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Of course, times have changed and now we see investor DDQ documents upwards of 5-10-20 pages in length and asking great levels of detail about technology, cybersecurity and operations.
Secondly, there is a clear increase in how hedge funds and financial services firms are leveraging outsourced service providers.
The last point here is with regard to some of the large-scale disasters we’ve seen in recent years. So we know now that there has been an evolution, but what exactly does that evolution equate to?
To properly conduct review and discussion with vendors and business partners, firms should have a series of questions and discussion points ready. Continuity Program Activities: This would include ensuring that the vendor or business partner regularly reviews and updates necessary plans and procedures.
Disaster Recovery Systems: During vendor discussions and evaluations, ensure your business partners are identifying the location or locations where data is backed up. Business Continuity Procedures: Firms should discuss comprehensive continuity strategies and procedures with all third-party vendors. Communication Practices: Firms should confirm with vendors or business partners that they have both an internal and external communication plan. Reviewing these four key areas with your vendors at least on an annual basis is important to ensure your continuity extends as areas of your business, including those managed by outsourced third parties.
The subject of hedge fund operational due diligence is one that has risen to the forefront for both hedge fund managers and investors in recent years. Historically, there has been a general lack of transparency within the hedge fund industry; larger funds, in particular, often balked at investor inquiries.
Due diligence, as a process, did not gain significant importance until just a few short years ago. Hedge funds managers and investors are now taking due diligence seriously and making conscious steps to maintain open communication and increase information-sharing. Operational excellence has become one of the most important factors to hedge fund investors today as they determine where to allocate their money. What service providers are you engaged with and how do you determine their quality of service? Investors need to understand why hedge funds have made each of their operational choices, including when it comes to technology.
Investors have become much more aware of technology and how important a role it plays in the day-to-day operations of a hedge fund. Hedge funds should be prepared to recover from both short- and long-term disasters and be prepared to outline their processes and procedures (in writing!) to investors. Hedge fund operational due diligence is an opportunity and a marketing exercise – one that funds should undertake with educated personnel and a willingness to be open and transparent.
Many firms create a 10-20-page written information security plan that formalizes the definitions and policies that govern the creation, access, and deletion of confidential information and computing services. Regulatory Risks – Following the right security practices will enable you to achieve clean audits from industry and government regulators.
Personal Email – Even if your employee is following all of your processes and practices with work-related email, you could still be vulnerable if her private, personal email is breached or corrupted. By developing an internal culture of security, the organization does far more than deploy and configure bits and bytes.
Show investors that you have a 3+ year budget for working capital without any performance fees. Make sure to properly allocate expense and investment opportunities if you decide to launch a single investor fund or separately managed accounts. When it comes to seed arrangements, pick the right partner and put parameters around potential issues that could arise.
Become familiar with the changing expectations on the cybersecurity front, from both investors and regulators. The Cybersecurity Interpretive Notice applies to all membership categories--futures commission merchants, swap dealers, major swap participants, introducing brokers, forex dealer members, commodity pool operators and commodity trading advisors. But whatever approach is taken, the Cybersecurity Interpretive Notice requires Members to adopt and enforce an information systems security program (ISSP) appropriate to its circumstances.
Description of ongoing education and training related to information systems security for employees. NFA recognizes that some Members may face a significant challenge implementing ISSPs by the March 1, 2016 effective date, and any programs that are adopted will be refined over time. Eze Castle Integration’s Cybersecurity Practice Team is available to create Written Information System Security Programs for firms. Operating capital may be limited in the first few years after your launch, so careful budgeting and long range planning will serve your firm well. Governmental oversight of the financial industry has evolved dramatically in the last decade. Apart from registration, you should also determine if there are any legislative implications for your new firm.
Since 2014, cybersecurity preparedness is also a critical area of focus for regulatory bodies.
Cloud services offer more flexibility than traditional infrastructure models and, beyond cost-savings, can reap rewards for new launches. Of course, one of the greatest benefits to using an outsourced cloud service is professional management and monitoring. Beyond infrastructure safeguards, it is critical that firms implement policies and procedures to protect firm and client assets. While the list of considerations is surely long for new hedge fund managers, we've whittled it down to 10 Keys to Launching a Hedge Fund Successfully - a guide for new startups to use when setting off on their new journey. Communicate – It is important to let your employees know as soon as possible that they will no longer be able to get to work. Technology – Technology has facilitated the ability for an employee to work remotely during a storm, but there are still some considerations to think through.
