When Will the Fsaid Website Be Up Again
Agency overview | |
---|---|
Formed | December 2001 |
Dissolved | April 2013 |
Superseding agency |
|
Jurisdiction | United kingdom of great britain and northern ireland |
Headquarters | 25 Northward Pillar London, United Kingdom |
Employees | three,801 |
Agency executive |
|
The Fiscal Services Potency (FSA) was a quasi-judicial body accountable for the regulation of the financial services industry in the Uk between 2001 and 2013. Information technology was founded equally the Securities and Investments Board (SIB) in 1985. Its board was appointed by the Treasury, although it operated independently of government. Information technology was structured as a company express past guarantee and was funded entirely by fees charged to the financial services industry.[ane] [2]
Due to perceived regulatory failure of the banks during the financial crisis of 2007–2008, the United kingdom of great britain and northern ireland government decided to restructure financial regulation and cancel the FSA.[3] On 19 December 2012, the Financial Services Human action 2012 received royal assent, abolishing the FSA with effect from ane Apr 2013. Its responsibilities were then split between two new agencies: the Financial Conduct Authority and the Prudential Regulation Authorisation of the Bank of England.
Until its abolitionism, Lord Turner of Ecchinswell was the FSA'due south chairman[4] and Hector Sants was CEO until the end of June 2012, having announced his resignation on xvi March 2012.[5]
Its main office was in Canary Wharf, London, with another office in Edinburgh. When acting as the competent authority for list of shares on a stock exchange and maintaining the Official List, it was referred to as the Britain List Authority (UKLA).[vi]
History [edit]
SIB [edit]
The Securities and Investments Board Ltd ("SIB") was incorporated on 7 June 1985 at the instigation of the United kingdom of great britain and northern ireland Chancellor of the Exchequer, who was the sole member of the company and who delegated certain statutory regulatory powers to information technology nether the then Financial Services Human activity 1986. It had the legal form of a visitor express by guarantee (number 01920623). After a series of scandals in the 1990s, culminating in the plummet of Barings Bank, there was a desire to bring to an end the self-regulation of the financial services industry and to consolidate regulatory responsibilities which had been split amid multiple regulators.[7]
FSA [edit]
The name of the Securities and Investments Lath was changed to the Fiscal Services Authorization on 28 Oct 1997 and it started to do statutory powers given to it by the Financial Services and Markets Act 2000 that replaced the before legislation and came into force on 1 December 2001. At that time the FSA besides took over the role of the Securities and Futures Authority (SFA) which had been a self-regulatory organisation responsible for supervising the trading in shares and futures in the UK.[8]
Abolition [edit]
On 16 June 2010, the Chancellor of the Exchequer, George Osborne, appear plans to abolish the FSA and split its responsibilities betwixt a number of new agencies and the Bank of England. The Fiscal Carry Authorization would be responsible for policing the financial activities of the City and the banking system.[9] A new Prudential Regulation Authority would carry out the prudential regulation of financial firms, including banks, investment banks, building societies and insurance companies.[9]
On xix December 2012 the Financial Services Act 2012 received majestic assent and came into force on 1 April 2013.[10] The act created a new regulatory framework for fiscal services and abolished the FSA.[10] Specifically, the Act gave the Bank of England responsibility for financial stability, bringing together macro and micro prudential regulation, and created a new regulatory construction consisting of the Banking concern of England's Financial Policy Commission, the Prudential Regulation Authority and the Financial Conduct Authority.[ten]
Activities [edit]
Scope [edit]
From fourteen January 2005 the FSA likewise regulated the motor manufacture, applicable when insurance products were sold in conjunction with the vehicle purchase. This regulation, which covered around 5,000 motor dealers, focused heavily on the FSA's "Treating Customers Fairly".[xi]
Statutory objectives [edit]
The Fiscal Services Human activity 2010, which was passed by Parliament on eight April 2010, gave the FSA the boosted statutory objective of "Contributing to the protection and enhancement of the stability of the Great britain fiscal system" and removed the public awareness objective.[12]
Retail consumers [edit]
The FSA had a priority of making retail markets for financial products and services work more finer, and so assist retail consumers to get a fair deal. Over several years, the FSA developed work to raise levels of confidence and adequacy amid consumers. From 2004, this work was described as a national strategy on building financial capability in the U.k..[13]
In June 2006, the FSA created its Retail Distribution Review (RDR) programme which they maintained would enhance consumer confidence in the retail investment marketplace. The RDR came into force on 31 December 2012.[14]
The RDR was expected to take a significant bear upon on the way in which financial services are delivered to retail investors in the Great britain.[15] The primary delivery mechanism of financial services to retail customers was via approximately 30,000 financial intermediaries (FIs) who were authorised and regulated by the FSA. They were expected to behave the brunt of the force of the RDR. The key elements of RDR were:
- Independent communication is truly independent and reflects investors' needs.
