This week, I'm joined by Chris Cunniffe CEO of tax pooling company Tax Management New Zealand. Morena Chris, welcome to the podcast. Nice to have you here. Now tax pooling is something that's been around now for, what, 15 years? For me and many other accountants and tax agents, it's a vital tool in helping manage clients' tax payments. But how exactly does it operate?
Chris Cunniffe
It's a good question, Terry. There's a lot that happens behind the scenes that people aren't aware of. So let me take a moment just to paint that picture. The tax pool is one really large account at Inland Revenue. It's got multiple billions of dollars in it because we have clients ranging from New Zealand's largest taxpayers right down to small businesses who pay their tax through the pool. When that happens, they deposit their tax in a bank account with our corporate trustee, Guardian Trust and Guardian Trust immediately passes that on to Inland Revenue. So the money is always sitting at Inland Revenue, but instead of being allocated at Inland Revenue against each taxpayer, it's sitting in this large pool known as the TMNZ tax pool.
We have the ability to trade balances within that pool. So if somebody has paid too much tax, they can sell their excess. If somebody hasn't paid enough tax, they can come to us and buy what they are short. At the end of the year, when people know their liability, we transfer to their account at Inland Revenue exactly the amount that they need. And their statement at Inland Revenue will show them to be completely compliant taxpayer with the right amount of tax paid on the right dates.
TB
Fantastic. It sounds a bit intricate. But what is the big advantage for clients of using a tax pooling method.
Chris Cunniffe
So the advantages differ I guess across the client base. Ultimately, tax pooling is about managing uncertainty around your tax payments. It's around giving people an insurance policy that if they have underpaid, somebody is there to help them out. It's particularly about managing exposure to Inland Revenue use of money interest. I'll come back to that in a minute. And increasingly, for small and medium businesses, it's about managing cash flow.
So let me just go back to the use of money interest. Inland Revenue charges taxpayers at the moment, 8.35% If they don't pay their tax on time. Now, that rate is designed to hurt them. It certainly does. Inland Revenue does not want to be a an involuntary banker where people say, oh, look, there's a fairly good interest rate there. I'll just pay later. So they want to have a fairly sharp interest rate that focuses the mind and gets people paying their tax on time and use of money interest largely achieves that.
But there's many reasons why people don't pay their tax on time, and we're not talking bad taxpayers, we're talking people who have cash flow constraints, who have seasonal businesses, who have unexpected events that caused them to have taxable income that they hadn't planned on. And for them to be hit with an 8% interest charge is kind of unfair.
So the genesis of tax pooling way back in the early 2000s was big business saying to Inland Revenue, you're charging us at that stage double digit interest when we don't make our payment on time or we get our tax payments wrong. That's usury. It's unfair. So Inland Revenue came up with this idea that said, well, what about allowing those who have paid too much to trade with those who have paid too little? And an intermediary can effect the payments.
So that's what we do. So people will save probably 30% on the Inland Revenue interest. They're going to charge them 8.35% We'll be charging them a rate. And it varies depending upon the amount of tax you're buying, the age of the tax but we're charging around 5% to 6%, in some cases less.
TB
That's a very significant advantage. It also means because the tax is deemed to be paid on its proper due date, you trade tax within the pool. And so not only have you reduce your use of money interest, you avoid the late payment penalties.
Chris Cunniffe
Absolutely. And there's a 5% penalty if you're a week late. So if you've missed a tax payment, tax pooling is an amazing solution. Just an example. Yesterday we had an inquiry, somebody at a largish company, because it was it was over two million dollars was saying, can we buy a tax payment for 28 November. And right now they're looking and down the barrel of a 5% penalty on that. They can come to us and buy that tax and we'll just charge them an interest rate and they eliminate their late payment penalty.
TB
Seriously for those who have not used it before this is a real life saver at times. When's the biggest demand for your services? Is there any particular time you'd see a lot of payments going through?
Chris Cunniffe
Oh, we run a regular cycle through the year. Most of New Zealand's largest taxpayers deposit their tax through us and increasingly small and medium businesses are paying their tax. So as you go through the year. If you think about the cycle on P1, 28th August, a lot of money comes into the pool and then again for the P2 payment on 15th January and finally for P3 at the 7th of May after which it sits there until people file their tax return.