Hunker Down –During severe storms employee safety should be at the top of the priority list. Set Workload Expectations – As an employee, a storm can be disruptive to their normal work day.
Updates – As a consistent theme throughout BCP, communication is key, and continued updates will keep the employee centered on their work and allow them to respond to changes quickly such as the reopening of the office building.
According to the National Oceanic and Atmospheric Administration (NOAA), El Niño conditions occur when abnormally warm waters accumulate in tropical latitudes of the central and eastern Pacific Ocean. La Niña conditions occur when cooler-than-average waters accumulate in the central and eastern tropical Pacific and tropical rains shift to the west. The key to a successful business continuity plan lies in understanding the impact a disaster situation could have on a business and creating policies to respond to any such impact. The final critical element of a BCP is ensuring that it is tested and maintained on a regular basis. Or contact Eze Castle Integration to speak with one of our certified business continuity planners about best practices or to learn about why leading hedge funds rely on Eze Business Continuity Planning Services. We spend a lot of time educating our clients about security best practices and encouraging them to implement comprehensive security policies and procedures to mitigate risk and protect both the firm and its employees.
While companywide policies should reflect long-range expectations and corporate best practices, they should also include tactical recommendations that employees can follow to ensure they are complying with the company’s overall risk strategy.
Provide information such as login IDs, passwords, social security numbers, account numbers, etc. It is no surprise that the investment industry landscape is becoming more and more competitive.
A comprehensive DDQ covers a wide range of topics, from assets under management to audited financial statements and investment strategies. So, to help you get started, we have compiled the following list of some frequently asked DDQ questions.
Does the firm have established, documented service level agreements in place with its technology partners to ensure a stable computing environment? Is the policy regularly reviewed to determine whether the controls are operating as intended? Do the appropriate management officials approve the policy and any changes that may be made? Does the firm’s IT staff (or technology partner) ensure appropriate access control to applications and sensitive company data?
Is a solution in place to ensure mobile devices and laptops are secure in the event of loss or theft? Has the firm established a dedicated location to retain backup copies of all critical data? Has a secondary working location been established to which employees should report in the event of a disruption or outage?
Is a comprehensive disaster recovery solution in place to provide system redundancy and ensure protection of critical data in the event of a disaster or system failure? Has the firm determined its crucial recovery point objectives (RPOs) and recovery time objectives (RTOs)?
A component of Disaster Recovery that deals with the restoration of business system software and data, after the operating system environment has been restored or replaced. A pre-identified group of individuals that is reponsible for maintaining and executing the recovery process. A system of planning for, recovering and maintaining both the IT and business environments within an organisation regardless of the type of interruption. A collection of information on a wide range of areas from recovery assumptions and critical business processes to interdependencies and critical staff that is then analysed to assess impact a disaster may have.
The process of restoring and maintaining the data, equipment, applications and other technical resources on which a business depends. A disaster recovery hot site is a remote physical location where you can maintain copies of all of your critical systems, such as trading applications, data, and documents. A computer system or application that is essential to the functioning of your business and its processes.
In the context of a primary and secondary site, the primary site contains the original data that cannot be recreated. The RTO is the duration of time and service level within which a business process must be restored after a disruption in order to avoid unacceptable losses.
The RPO is the point in time to which a firm must recover data as defined by the organisation.
A system of using multiple sources, devices or connections so that no single point of failure will completely stop the flow of information.
The identification and prioritisation of potential business risk and disruptions based on severity and likelihood of occurrence. The secondary site contains information and applications that are built from the primary repository information. If regular testing is a critical component of an effective DR solution, why do many firms fail to do so?


Here at Eze Castle, we strive to educate our clients on different testing methods so that they find an option that best meets their unique business requirements.
As we continue to educate our hedge fund and investment firm clients on disaster recovery testing methods and the available options, we have seen a drastic increase in the number of clients that elect to implement regular testing procedures. Supplemental Evacuation provides the redundancy and survivability into the building evacuation system that account for multiple ?what if? scenarios to be planned for if the building evacuation is to be successful. People should be responsible for their own safety, but the lack of awareness and knowledge about the concept of fire safety is a problem we face.