- People can clearly identify and understand the service they are being offered.
- Commission-bias is removed from the organization and recommendations made past advisers are non influenced by product providers.
- Investors know up-front end how much advice is going to price and how they will pay for it.
- All investment directorate will be qualified to a new, higher level, regarded as equivalent to the first year of a degree[16]
The combination of these factors was expected to significantly reduce the profitability of many FI practices.[17] In apprehension of the new regulatory environs being enforced the industry landscape is undergoing significant change. Despite the fact that many in the industry are considered to exist poorly prepared for the changes coming into outcome,[eighteen] The most significant identifiable trends are:
- Consolidators ownership up modest firms of FIs every bit a upshot of the higher qualifications threshold and downward pressures on profitability resulting from RDR – Due east&Y gauge that the number of Registered Individuals volition fall from thirty,000 to 20,000 inside the adjacent v years.[19]
- IFAs are embracing the concept of wrap account – incumbent fund supermarkets and Life Assurance Companies are in response launching their own Wrap Platforms.[20]
- IFAs are chop-chop moving from the traditional investment solution for clients: recommending a portfolio of largely equity-oriented collective investment schemes (Unit trusts and OEICs) and existence paid initial and almanac renewal commission past the fund provider to an outsourcing model: recommending that clients appoint a discretionary fund manager to manage the client'southward portfolio(due south) and charging the client an annual oversight fee. A recent survey institute that 89% of IFAs are considering outsourcing to discretionary managers as a result of RDR.[21]
- Several new entrants are making major in-roads into this market[22] [23] at the expense of the incumbent retail-oriented funds groups such as Schroders, Gartmore, Fidelity Investments etc.[24] The larger discretionary fund managers are finding it difficult to adjust their business models to cope with these changes, given that the small boilerplate portfolio size is better suited[25] to multi-manager (portfolio of funds) solutions,[26] via wrap platforms, when these fund managers tend to prefer to retain custody and investing in direct equities.[27]
2009 regulations [edit]
The Payment Services Regulations 2009 came into force on 1 November 2009[28] and shifted the onus onto the banks to show negligence by the holder of debit and credit cards in cases of disputed payments.[29]
On the same date the Banking Comport Government commenced.[30]
Organisation [edit]
The FSA was governed by a Board appointed by HM Treasury. At the time of abolitionism its executive chairman was Adair Turner.[31] Hector Sants was CEO until the end of June 2012, having announced his resignation on sixteen March 2012.[5] The FSA was besides provided with advice on the interests and concerns of consumers by the Fiscal Services Consumer Panel.[32]
Criticisms [edit]
The FSA rarely took on wider implication cases. For example, thousands of consumers have complained to the Fiscal Ombudsman Service almost payment protection insurance (PPI) and depository financial institution charges. This was despite determining that there was a problem in the selling of PPI.[33] [34] [35]
The FSA in an internal report into the treatment of the collapse in confidence of customers of the Northern Rock Plc described themselves as inadequate.[36] It was reported that to prevent such a situation occurring again, the FSA was considering allowing a bank to filibuster revealing to the public when information technology gets into financial difficulties.[37]
The FSA was criticised in the concluding report of the European Parliament's research into the crisis of the Equitable Life Assurance Society.[38] Information technology is widely reported that the long-awaited Parliamentary Ombudsman's investigation into the government's handling of Equitable Life is equally scathing of the FSA's handling of this example[39]
The FSA ignored warning signals from Northern Rock building society and continued to permit the banking company to operate without a risk mitigation programme for months before the banking concern's collapse.[40]
Despite heavily criticising split-cap investment trusts, in 2007 it suddenly abandoned its investigation.[41]
In that location were also some questions raised about the competence of FSA staff.[42]