Now, like all good tax agents, I'm sure your filing percentages are right up to date, but there are some who seem to do all their tax returns of the last week of March. That is when we get frantic at that stage. Agents are coming to us and saying, here's the tax liability for my client, please transfer. And that's where agents are coming to us and saying, my client’s got a problem. They didn't pay enough tax. Can I please buy tax? So we are frantic from March through till June. That's our trading window.
The rest of the year it's regular and routine transactions. Under the new provisional tax rules, interest now only applies from P3 on 7th May if people have used the standard uplift method. So most of the demand is for tax for P3 so seventh of May is the biggest date that we will sell tax for.
TB
So the changes to the provisional tax rules, they were designed to make life a lot easier for taxpayers. That probably made your life worse.
Chris Cunniffe
We were disrupted without doubt, but I don't think there's a business in New Zealand that doesn't get disrupted by competition or by technology or in our case, by regulation. Yes. And what it's forced us to do is look at "What are the services we provide? What are we good at doing?" And looking at our client base and so. Whereas we originally existed, I guess, as an ambulance at the bottom of the cliff, "my client is short paid can I buy tax?" We have now morphed into being a cash flow and a working capital solution, particularly for small business.
So, it will be no news to you, what's the biggest issue for your clients? Cash flow? Inland Revenue is quite prescriptive. You shall pay tax on these dates depending on your balance date with no care about whether you're a seasonal taxpayer, whether your business is growing, whether there's any other things going on. Too often those dates don't fit with your business needs.
So paying tax on the 15th of January, straight after Christmas and when everyone's in shutdown mode, how dumb is that?
TB
Indeed, there's a story behind that which can wait for another day.
Chris Cunniffe
Anyway, we increasingly have people saying, look, will you pay tax on our behalf? We could give you an example of some people who use us for cash flow. Trucking company wins a major contract. Great news. The business is going to grow. What we need to buy three more trucks. I need to pay my property tax. Now, where's the best use of their cash right now? It's obviously putting down deposits and getting new trucks into the fleet. So they came to us and said, can we defer the payment of our provisional tax for six to nine months? And we said, of course she can. So, we have this product we call it tax finance and you essentially tell us I'm due to pay tax on a particular date, let's say the 15th of January coming up. It would suit me better if I could pay that in six months time. So we will get a funded pay tax on your behalf and you pay us a fee upfront and in six months time when cash flow is strong you come back and you essentially buy that deposit out of the pool. We transfer it to Inland Revenue you're a compliant taxpayer. You've paid your tax on time. So that's one way to do that. Kind of "I know exactly what I need to pay and I want to defer it in a structured way".
The other way is just to do it like having a revolving credit or a flexible mortgage. You say, "I know what my liability for this year is and I want to pay it through TMNZ and I'll pay 200 dollars a week." We had a lot of clients who do that and they just set up that automatic payment to pay it through us and we transfer it across and we work with the tax agents to make sure the tax is on the right date at the right time. But for that taxpayer and sometimes even for the agent, all that stress about whether the money will be still in the bank account when it's time to pay the provisional tax will is gone. We often hear agents that tell us about clients who when they get the provisional tax reminder they go "Whoops, I've just spent that."
TB
Yeah, that's fairly common. There wouldn't be a tax agent in New Zealand who hasn't experienced the call on the morning of the 28th August, for example. "So what's this about paying ten thousand dollars? I haven't got it". I mean what are you describing here is something that anyone who works in the SME sector knows, that a lot of the legislation and processes are designed for big companies and assume a level of cash flow and capital and basic skill that just simply doesn't exist or is not commonplace in this sector.
I mean, we've talked about provisional tax, but actually you can also cover GST and other taxes. How does that work?
Chris Cunniffe
We can cover other taxes where there's been a reassessment. Where you've got an uncertain position, and this could either be that Inland Revenue has approached you and questioned a tax position you've taken or increasingly it is where the tax agent has done a review and says "I don't know that we got this quite right" and a voluntary disclosure is going to be made. You can come to us and buy tax at those historic dates. This is incredibly valuable. If you if you think that interest rates over the last four years have fluctuated between 8% and 9%. So take a client who has been getting a position wrong for the last four years. The interest that has built up on that underpaid tax there could be north of 30% of the core tax, so that's quite an uncomfortable conversation to be having with your clients as you talk them into a voluntary disclosure or when Inland Revenue is putting a proposal for a reassessment on the table and then they went 30% extra with interest. This is before we even get to penalties.