Fire in an occupied high-rise could mean having to evacuate hundreds, or perhaps thousands, of people in difficult and dangerous conditions. 1) How do you empty the total building population of a high-rise in the shortest possible time? 2) How do you get those people with physical disabilities down quickly and with minimum assistance in the absence of lift and elevator for egress? 3) How do you increase the egress capacity of a tall building that is designed for phased evacuation to facilitate simultaneous evacuations? 5) How do you provide additional emergency exit(s) or increase the size of existing stairways for mass rapid evacuation where it is not possible due to building structure? That is where preparedness in pre-planning for ?Supplemental Evacuation? provide the answers! We encourage you to take the time to browse through the website and consider how these products can help you in solving your building evacuation problems and needs. Did you know that only 38% of people register the presence of an emergency exit sign during an evacuation? But with the way IT has evolved over the last 5-10 years, it’s no wonder investor inquiries have changed in both size and scope. An investor due diligence questionnaire may have been one or two pages and focus mostly on firm investment history, performance, etc. So let’s talk a little bit more about the influences for this due diligence evolution. The reality is, you can’t operate a successful hedge fund with a couple of laptops and a Verizon FIOS connection.
Years ago, most firms were operating their own Server Rooms and managing their own technology.
They have all, in and of themselves, led to one of the biggest influencers of all, and that’s regulation. If investors are educating themselves more about technology and asking more probing questions in order to achieve higher levels of satisfaction, what exactly do they want to know? If your firm has a comprehensive business continuity plan in place and you conduct regular BCP tests, you might think your responsibility ends there. Four critical areas you may want to review include continuity program activities, disaster recovery system details, business continuity procedures, and communication practices. They should also identify recovery time objectives (RTO) related to that data and compare that desire with the RTO outlined within the existing plan. Service providers should be able to explain how, even in the face of various interruptions, they will continue to provide the contracted level of service stated in the contract. Additionally, firms should discuss the process that outlines how your fund would be notified if a disruption were to occur with your service. Following the review discussions, your firm's internal continuity team should meet and evaluate any deficiencies noted and determine the comfort level with any identified risks. Prior to the economic downfall in 2008 and high-profile investment scandals made infamous by Bernard Madoff and others, hedge fund due diligence was viewed as an unnecessary assignment.
They figured there would never be a shortage of investors, so there wasn’t a need to spend extra time satisfying their needs. In the past, the responsibilities associated with hedge fund due diligence would often fall under the role of a CFO, CCO or other executive – someone who had very little time to devote specifically to due diligence. There has, undoubtedly, been a significant increase in the number of due diligence inquiries by hedge fund investors, and the questions they are asking are much more relevant and involved - that rings true across business and operations functions, technology departments and the investment side of the business.
They want more information, more transparency and more assurances that fund managers have done their own due diligence in assembling and managing their infrastructure and overall businesses.
Small-scale disasters, such as winter weather scenarios, and larger incidents like the Madoff scandal have initiated a real shift in the hedge fund industry and highlighted the need for hedge funds to have robust technology solutions in place and systems and procedures to keep them operational at all times. During the due diligence process, they often ask to see systems at work, the processes through which data is transmitted and stored, and how testing procedures work.
Explain the designs and processes of your operations, particularly when it comes to your technology. If you do not have an in-house IT staff, you can ask your technology service provider to do this for you. You will score points with investors if you are up front about everything and don’t attempt to hide anything.
Hire a consultant to help you with this – it is the single easiest way to prepare for a real investor review.
Test your disaster recovery system frequently (at least twice annually), and show the results to investors. Investors want to see that funds are serious and that they value operations and technology as vital aspects to their businesses. It does not begin when an investor comes in for a meeting and end when they walk out the door. That can be everything from a definition of personally identifiable information (PII), a description of user access privileges and roles, or policies regarding USB thumb-drives. It commits to defining and following thoughtful, far-ranging policies to eliminate the needless internal vulnerabilities that often go unrecognized.
Not only must emerging managers evaluate traditional deployment strategies, but consider current factors influencing the financial landscape. There was quite a bit of content discussed during the 1-hour event, so we’ve pulled out some key takeaways. Target those who have a history of being receptive to founder share class and who may offer lower management and performance fees.