Although one of the prime responsibilities of the FSA was to protect consumers, the FSA was active in trying to ensure companies' anonymity when they were involved in misselling action, preferring to side with the companies that have been found guilty rather than consumers.[43] [44]
Information technology was announced in Nov 2008, that despite self-acknowledged failures by the FSA in effectively regulating the fiscal services manufacture, FSA staff would receive bonuses.[45] On 31 May 2008, The Times confirmed that FSA staff had received £20m in bonuses for 2008/09, a 40% increase on the previous yr.[46]
On 11 February 2009, FSA deputy chairman, Sir James Crosby resigned after it was revealed that he had fired a whistleblower, Paul Moore, who had warned of dangerous lending practices at HBOS when he had been in charge of chance regulation.[47]
Lord Adair Turner, the then FSA chairman, defended the actions of the regulator on the BBC's Andrew Marr bear witness on 13 February 2009. His comments were that other regulatory bodies throughout the world, which had a variety of unlike structures and which are perceived either as heavy touch or light bear on also failed to predict the economic collapse. In line with the other regulators, the FSA had failed intellectually past focusing too much on processes and procedures rather than looking at the bigger economic picture. In response as to why Sir James Crosby had been appointed deputy chairman when his bank HBOS had been highlighted by the FSA as using risky lending practises, Lord Turner said that they had files on almost every fiscal institution indicating a degree of hazard.[48]
Turner faced further criticism from the Treasury Select Committee on 25 February 2009, particularly over failures to spot or act on reckless lending by banks earlier the crunch of 2008 occurred. He attributed much of the blame on the politicians at the time for pressuring the FSA into "light affect" regulation.[49]
On 17 April 2009, a whistleblower (former FSA employee) alleged that the FSA had turned a blind eye to the explosion in purchases of whole sale loans taken on by various Uk building societies from 2005 onwards. The FSA denied the claims – "This is not whistleblowing, it is green ink" a spokesman said. "The allegations are a farrago of lies, distortions and half truths made by an obviously disgruntled former employee who conspicuously has an axe to grind. It does not paint a realistic picture of our supervision of edifice societies."[50]
On eighteen August 2012, the Treasury Select Commission criticised the FSA for its poor enforcement of the LIBOR rate setting rules.[51]
More principles-based regulation [edit]
There were suggestions that the FSA stifled the United kingdom financial services manufacture through over-regulation, post-obit a leaked alphabetic character from Prime number Minister Tony Blair during 2005. This incident led Callum McCarthy, then Main Executive of the FSA, to formally write to the Prime number Minister asking him to either explain his opinions or retract them.[52]
The Prime Minister's criticisms were viewed as peculiarly surprising since the FSA's make of light-touch financial regulation was typically popular with banks and fiscal institutions in comparing with the more prescriptive rules-based regulation employed by the US Securities and Substitution Committee and by other European regulators;[53] by dissimilarity, most critiques of the FSA defendant it of instigating a regulatory "race to the bottom" aimed at attracting strange companies at the expense of consumer protection.[54]
The FSA countered that its movement away from rules-based regulation towards more principles-based regulation, far from weakening its consumer protection goals, could in fact strengthen them: "Our Principles are rules. Nosotros can accept enforcement activity on the basis of them; nosotros have already done so; and we intend increasingly to practise so where information technology is appropriate to do so."[55] As an case, the enforcement action taken in late 2006 against firms mis-selling payment protection insurance was based on their violation of principle half dozen of the FSA'due south Principles for Concern, rather than requiring the use of the sort of circuitous technical regulations that many in fiscal services find crushing.[56]
Enforcement cases [edit]
The FSA was criticised for its supposedly weak enforcement program.[57] [58] [59] For example, while FSMA prohibits insider trading, the FSA simply successfully prosecuted two insider dealing cases, both involving defendants who did not contest the charges.[60] Too, since 2001, the FSA only sought insider trading fines eight times against individuals and companies it regulated,[61] despite the FSA's own studies indicating that unexplained toll movements occur prior to effectually 25 percent of all United kingdom corporate merger announcements.[62]