We've got tax in the pool going all the way back to 2008. It does not matter what date your client is being reassessed for. We've got tax available. Anybody who is being reassessed for any income tax or any other tax type, you should contact the pool and we'll be able to reduce their interest costs in the region of 30% to 40%.
TB
That's a significant help. This is a scenario we see quite a bit often around overseas income because the rules are so complex and people assume that it's just like to be taxed at source. So, yeah, the ability to make a voluntary disclosure and get a reassessment and then use TMNZ to reduce the interest bill is very significant. In one example I can think of we saved a client $10,000 in interest by using tax pooling.
Chris Cunniffe
Yeah. And this is real money for people who in most cases were unaware that they had a problem.
TB
It's the old saying you don't know what you don't know until you find out. And then it gets very expensive. So obviously, a key part of your business would be regular interactions with Inland Revenue. And at several different levels. So how does that work? There is a special unit within Inland Revenue that deal specifically with tax pooling.
Chris Cunniffe
Well, let's take a step back. Inland Revenue created tax pooling, it was the solution to a problem that arose in the early 2000s. So we exist at the behest of Inland Revenue. So at a policy level, we have engagement with them, which is around what should tax pooling be able to be used for and how has the industry evolved? I talked about how we changed over the years. We have regular discussions with tax policy officials. Just to let them know what's happening and make sure that, you know, they have comfortable with the settings. So that gets a gets a big tick.
And about four years ago, Inland Revenue did a review of the industry just to check that there was no risk to the system by having this industry called tax pooling.
And it came back with a very solid report, in fact one of the recommendations was this is now relied upon by so many taxpayers, you would not want to take it away.
Operationally. there's a unit at the processing centre and on a daily basis, we're interacting with them we're uploading schedule, we're saying this is who's put money into the pool, this is people who are buying tax. Please transfer from the pool to these taxpayers X amount of tax. We do tens of thousands of transactions a year with that unit. So, we work very, very closely with them.
And as you imagine, with all interactions with Inland Revenue just around the fringe, there can be systems, issues or uncertainty about legislation. And we work through that. And that final piece on uncertainty with legislation is in a technical area at Inland Revenue that we liaise with and there's a regular liaison between Inland Revenue and the industry to ensure that issues are running smoothly. We pay a massive amount of New Zealand's provisional tax. TMNZ would be the largest taxpayer in New Zealand. If you think about our account at Inland Revenue with multiple billions of dollars in it. So there's a an investment on both sides to make sure that this runs efficiently.
TB
Yes, the tax pool has at any one time six or seven billion dollars?
Chris Cunniffe
It can get it can get well north of that when is all the money comes in. And then as it gets transferred out, the pool drains again and then we fill it up for the for the next year. But it's in the multiple billions of dollars.
TB
I understand included amongst your clients is the New Zealand Super Fund, the country's single largest provisional taxpayer, with a billion dollars plus regularly. So it's dropping 300 million at a time every provisional tax payment.
Now we've got a provisional tax payment coming up on the 15th of January. So now tax agents like will be looking out to our clients and telling them what's going on. But as you know the rules, 105% or 110% of RIT [residual income tax] are confusing. I think you've got a specific tool to help tax agents like myself and clients calculate your RIT and your payment.
Chris Cunniffe
Yeah. A couple of years ago, Inland Revenue looked to simplify the provisional tax rules to take the heat out of the use of money interest by saying if you pay your first and second instalments based on an uplift to prior year returns, then there's no interest. That's good for business, but they’ve created a level of flexibility and an optionality in the system that has actually now started to confuse people. As you say, should it be 110% of last year of two years ago or 105% of last year? Have I filed my last year's return or not? It starts becoming quite a complex calculation. So we've created a calculator on our website which allows agents to enter the details of their client's prior tax positions. And it will come up and say this is how much tax should be paid on on each instalment date. And so that's become very popular with agents. And they tell us it is now a core part of their provisional tax process in terms of advising clients.
TB
Excellent. Yes, even for someone who's been like myself working for 25 years or more, provisional tax every now and again, I just go back and say "Wait a minute. What applies here? Do we file a return or not file a return." It's all sort of needless complexities and confusion. So it's always invaluable the assistance we get from yourself.