Recognize where the private cloud has an edge: high-touch, industry-specific service and support, scalability and application integration, and security and compliance. Value is derived from knowledge of the application, knowledge of business, and having a dedicated support team. The NFA's Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49 entitled Information Systems Security Programs requires Member firms to adopt and enforce written policies and procedures to secure customer data and access to their electronic systems.
Executive-level participation and annual review of the information security program is expected.
NFA expects to devote appropriate resources, such as providing additional guidance, to assist Members as they develop and implement their ISSPs.
Don't forget to visit Hedge IT on Thursday as we reveal the last of our key considerations for starting a hedge fund.
Hedge funds, private equity firms and registered investment advisers now operate in a world where they are beholden to regulatory bodies with growing expectations and requirements. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which redefined the registration requirements for hedge funds, also set forth new reporting requirements and standards for safeguards.
With the prevalence of cyber threats and attacks, the SEC’s Office of Compliance and Examinations (OCIE) has incorporated cybersecurity into its examination targets.
Firms can add users nearly instantly – a welcome benefit for startups looking to ramp up quickly.
You can do this by conducting employee awareness training to keep all users informed and educated about the cyber environment and the threats that may arise.
And be sure to come back to Hedge IT later this week when we'll be sharing an excerpt from our brand new whitepaper on the same topic! For example, what exactly will your employees need to fulfill their functions remotely and are they trained to do so? Therefore, if the storm seems to be impassable it is best to allow employees to work remotely.
In the United States, seasonal precipitation impacts are generally opposite those of El Niño. In addition to providing employees with security best practices they should follow, don’t forget to also include a list of actions they should not.
Over the past few years, as regulations have changed and investors increasingly seek transparency, hedge funds are spending more time than ever preparing for the due diligence process.
As this trend continues, investors are raising their expectations and looking towards hedge funds that display the highest levels in operational excellence. One major area of focus is the hedge fund’s IT and accompanying cybersecurity policies and procedures.
Are steps being taken to ensure visitors do not have the ability to observe or access sensitive employee systems and documents?
Have appropriate training and documentation been established and shared with all personnel? In addition to the IT infrastructure, it covers people, facilities, workplaces, equipment, business processes, and more.
High availability can be implemented into a firm's IT infrastructure by reducing any single points of failure using redundant components.
In working on the Eze Disaster Recovery team, I have heard a variety of reasons from clients as to why this is the case. Current technologies allow IT providers to overcome just about any objection users may have with regards to DR testing.
We often find that firms grow, evolve, and change their production environments as they develop and expand their businesses. This website focused and sustained awareness drive of supplemental evacuation in enhancing fire safety to make people more aware of the fire risks, and how they can get out of danger in the event of a building evacuation. It is the Management?s responsibility to evacuate ALL people from the building in an emergency before the fire engines arrives. For examples, having to evacuate a building in darkness due to power outage; having to evacuate people on wheelchair if the elevator is not working or if the stairway is not accessible because of smoke and fire. The provision for ?Supplemental Evacuation? in buildings is not a luxury but risks reduction strategy in tackling the perceived difficulties and problems of building evacuation. Sadly, many people, too wrapped up in their own lives, don't realise the realities of poverty in The UK, assuming it is their own fault.
We’ve seen high-profile breaches at major retailers, healthcare providers and financial services firms. 2012 wasn’t that long ago, but the reality is, many firms were unprepared for the havoc that storm wreaked on their businesses. In 2010, with the Dodd-Frank Act, firms were introduced to stern recordkeeping requirements as well as calls for enhanced disaster recovery and business continuity plans. However, if the service providers that you engage with do not also have proper disaster recovery systems and business continuity plans and test said plans regularly, they are exposing your firm to serious risk and may be the weakest link in your continuity or recovery. This is important as it relates to recovery time, since it will outline at which point after a disaster you are expected to have access to critical systems and data.


But as the hedge fund industry has evolved over the last several years, so has the need and desire for operational excellence. You can also compile a comprehensive presentation or simply have an open question and answer session with your potential investors. Due diligence is an ongoing process that can continue to improve and evolve as investors and fund managers open the lines of communication and maintain an open dialogue.
The bank believes hackers executed a hack that allowed $81 million to be taken from the bank’s foreign exchange account at the Federal Reserve Bank of New York.
And the way that starts to happen is through systemic and comprehensive training practices. Prepare an institutional set of documents up front if you are looking to attract institutional money versus high net money.