Afterwards the HBOS insider trading scandal, the FSA informed MPs on vi May 2008 that they planned to crevice downwards on inside trading more effectively and that the results of their efforts would exist seen in 2008/09[63] On 22 June, the Daily Telegraph reported that the FSA had wrapped upwards their case into HBOS insider trading and no activeness would be taken.[64] On 26 June, the HBOS chairman said that "There is a strong case for believing that the United kingdom of great britain and northern ireland is exceptionally bad at dealing with white-collar criminal offense".[65]
On 29 July 2008, nevertheless, it was announced that the Police, acting on information supplied past the FSA, had arrested workers at UBS and JP Morgan Cazenove for alleged insider dealing and that this was the third case inside a week.[66] A year after the subprime mortgage crisis had made global headlines, the FSA levied a record £900,000 on an IFA for selling subprime mortgages.[67]
Deportment relating to the 2007—2009 credit crisis [edit]
The FSA was held by some observers to be weak and inactive in assuasive irresponsible banking to precipitate the credit crunch which commenced in 2007, and which has involved the shrinking of the UK housing market, increasing unemployment (particularly in the financial and building sectors), the public acquisition of Northern Rock in mid-February 2008, and the takeover of HBOS by Lloyds TSB. On 18 September 2008, the FSA announced a ban on short selling to reduce volatility in hard markets lasting until 16 January 2009.[68] [69]
Certainly, the FSA's implementation of capital requirements for banks was lax relative to some other countries. For example, it was reported that Commonwealth of australia's Commonwealth Banking company is measured as having 7.6% Tier 1 majuscule under the rules of the Australian Prudential Regulation Authority, only this would be measured as x.1% if the banking concern was under the jurisdiction of the FSA.[70]
In March 2009, Lord Turner published a regulatory review of the global financial crisis.[71] The review broadly acknowledges that 'lite touch' regulation had failed and that the FSA should concentrate on macroeconomic regulation equally well as scrutinising individual companies. The review also proposed cantankerous-border regulation of banks. There were no further promises to improve consumer protection or to directly intervene against fiscal institutions who treat their customers badly. The review was reportedly met with widespread relief in the city of London where firms had feared a 'revolution' in the style that they would be regulated.[72]
See also [edit]
- Financial regulation
- Financial Bear Authorization
- ORRF Run a risk Research Forum
- Prudential Regulation Authority
- Securities commission
References [edit]
- ^ "Who are we?". FSA.gov.great britain. Retrieved nine April 2012.
- ^ "NDS.coi.gov.u.k.". NDS.coi.gov.britain. Archived from the original on 26 March 2009. Retrieved nine Baronial 2011.
- ^ George Parker and Brooke Masters (16 June 2010). "Osborne abolishes FSA and boosts Banking company". Financial Times.
- ^ Lord Turner confirmed chairman of FSA in its 60 minutes of demand Archived 23 September 2008 at the Wayback Machine
- ^ a b Michelle Abrego. "FSA chief exec Hector Sants quits". New Model Adviser.
- ^ "FSA.gov.uk". FSA.gov.u.k.. Retrieved ix August 2011.
- ^ "fifty years of regulation". FT Adviser. 23 March 2012. Retrieved 3 August 2021.
- ^ "FSA History". Financial Services Authority.
- ^ a b Vina, Gonzalo. "U.G. Scraps FSA in Biggest Banking company Regulation Overhaul Since! 1997". Bloomberg BusinessWeek. Bloomberg. Retrieved xvi June 2010. [ permanent dead link ]
- ^ a b c "Financial Services Bill receives Royal Assent". HM Treasury. 19 December 2012. Retrieved 4 January 2013.
- ^ "Treating Customers Fairly spider web page". FSA. Retrieved 9 August 2011.
- ^ "Financial Services Act 2010". Legislation.gov.britain. Retrieved 9 Baronial 2011.
- ^ "Terminal Cover" (PDF) . Retrieved 9 August 2011.
- ^ "Retail Distribution Review, Financial Services Authorisation". Fsa.gov.uk. 17 February 2009. Archived from the original on one August 2011. Retrieved 9 August 2011.
- ^ "Evidence submitted to parliamentary inquiry". Retrieved four June 2011.
- ^ "Concise-Guide-to-the-Retail-Distribution-Review" (PDF). EA Consulting. [ permanent dead link ]
- ^ "Report by Plimsoll Consulting". Archived from the original on 7 April 2011. Retrieved 4 June 2011.
- ^ "Article referring to Defaqto written report". Retrieved 4 June 2011.