Chris Cunniffe
And again, that's the advantage of the pool is that you can kind of pay what you think you owe. But if there's overs or unders at the end of the year, you can work with us to smooth that out. We shouldn't be stressing before Christmas about provisional tax.
General satisfaction with Inland Revenue engagements well down
TB
Yes, but we have to. Now a big part of your daily routine is interaction with Inland Revenue. And in recent years, you actually started conducting an annual survey of tax agents views about satisfaction with Inland Revenue. And the latest iteration was released at the Chartered Accountants Australia New Zealand tax conference that I was at two weeks ago. Now, this is a fully professional poll carried out by Colmar Brunton. And how did what was the survey' results?
Chris Cunniffe
That's right, Terry, we have run the survey for the last nine years in conjunction with Chartered Accountants Australia New Zealand. It's designed to elicit feedback from agents or tax professionals generally about how their engagements with Inland Revenue have gone. I guess the key out-takes from this year [is] it has been a tough year and the general satisfaction on Inland Revenue engagements is well down.
Let's take a step back and think why that is though, and acknowledge that Inland Revenue have just implemented probably the single biggest technical or system transformation in New Zealand history with millions and millions of accounts for taxpayers being moved from the old FIRST system to the new START system and the movement of that data went without a hitch. Unfortunately, as happens with all major transformations around the edges, there's a few challenges and these played out and all agents will be aware of these if they think back to what life was like between April and July this year.
TB
We'd rather not.
Chris Cunniffe
Yes, the auto refund, they thought this was a good idea, but in many cases the money was sitting with Inland Revenue for a damn good reason and the agents knew why it was there. And if you take a back to first principles, agents know their client's tax affairs and should be trusted to manage them. The getting hold of Inland Revenue on the phone became a nightmare. Correspondence slowed down, mixed views on this, but they stopped doing audits. So if your business consisted of advising taxpayers through audits, that was a bad thing as all the auditors were pulled in to answer correspondence.
The survey showed that the overall satisfaction with Inland Revenue has been declining since 2015, which corresponds with this massive transformation change they've been going through. It's now at 66%. It had been right up into the into the 80s.
People in public practice are the ones who are expressing the greatest dissatisfaction with the engagement. That probably makes sense because they deal with Inland Revenue on a much more regular basis than those in business. And to be fair, I think if you are in business, the new system is much more intuitive and much more immediate. And so, yeah, there's a winner in that area. If you're in practice, the frustrations we've talked about have come to the fore.
The dissatisfaction with phones is it's very, very strong. This is nothing Inland Revenue doesn't know. They get feedback all the time. The advantage of the survey is it's kind of like a mark in the sand and we'll be able to track over time how they perform. We would expect that next year we should see an upturn in satisfaction with contacting Inland Revenue by phone or by for processing purposes.
TB
Inland Revenue seems, however, to be very much driving its business model to take everyone going online. And from their business perspective, that makes sense. It reduces maintaining a large call centre staff. It probably would be comfortably the largest in the country by a long way, And I remember one time hearing from a person at Inland Revenue who had handled a call centre for a bank. And the one thing he hadn't realised just was what was involved is whereas for a bank call centre, the interaction was designed to be kept to two minutes or so. But for Inland Revenue, basically anything goes and that's something that he hadn't realised the issues around that. So the call centre issue is one I think we will want to watch very carefully how that proceeds, because the nature of tax being what it is.
And this is also a reflection of the fact that Inland Revenue is a largely trusted organisation. Understandably, people will want to talk to Inland Revenue and say "Have I got this right?" So it's a double edged sword for Inland Revenue. It might want to move people online, but its stature and trust within the community means it's going to get a lot of calls. Tax agents as well want a bit of reassurance because here's the thing. There are about 5200 tax agents registered and that would include organisations as big as PricewaterhouseCoopers, Ernst Young, Deloitte, the huge mega firms who have hundreds of accountants down to your sole practitioners. But the majority are sole practitioners. And it's lonely out there. And we carry the can if we get it wrong? So every now and again, it's nice to have a voice at the other end who said, yep, that's right or no, you need to do it differently.
