondering if im getting confused again the words above "your business" is that my business????

benn72 · Veteran Member

i have insurance sorted

what do you all think to regulation 17???

abacus12345 · Guru

I think, maybe, with all due respect, your trying to split hairs on this one. Please get your cover, your obviously working hard as you have yourself a client. The last thing you need is to get yourself in trouble. The law is unfortunately what it is, good or bad. It's there. In a round about way it is a good law, not just for the obvious helping to cut down on finance crime, for whichiI believe is the equivalent of Spain's GDP year on year. It also helps to stop the blame culture. For instance, if you spot something, and inform the accountant of such, at a later date, if there was an investigation the accountant could not turn around and say, 'well it was not brought to my attention' to try to avoid liability as under the act, you yourself are responsible to report. All this of course is not to mention tipping off offensives, holding money as a trustee etc etc.

Shamus · Forum Moderator & Expert

benn72 wrote:
Could i rely on the accountants MLR under regulation to start, but be in the processing of registering myself for MLR and when the registration comes through say to the client its because my business is now growing ??? and in the mean time make sure i dont give advise get ie cover my behind by emailing the accountant ???

You must be registered for MLR before you take on your client.

On the bright side HMRC are pretty fast at getting you registered.

As mentioned by John it doesn't matter if you have one client or whether you are KPMG money laundering expectations are the same.

MLR is not about the advice that you give, it is about understanding whether your client's is who they say they are, whether their revenue is the result of legitimate business and whether they are declaring everything that they should.

In some ways think of it as you paying HMRC to work for them in investigating your own clients.

Also don't believe the hype about MLR being about anti terrorist funding... Its not, or at least thats a tiny part of it.

As part of its implementation tax evasion was classified as money laundering so your real role is in identifying those evading their tax burden by no legitimate means.

Considering the above, thats why non compliance with the regulations carries such draconian punishment.

MLR is not taking over things, its simply a legal burden as part of your start up procedures and an awareness that you need to be aware of the source of your clients business with a view to any illegal activity (inclusing tax evasion).

Tut, just went off to talk to a client and you've been busy with the posts before I've had chance to post my reply!

Bookkeeping comes under Accountancy Service Providers so the fit and proper test is not required.

You can rely upon the work of external accountants only if you work for / under the external accountants. That is not the situation here.

You may be confusing the elements of the rules as OR rather than AND. The actual rules are that all apply so :

when all their customers are other ASPs that are supervised by HMRC or a professional body listed in Section 8, providing:

they do not deal directly with the customer of the supervised ASP

they are included within the scope of the AML procedures of the supervised ASP including suspicion reporting procedures and appropriate training, and both businesses provide evidence in the form of a written contract to confirm that the arrangement covers compliance with all the AML requirements in respect of the entire customer relationship.

You would be dealing directly with the client rather than under the umbrella of the accountant

A 64-8 is an agent authorisation. It gives HMRC permission to talk to you about your client. Without you being lodged as their agent they will not talk to you (note. If you are register as the clients agent via a 64-8 that supercedes all previous authorisations... That wouldn't make you very popular with the clients accountant).

Having a 64-8 in place is absolute proof that you need to be registered for MLR.

As mentioned above before I had read your other posts, MLR comes through pretty quickly. Think that its mostly within 10 days although pretty sure that when I was registered through HMRC it came through in five.

There is no reason that you could not start the premptive KYC work before you have the MLR fully in place but you cannot start actual work including the signing of the engagement letter until your MLR is in place. (which is effectively acceptance of your responsibilities)

Right, post that and see whast else you've posted, lol.

benn72 · Veteran Member

benn72 wrote:

HMRC describes the Money Laundering Regulations as: "Money Laundering Regulations are designed to protect the UK financial system. If your business is covered by the regulations you must put in place certain controls to prevent it being used for money laundering by criminals and terrorists. "

im wondering if im getting confused again the words above "your business" is that my business????

I read "your business" as my business????

therefore i must put certain controls to prevent "it" (my business?) being used for money laundering by criminals

So why do i need to go through MLP forms with my client ... my client would not be able to use my business for money laundering??

But then i think i am misunderstanding as you all talk about i must note clients activities etc - therefore it is his business not mine being checked for money laundering???? and his business that must be reqistered for it???

Or am i loosing the plot here??? i simply want to be able to enter their sales and purchase ledger!!!!

Shamus · Forum Moderator & Expert

Think that the answers are burried in my last post. Give you chance to read that one and then ask follow ups.

Peasie · Expert

Shamus wrote:
In some ways think of it as you paying HMRC to work for them in investigating your own clients.
Also don't believe the hype about MLR being about anti terrorist funding... Its not, or at least thats a tiny part of it.
As part of its implementation tax evasion was classified as money laundering so your real role is in identifying those evading their tax burden by no legitimate means.

This is the bit that annoys me. MLR was brought in most other countries for this purpose. Not the UK though. An easy way to get free tax investigators. Or in some cases, get investigators to pay for the privilege.

benn72 · Veteran Member

ok ... from what i undertand from your posts is i cant rely on MLR accountant has done if i work directly with the customer??
I have just read this fliipin regulation 17 (whic im fast begining to wish i never knew about!!! as feel thats why im so confused

17. (1) A relevant person may rely on a person who falls within paragraph (2) (or who the relevant person has reasonable grounds to believe falls within paragraph (2)) to apply any customer due diligence measures provided that
(a)the other person consents to being relied on; and .
(b)notwithstanding the relevant persons reliance on the other person, the relevant person remains liable for any failure to apply such measures. .
(2) The persons are
(a)a credit or financial institution which is an authorised person; .
(b)a relevant person who is .
(i)an auditor, insolvency practitioner, external accountant, tax adviser or independent legal professional; and .
(ii)supervised for the purposes of these Regulations by one of the bodies listed in Part 1 of Schedule 3;

ie A relevant person may rely on a person who falls within paragraph (2)/ external accountant

This where im getting confused as i cant see where it says not if you deal directly with the external accountants client?