- ^ "Ernst & Young industry study". Retrieved 4 June 2011.
- ^ "Pension Age article on Wrap Platform Growth". Retrieved 4 June 2011.
- ^ "should-you lot-outsource-your-investment-management". Money Marketing. 5 April 2011. Retrieved 4 June 2011.
- ^ Levy, Danielle. "saltus-gets-fix-for-rdr". Wealth Manager. Retrieved 3 June 2011.
- ^ Girard, Simoney. "Saltus-portfolios-witness-increase-in-IFA-outsourcing". FT Adviser. Archived from the original on three October 2011. Retrieved 3 June 2011.
- ^ "Boutiques come out of the shadows". Fund Web.
- ^ "Multi-managers to prosper at expense of fund groups". Archived from the original on xviii June 2011. Retrieved 4 June 2011.
- ^ "Discretionary Manager Directory". Retrieved 4 June 2011.
- ^ Holt, Natalie (2 June 2011). "IFAs Still in Deprival". Retrieved iii June 2011.
- ^ FSA: Payment Services Regulations 2009, in force from 1 November 2009
- ^ Evans, Richard (15 October 2009). "Menu fraud: banks at present have to prove your guilt, 12 February 2010". The Daily Telegraph. London. Archived from the original on 21 October 2009. Retrieved ix August 2011.
- ^ FSA: The Banking Deport Authorities and the Cyberbanking Conduct of Business organisation sourcebook (BCOBS), in strength from 1 November 2009
- ^ "FSA chairman Lord Turner: we got information technology incorrect but we'll keep our bonuses". Business.timesonline.co.united kingdom of great britain and northern ireland. Retrieved 7 May 2014.
- ^ "Financial Services Consumer Panel – Our work". Archived from the original on 3 April 2008.
- ^ "FSA update on payment protection insurance (PPI)". Fsa.gov.uk. 4 November 2005. Retrieved 9 August 2011.
- ^ Your proper noun: (required) (4 Nov 2005). "Example for OFT investigation into payment protection insurance now overwhelming, says Citizens Advice". Citizensadvice.org.uk. Archived from the original on xvi July 2011. Retrieved 9 August 2011.
- ^ Citizens Advice Printing office (19 October 2006). "Citizens Advice urges swifter activity on PPI". Citizensadvice.org.u.k.. Archived from the original on sixteen July 2011. Retrieved ix August 2011.
- ^ Seib, Christine (27 March 2008). "The FSA Northern Rock report: condemned in its own words, the regulator that missed the collapse". The Times. Archived from the original on 23 September 2008. Retrieved 21 February 2018.
- ^ Griffiths, Katherine (22 July 2008). "FSA unveils plans for banks to seek secret emergency funding". The Daily Telegraph. London. Archived from the original on 22 July 2008. Retrieved 9 August 2011.
- ^ Final written report of the European Parliament'south inquiry into the crisis of the Equitable Life Assurance Society European Parliament, 25 May 2007
- ^ Daley, James (17 July 2008). "Authorities disputes lodge to pay billions to Equitable policyholders". The Contained. London. Retrieved nine Baronial 2011.
- ^ FSA immune Northern Rock to keep breaking rules Archived 23 September 2008 at the Wayback Automobile
- ^ FSA ends split-cap scandal investigation with no scalps, The Times, 22 May 2007
- ^ Regulator, heal thyself, The Economist, 20 Jan 2005
- ^ "MODEL Determination NOTICE AND ADVICE] Version iii" (PDF). Archived from the original (PDF) on 25 July 2011. Retrieved 9 August 2011.
- ^ "MODEL Determination NOTICE AND Communication] Version three" (PDF). Archived from the original (PDF) on 25 July 2011. Retrieved ix August 2011.
- ^ Kirkup, James (3 November 2008). "FSA staff will get bonuses despite overseeing financial crisis". The Daily Telegraph. London. Retrieved 9 August 2011.
- ^ Depository financial institution watchdog 'failures' pocket £20m in bonuses Archived 12 June 2011 at the Wayback Machine
- ^ Graeme Wearden, Simon Bowers and Deborah Summers (xi Feb 2009). "Sir James Crosby resigns from FSA". The Guardian. London. Retrieved 9 August 2011.