Chris Cunniffe
It's a very good point. And there's a real.point about what is the psychology of engaging with your regulator. Clients in particular are worried when Inland Revenue contacts them. They think, have I done something wrong? So there's a there's a real fear. And Inland Revenue has invested a lot in trying to show off a friendly face. But they still are a regulator. Tax is a really big issue for people. It's not something that they feel qualified to do. And the stigma and the consequence of getting it wrong is significant penalties and interest. For an agent you wear that because if you have advised your client and got it wrong, the client is pretty grumpy and would expect you to be responsible for the consequences.
So I agree there is a need to be able to get the right assurance and the right level of engagement where appropriate. On the other hand, a really good system design would say we make it really hard for you to get it wrong. We give you all the easy and all the basic information you need. The most popular question asked of Inland Revenue call centre staff is "What is my IRD number?" There's an engagement if they can get rid of that, you would free the staff up to answer the high quality calls where there is genuine uncertainty and people do need to be guided. So Inland Revenue has got that challenge. But I think it's essential for agents in particular that when there is uncertainty, they can talk to somebody and figure out what's going on. So getting that service available and an effective fit for agents, I think is a top priority for Inland Revenue.
TB
Yes. That's an amazing thing. And people ring up asking "What's my IRD number?" That's going to be a very circular conversation. I think education is going to be very important about people understanding the system, and that's everybody. I think the classic example this year, it's emerged, is a one and a half million people got their prescribed investor rate wrong either under or over. So there is something where everyone needs to work out. There was an assumption that people knew more about this, were watching it regularly, and there was an assumption that because of the auto default rate, Inland Revenue and the KiwiSaver funds were all getting it right. So everyone was sort of assuming everyone else was looking after what they should have been looking after and of course, it landed up in a big mess in the middle.
So, yes, Inland Revenue is still going to have an educator role. I think in many ways it probably needs to be putting more resources into that. We run a self-assessment system, which means we're supposed to know and assess our own position. But even though our tax system is widely regarded as one of the more conceptually straightforward in the world, you get around the fringes of GST or the financial arrangements regime, or even the bright line test all those little quirks in them, which keeps people like myself in business, but means that you can't really work on a true yes, you can work out this tax for yourself.
Chris Cunniffe
It's interesting, over the years, Inland Revenue had pushed away the salary wage earner, the man or woman in the street. "You didn't need to file tax returns". So a lot of people were totally unaware of how Inland Revenue works, how your tax system works. And that leads to things like when you asked by your bank or by your fund manager, what is your tax rate? People are kind of oblivious to this. It led to the expansion of the tax refund companies charging for a service that anybody themselves could have done online, but people just weren't used to being in the tax system that the new platform now brings people in a lot more.
And the interaction with investment income and with PR, they live lifted a rock and found out there's actually quite a lot under there. That was everyone was oblivious to be it by design or by accident. People were on the wrong rates. I suspect that's an example of something that wasn't really thought through particularly well. It should take us a period of time to get it right before going forward it will be set and forget. But you're right, there's a number of other places where people get drawn into the system. So the bright line test, the other person who has one property, one investment property, you're now in the system. The increased amount of information that Inland Revenue will be getting from foreign tax authorities, from the banks and from the investment funds means that they will be asking questions if all your settings are not right. So I think there's a lot more engagement or interaction going to happen between individuals and the department.
TB
Yeah, that's definitely coming. Definitely. And the survey was fascinating to be part of it because the Commissioner then spoke immediately afterwards, talk about the wrong warm up act. How did you think she responded? She responded to the criticism that clearly could not be ignored, but also was also looking forward. How much confidence you draw from what her summary of where things were at?
Chris Cunniffe
So that it worked very well that I was able to report the survey. And one of the main issues out of the survey, if we take away the what's general satisfaction like in a year where there's a massive transformation, the biggest gripe that's been coming through had come from tax agents around Inland Revenue approaching their clients directly. And I think this was a philosophical thing in some ways from Inland Revenue, "we want to talk to people that ultimately, they're the customer. We can get there and share information with them".
But what that was doing was frustrating agents immensely. And we got really, really strong feedback from agents around that 72% of them said Inland Revenue had gone to their clients directly and we don't like that.
TB
Can you imagine if you're in business, any businessman and one of your rivals approach 72% of your clients? You could see why the tax agent community was seething.