They include risk assessment, governance, training, access control, vendor management, and information sharing. Additionally, firms must provide employees training during the onboarding processes as well as periodically during employment. For example, system safeguards such as data protection, disaster recovery measures and email archiving are requirements under Dodd-Frank.
Having released two extensive questionnaires and several risk alerts focused on security, the SEC has made it clear to investment firms that they will be investigating the practices employed at firms and increasing expectations for the future. Startups have a variety of options when it comes to settling on their technology infrastructure.
Users can gain access to email, file services and applications from virtually anywhere, and built-in disaster recovery provides confidence that everything is protected from the inside out.
Users should understand how security threats may present themselves (phishing schemes, social engineering, etc.) as well as how they can become cybersecurity assets to your firm. Successfully operating a new startup beyond the first year is a feat many managers struggle to accomplish, therefore it's critical for emerging managers to gain a full understanding of the industry that awaits them and the hurdles they should expect to face.
With these unprecedented levels of snow, New York City was forced to halt public transportation and implemented a mandatory restriction on private transportation as well.
One must also consider licensing, infrastructure, security, and employee comfort as working from home will be a change for them. If essential functions are unable to meet their workload demands from home, then temporary office space with redundant power is always an option.
It is always important to review your business continuity plan and make sure employees are aware of their roles if an issue were to occur. In the coming months, there is expected precipitation in Southern California, extending along the South coast. In today's landscape, however, investors and regulators alike expect and demand that firms implement preparedness plans for disasters and cyber-attacks. Take a look below and discover a vast range of security tips and tricks from email encryption to proper security measures for protecting computers and mobile devices. One important way to ensure your firm meets these high standards is to complete a due diligence questionnaire (DDQ) that can be shared with potential investors.
At Eze Castle, we frequently assist our hedge fund clients in completing DDQ questions on technology, and we often see the same types of questions popping up. In addition, a great resource for conducting due diligence on a hedge fund's service providers is the 200 question document published by the Alternative Investment Technology Executives Club (AITEC). Be sure to read our articles on the difference between DR & BCP and preparing for a worst case scenario. Additionally, we are hearing from a growing number of hedge fund clients whose investors now require them to test their DR solutions and report on the results from those tests.
In turn, the DR site needs to evolve and change simultaneously in order to continuously meet business requirements.
All of these circumstances and more have to be planned for if the building evacuation is to be successful. They are using a wide variety of systems and applications to track investments, communications, etc. Now, with the advent of the cloud, especially, funds are leveraging outsourcing to support all aspects of their business.
Hackers today are savvy and have a wide variety of tools that they’re using to penetrate networks and access sensitive material and, in many cases, take control of assets. And of course, now, the SEC has taken a keen interest in cybersecurity and is focusing their examinations on the level of preparedness firms have in place to thwart cyber-attacks. Lastly, it’s also critical that they provide employees with necessary training on these plans, both at the outset of the plan implementation and at least annually. If RTOs are unclear, you run the risk of being unable to work or access data or information you need, potentially disrupting clients and even violating contracts or regulations.
Relay your concerns to the vendor to validate the deficiencies and understand if they are willing and able to take steps and correct them. Hedge funds should continue to take the time to understand where the real risks are within their businesses and work to instill confidence with their investors. It appears that the initial point of entry for the hackers was a spear-phishing email, potentially sent weeks before the fraud took place, which allowed the criminals time to remotely monitor and probe the bank’s networks without detection.
Regardless of the assets your firm is launching with, you will be expected to have sophisticated and comprehensive policies and procedures in place from day one to combat cyber threats. With the birth of cloud technology, firms can save on upfront capital expenditures and host their infrastructure in the cloud – providing flexibility within those startup budgets.
A reputable cloud services provider not only provides world-class infrastructure and resiliency; it also assumes responsibility for the management and daily maintenance of your cloud environment. Investors also have high expectations, and before they will even consider allocating money to your firm, they want to understand what protections you’ve put in place to protect their assets.
Jonas proved to be kind in the fact that the majority of the impact fell on the weekend but many firms can recall more disruptive storms occurring during regular business hours leaving many employees feeling stranded. Temperatures are also expected to be warmer than average for most of the Northern parts of the country - a welcome gift for places like New York, Philadelphia and Washington, D.C. This trend is putting more pressure on firms to participate in regular testing than ever before. The fire-fighters will assist in the evacuation if people are still in the building when they arrive. Many firms today are not only outsourcing IT, but using tools or service providers for fund administration, portfolio accounting, investor relations, and so on. If not, you can look for other vendors whose continuity practices reduce or eliminate any risks or concerns you may have.