- ^ FSA chairman Lord Turner: nosotros got information technology wrong only we'll continue our bonuses Archived 12 June 2011 at the Wayback Machine
- ^ Pratley, Nils (26 February 2009). "Past failings take hold of up with FSA". The Guardian. London. Retrieved 2 April 2010.
- ^ Patrick Collinson and Tony Levene (17 April 2009). "Building societies face atrocious truth about blast-fourth dimension spending spree". The Guardian. London. Retrieved 9 Baronial 2011.
- ^ "TSC slams FSA over role in Libor scandal". moneymarketing.co.united kingdom of great britain and northern ireland. xviii August 2012.
- ^ Liberty of Information request for disclosure of the alphabetic character from Sir Callum McCarthy to the Prime number Government minister. FSA, 29 May 2007
- ^ FTSE firms volition 'keep UK rules'. BBC, 12 June 2006
- ^ Voice communication past SEC Chairman: 'The Hunters and the Stag': Why National Securities Regulators Must Collaborate In the Era of Global Investing xvi Nov 2006
- ^ Treating Customers Fairly and more principles based regulation Clive Briault, managing director for Retail Markets, FSA, 24 July 2006
- ^ FSA fines abode shopping visitor £270,000 for PPI selling failures FSA, xx December 2006
- ^ "'London loophole' leaves US at odds with FSA". Fiscal Times. 7 July 2008. Retrieved 9 August 2011.
- ^ How tin can this still happen?, The Guardian, eighteen January 2003
- ^ FSA chiefs hit back at criticism Archived 31 Oct 2007 at the Wayback Machine, The Scotsman, 12 March 2003
- ^ Police force and the Market place: the Impact of Enforcement Archived 28 March 2007 at the Wayback Machine, John C. Coffee Jnr
- ^ FSA Struggles With Insider Trading That Doesn't Happen in U.K., Bloomberg, 11 June 2007
- ^ Measuring Market Cleanliness, FSA, March 2006
- ^ Jill Treanor (6 May 2008). "Nosotros'll crack down on insider dealing, FSA tells MPs". The Guardian. London. Retrieved nine August 2011.
- ^ Kleinman, Mark (22 June 2008). "FSA admits defeat after HBOS probe". The Daily Telegraph. London. Archived from the original on 24 June 2008. Retrieved 9 August 2011.
- ^ Phillip Inman in Edinburgh (27 June 2008). "UK is weak on tackling white collar crime and short sellers, says HBOS chairman". The Guardian. London. Retrieved nine August 2011.
- ^ "Viii arrested in FSA insider dealing inquiry". Yahoo!. Retrieved 9 Baronial 2011. [ permanent dead link ]
- ^ "FSA levies record sub-prime fine on Thinc". Archived from the original on eight July 2012. Retrieved 22 Apr 2008.
- ^ "FSA statement on short positions in fiscal stocks". Financial Services Authority. 18 September 2008. Retrieved 21 February 2018.
- ^ "FSA introduces brusque-selling ban". BBC News. 19 September 2008. Retrieved 2 April 2010.
- ^ "Boyd, Tony, "A Capital letter Idea", 21 October 2008". Business Spectator . Retrieved ix August 2011.
- ^ "The Turner Review: A regulatory response to the global banking crisis" (PDF) . Retrieved 9 August 2011.
- ^ "City relief as Turner shuns revolution". Fiscal Times. 18 March 2009. Retrieved nine August 2011.
External links [edit]
- Coin Advice Service
- HBOS whistleblower concerns over FSA 10 February 2009
- European Parliament Temporary Commission of Inquiry into the Crisis of the Equitable Life Assurance Lodge
- The Herald: Northern Rock to be nationalised 18 February 2008
- Telegraph: Nationalising Northern Rock is correct [ dead link ] 18 Feb 2008
- BBC News: City watchdog revises probe rules 19 July 2005
- BBC News: FSA under fire subsequently Blair speech 6 June 2005
- Lawrence A. Cunningham, A Prescription to Retire the Rhetoric of 'Principles-Based Systems' in Corporate Law, Securities Regulation and Accounting (2007)
- Cristie L. Ford, New Governance, Compliance, and Principles-Based Securities Regulation (2007)
Source: https://en.wikipedia.org/wiki/Financial_Services_Authority
0 Response to "When Will the Fsaid Website Be Up Again"
Postar um comentário