Chris Cunniffe
Indeed, because in the feedback we got was things like this worries my clients needlessly" because the agent often would have it all under control as a GST refund about to be released. It'll cover that liability, it'll all be squared out and the client's got this phone call "you haven't paid your tax. What's going on." That undermines the agent in the eyes of the client. "I thought, Terry, I paid you to look after my affairs. I've got Inland Revenue in my ear saying I'm in arrears. What's going on?" It means that you as an agent have to then spend time talking to the client, calming them down. You probably can't charge for that.
So there was a lot of needless angst in their Inland Revenue has found that there were 72 letters or interaction, real written interactions going out to clients that probably should have gone to tax agents. They have worked through the system and have now read re-pointed those so that they will go to the agents in the first place and they will only go to the client where the agent becomes non-compliant. Or they will go to the client directly if there's thing's like a change in bank account number. That's proper, that's an updated security check.
TB
I hate to say this, but it's one of the more common frauds I've encountered where the tax agent alters a client's bank account details that refunds go into the agent's bank account. I encountered that a number of times. So Inland Revenue is absolutely proper to be sending authorities like that to clients as well as tax agents.
Chris Cunniffe
But what they have acknowledged now is their settings were wrong. I think it was a deficiency in the new system that they've got that it's not particularly geared around the New Zealand system and the way that we use agents. It is an off the shelf system. So it has needed some adoption.
But it was getting to the stage and Terry, I know you've been vocal on this yourself about Inland Revenue's engagement with clients. You and a number of others have been very vocal about this saying "This is wrong". And I've I talked to an awful lot of agents and they've been saying to me, is there a strategy at Inland Revenue to displace the agent, to essentially disintermediate, get them out of the system?
So I put that question at the conference and the Commissioner basically got up and her opening comment was, "Let me affirm the place of tax agents in the New Zealand tax system", which I think was music to the ears of tax agents. She then talked through the changes that have been made and the fact that they're kind of inverting the pyramid to say our default position is we'll engage with the agent. As an agent you can control this if you'd rather the client dealt with maybe the payroll or maybe that the GST, you can you can adapt adjust the settings to do that.
So I look, that was a major success because the agent community felt like they were banging on the door and not being heard. And I think we finally had pulled all the strings together and I was very grateful to the Commissioner for her immediate response and the fact she stood there and said, "look, this is where we see agents. This is what we're doing. We've got a strategy around it". I'm hopeful that in a year's time we're not talking about this.
TB
So am I. And I think also the other thing was interesting about your survey, and this is something we've seen when business transformation first came along. A lot of agents I was speaking to were nervous about it "have we got a role in the future?" But the survey shows very much the feeling is, "yes, we definitely have a role in the future" and they are adjusting their business model to something which is more appropriate to an advisory client, helping clients with cash flow issues and using tools like TMNZ and getting ahead of the tax issue so being proactive rather than reactive. And the survey showed those results, didn't it?
Chris Cunniffe
It did. And it's been a theme that we've asked for the last couple of years, essentially for the reasons that you ask. I talked about disruption so that the model of doing a basic tax compliance programme where you do everything for your client is largely dead because the software companies have got to the stage where clients can do a certain amount of it themselves. How far the client goes along that that process is a discussion between the agent and the client. But you're right, agents are looking to move up the value curve and be less about someone who will process a set of accounts and tell you six months or nine months after year end whether you made a profit or not to somebody who engages with you real time around how your business is doing.
TB
Well, I look forward to seeing the survey next year. And I think that we'll leave it there. Going to be an exciting twelve months ahead, another release coming forward. But. And so the commissioner reassured us about how they were managing. So it's a wait and see. But thank you very much, Chris, for joining us on the podcast. It's been absolutely insightful and fascinating. I really appreciate you coming over.
That's it for the week tax. Next week will be the final podcast of the year and we'll have a retrospective on the big events of the year. In the meantime, I'm Terry Baucher, and you can find this podcast on my website www.baucher.tax Or wherever you get your podcasts. Please send me your feedback and tell your friends and clients until next week. Have a great week. Ka kite āno.
This article is a transcript of the December 6, 2019 edition of The Week In Tax, a podcast by Terry Baucher. This transcript is here with permission and has been lightly edited for clarity.
You can also listen below.
We welcome your comments below. If you are not already registered, please register to comment.
Remember we welcome robust, respectful and insightful debate. We don't welcome abusive or defamatory comments and will de-register those repeatedly making such comments. Our current comment policy is here.