Disaster recovery, business continuity planning and cybersecurity preparedness should all be viewed as full business exercises, not solely technology ones. Be sure to enable your firm’s processes to comply with SEC recommendations including risk assessments, infrastructure practices, policy documentation, etc.
With hackers savvier than ever and financial firms as known targets, it’s critical that firms establish a comprehensive approach to security to not only meet investor and regulatory demands but also to protect firm assets and mitigate business risk. To alleviate the stress incurred during winter storms, we sat down with our own Business Continuity Analyst, Matt Donahue, who creates, writes, and audits hedge fund’s business continuity plans.
As far as specific remote access technologies, Matt recommends Virtual Private Networks (VPN), Citrix or Outlook Web Access (OWA), depending on a user’s specific needs.
These tests do not need to be elaborate, for example, a work from home day or a call tree run through might suffice. The whole problem is that the greedy few take far more than they need, leaving the rest of us struggling.We ask you, - who really needs more money than they can possibly spend? As these types of software platforms and infrastructures have developed, investors have had to re-frame how they view technology and spend more time learning about it in order to fully understand how their assets are being used and protected. And each of those relationships then is something an investor is going to want to scrutinize. If not forthcoming, you may open up your firm to serious regulatory and criminal prosecution. Your cloud services provider should act as your trusted technology adviser and, as such, give you the flexibility and time you need to focus on your investment priorities without worrying about security updates and patch controls.
Matt spoke with us about different BCP scenarios and provided tips to keep your firm operational during the worst of storms. In California - a state tortured with drought in recent years - rain might, at first, seem like a positive. How did we do?"  "What are your thoughts on these new ways of; 'All-Green', All-Sustainable', and 'All-Climate' Community Living Styles? Typically, drought conditions impact vegetation and other natural defenses that hold surface soil and sediment in place, meaning floods and landslides could develop with heavy rains. The Mark, the currency of Germany's value was not competitive in the international currency and the economic fabric became miserable with poverty, unemployment and other economic problemsIn 1931, Hitler came to power with his intrigues and Nazi propaganda. He established a racial regime where top position was given to blue eyed Aryan race of Germans .Where as Jews and blacks were given low position. Associating with Jews was not felt good and they were forced to surrender their property and send to areas where poverty and unemployment were the social outcomes.
He encouraged to multiply the children of German race and given clear instructions to avoid the marriages with the Jews.
MOVE FORWARD TO 2014: Disillusioned with Capitalism and Socialism,A Nigel Farage joined a small party called UKIP. Through his attractive speeches, he got a wide following all over The UK.The economy is struggling, and through the ConDem's policies, there is widespread poverty, unemployment and economic problems. A A Despite what he says, Nigel Farage and his cohorts are racist, indeed, the name United Kingdom Independence Party says it all - The British for the British!
It was a political earthquake!A Less than 12 weeks earlier, Winston Churchill (pictured right) had announced the unconditional surrender of Nazi Germany.
Churchill wanted his wartime coalition to continue until Japan too had been defeated, but was not unduly dismayed when his Labour ministers insisted that the country be offered a choice. The Prime Minister called the election for early July, confident that the British people would back the greatest hero of the hour. Of all Churchill's colossal misjudgments, that was probably the most egregious!A The voters wanted an end to wartime austerity, and no return to prewar economic depression. Three years earlier, in the darkest days of the war, they had been offered a tantalising glimpse of how things could be in the bright dawn of victory. It offered nothing less than a cradle-to-grave welfare state.That was the great promise dangled before the British electorate in 1945. Though Churchill had presided over the planning for radical social reform, though he was a genuine hero of the masses,A the people of The UKA did not trust him to deliver the brave new world of Beveridge.There were other factors too. Sadly, many people, too wrapped up in their own lives, don't realise the realities of poverty in The UK, assuming it is their own fault.
The Mark, the currency of Germany's value was not competitive in the international currency and the economic fabric became miserable with poverty, unemployment and other economic problemsIn 1931, Hitler came to power with his intrigues and Nazi propaganda.




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