Response to further ATOL consultation January 2023

The protection of pipeline monies paid by the traveller in good faith can only be satisfied by mandatory escrow accounting and the use of approved Trust accounts. Any other half measures condone embezzlement.

The Travel Industry has always been alone in not conforming to this fundamental discipline prescribed by the FCA in all other comparable commerce.

This yet further ‘consultation’ with 33 laboured and muddled questions is essentially irrelevant if the principles of escrow accounting are made mandatory. We have spent hours drafting answers to these rambling questions totalling 1545 words with a vacuous outcome.

Trailfinders is living proof of concept having adopted escrow accounting from their formation over 50 years ago and formal Trust accounting over 30 years ago. All enabled from organic growth and setting some profit aside to establish a war chest and allow immediate refunds.

Trailfinders took the final step to the Ultimate Trust model on the 4^th August 2020. All client monies retained in a CAA approved Trust Account until their travel contract is completed and commission then earned. Travel is hostage to many unwelcome events until completed.

Trailfinders is profitable because of this ethic not in spite of it.

Whitehall does not enjoy a reputation for getting things done but after years of procrastination the CAA or more appropriately the FCA must insist on models to qualify for an ATOL.

1) Ultimate Trust. De-minimis risk. No APC fee.

2) Partial Trust. Supplier payments drawn down from Trust when due with commission only taken when the contract is completed. £2.50 APC fee (?)

Auditors certificate of compliance rendered monthly.

Integrated Operators (own airline) require a different model but anchored by escrow accounting.

Time to call the Travel Industry to account.

Quod Erat Demonstrandum.