What do i do now re the person i know as they seem to be doing it wrong ?

I dont want to tell them above and have them worry about fines and prison!!! but feel i have to tell them

As far as i understand it they are self employed but do nothing without the permission of the owner or accountant and reports to the owner and accountant

So they dont work for the accountant as in the accountant pays them but dont work without the accountants and owners authority

what is KYC?

benn72 · Veteran Member

abacus12345 wrote:
I think, maybe, with all due respect, your trying to split hairs on this one. Please get your cover, your obviously working hard as you have yourself a client. The last thing you need is to get yourself in trouble. The law is unfortunately what it is, good or bad. It's there. In a round about way it is a good law, not just for the obvious helping to cut down on finance crime, for whichiI believe is the equivalent of Spain's GDP year on year. It also helps to stop the blame culture. For instance, if you spot something, and inform the accountant of such, at a later date, if there was an investigation the accountant could not turn around and say, 'well it was not brought to my attention' to try to avoid liability as under the act, you yourself are responsible to report. All this of course is not to mention tipping off offensives, holding money as a trustee etc etc.

Honestly im not trying to split hairs .... im trying to understand ... and im sorry if im being a pain

The way i am understanding it is a business has numerous people paying HMRC a MLR to regulate them ie if a firm has an accountant, a book keeper and them say gets a credit management company to collect any old debts, thats 3 people doing MLR checks on them .. the client is going to feel hounded!!!

What gets me is in all the years i was employed as a book keeper before i had my child 3 years ago - never once was i put on a money laundering course etc etc ?????

And i would always put things in writing to the accountant

benn72 · Veteran Member

so what form do i need to fill in - the MLR101 doesnt seem to be right re Shamus saying Bookkeeping doesnt need a fit and proper test. The MLR101 is called Application for a fit and proper test which i dont think is right now - hence another reason why i may have confused myself in all this????? as ive been looking at the wrong form????

benn72 · Veteran Member

can someone tell me what form to do and i will get on the case for me straight away

can anyone advise what i say to the client when they contact me this week - as it wont be in place re MLR when they contact me - what do i say if they want me to at least sign letter of engagement - i cant at present

Can someone also direct me please o the regulation bit that says you cant rely on accountant MLR if you deal direct;y with the client for me to forward on to person i know

If i go to them with whats in posts i will give them a heart attack with panic as i know they have been working off reg 17 as they chanted that out to me - which is what confused me

He has been doing this about 5 months - i know he will have been observant etc as to make sure all is done right, nothing criminal so in affect doing all that MLR requires without having paid HMRC for the "priviledge" !!!

i suspect him to be sleepness night and awiating HMRC to open tomorrow and will be their first caller - i hope they will understand as i have to admit i couldnt see in reg 17 where it says not if you work directly with the client

I feel awful having to tell him ... but i have to

benn72 · Veteran Member

please help what form do i need etc and what should i say to client etc?

im sorry to be a total pain

Shamus · Forum Moderator & Expert

No worries, we try to make sure that all of the people on the site do everything correctly and as I've said before if you are asking a question then others will be wanting to ask it but for one reason or another be too apprehensive to post. (anyone would think that we bite!)

Its form MLR100 that you need not MLR101.

KYC = Know Your Client (who are they, what authority do they have over the business, what is the source of funds of the business, etc.).

The letter of engagement is from you to the client, not the other way around.

All that you are looking for immediately is a copy of their passport and/or driving licence and a utilility bill with their name and address on it.

If they are limited go to the companies house website to confirm who the directors of the company are and the registered address and make sure that matches to the passport/utility bill.

Thats the basics. To the client you simply pass it off as part of the sign up procedures and don't make a big thing about it as its not... They would give exactly the same information if they were signing up with a video store.

You keep the client information on a permanent file which you store per client.

When looking at the clients books and records you need to know where their money is coming from. Most of the time the transactions being processed speak for themselves.

You may be escalating the process into something bigger than it is. Your main concern is just making sure that you stay within the letter of the law.

As for your freind, just because they get it wrong does not mean that you should follow.

Advise them that they need to register for MLR immediately. The issue is more difficult for them than you as they are already working with clients tha tthey now need to get information from where you are simply getting the required information as part of the sign up process.

Don't take their problems on your shoulders, you have enough problems trying to get your own business off the ground.

Feel free to point them at this thread and then feel free of further responsibility.

kind regards,

Shaun.

benn72 · Veteran Member

Thanks for that

The client isnt a limited company so just a simple "id process"

I will give this thread to my friend - who i dont feel so worried about now as their client isnt limited and i know that they see the owners home bills etc so have done an id check really. They also will know where all the money comes from

So hopefully as they havent been doing it long, explain the misunderstanding re reg 17, say they work closely with the accountnat which they do, and say they have id checked them which they have, and they know where all moeny comes from, and fact they are going to HMRC now and isnt HMRC have found them... if they register immediately fingers crossed all will be ok for them

benn72 · Veteran Member

that flipping reg 17 - bet it confuses so many people !!!!!

i still cant find where it says in that regulation not rely on accountant MLR if you work directly with the client ????

Thank god i found this website as id have followed understanding of reg 17 as i understood it, how my friend understood it and how many others i bet understood it

you quoted abit earlier re not if direct with client - which reg point was that? is annoying me that i cant find that

will do my mlr100 not mrl101 (again a cause of my confusion!!!) immediately!!!

thanks so much