Jayne's Baby Bank C.I.C.
The charity shop that isn't a charity.

Charities Act 1992 s.63Operating as a charity shop without registration

Social media posts, Facebook descriptions, video content, and physical signage have described the operation as a "charity shop," "charity boutique," and "food bank charity" across multiple premises for years. The original Facebook profile bio for the operation read: "I have ovarian cancer, I launched a food bank, womens aid and baby bank to help as people in 2020" — embedding a health claim directly into the permanent public-facing identity of the operation from launch. An earlier operation under the name Baby Bank and Friends predates the main JBB brand — items were described as "on loan from the Baby Bank and Friends" in archived posts. The precise dates of this operation are unconfirmed but predate May 2022. A Facebook group was created on 21 May 2022 under the name "Jayne's Baby Bank & Charity Shop Newport Free Page" — using the word "charity" from day one — before being renamed "Jayne's Baby Bank SOUTH WALES Free Page" on 27 July 2022.

No Charity Commission registration has ever existed. The Charity Commission confirmed two applications were received and both failed: the first under "Jayne's Mother and Baby Bank, Food Bank & Charity Shop" (org. 5223055) did not proceed as information required was not fully complete; the second under "Jayne's Baby Bank" (org. 5223411) was refused in August 2023 on the basis of failing to meet the threshold of being a charity. Declared income in both applications was £3,000 and £500 respectively — both below the registration threshold. The applicant, Jayne Price, was formally notified of refusal on 20 October 2023. Despite this, the operation continued to use "charity" in its branding, signage, and online presence.

In February 2024, the operator submitted an official food business registration at Risca falsely declaring herself "CEO/trustee" of a "charity" with registration "Awaiting." A December 2023 inspection at the Pontypool premises recorded the operator claiming to distribute food "supplied by the Trussell Trust" directly to a Torfaen council officer during an official visit — the Trussell Trust formally rejected all claims of affiliation in September 2025, meaning a false affiliation was being stated in a regulatory inspection context. PayPal charity listings maintained by the operation continued to carry "charity" status descriptions after the investigation was well underway. In March 2026, despite Caerphilly CBC actively working to have false charity branding removed, the operator was personally photographed placing new "charity shop" signage on street corners in Caerphilly town centre.

DeliberateRegistration avoided and applications failed

Two formal applications to the Charity Commission were made and both failed. The first, under "Jayne's Mother and Baby Bank, Food Bank & Charity Shop" (org. 5223055), did not proceed due to incomplete information. The second, under "Jayne's Baby Bank" (org. 5223411), was formally refused in August 2023 for failing to meet the threshold of being a charity — with declared income of £3,000 and £500 respectively, both below the registration threshold. Jayne Price was notified of the refusal on 20 October 2023. Nothing prevents a further application.

The Charity Commission correspondence also directly addresses the FCA authorisation claim, stating: "In regards to the claim that the Commission had provided authorisation to use 'charity' in the business names… I think this is unlikely — but in any case I would have thought the onus would be on the person making the claim to demonstrate that had been the case." This official response predates the FCA's own July 2025 confirmation and represents a second statutory body dismissing the same false claim.

In a video recorded 13 February 2024 and subsequently deleted, the operator explicitly stated that charity registration was being avoided so that critics could not report the organisation to regulators. When the CIC was incorporated in November 2025, the operator immediately and falsely claimed it conferred registered charity status.

IdentityMultiple names across legal and operational contexts

The operator's legal birth name is confirmed by the England and Wales Civil Registration Birth Index as Carrie-anne Ridsdale, registered in Newport in the April–June quarter of 1980, with mother's maiden name recorded as Jenkins. This is directly significant: Director 2 on the CIC filing is Mrs Gail Jenkins — the same surname as the operator's mother. The public-facing persona is Jayne Price. Official documents — including the CIC36 contact field, Trading Standards papers, and Torfaen Council enforcement records — all reference Carrie-Anne Ridsdale. A Caerphilly CBC Subject Access Request of 398 pages documents at least seven name variants. A lease for the Pontypool premises (17 January 2023) lists the tenant as "Miss Jayne-Anne Carrie-Anne Ridsdale" — combining both identities in a single legal document. The £7,141 CCJ (case ref. 521MC287) was registered against "Ceri-Ann Ridsdale T/A Jayne's Baby Bank." The Aberbargoed eviction notice was addressed to "Ms Ceri-Anne Ridsdale." A publicly posted driving licence shows the name "Jayne-Anne Price."

At least three PayPal accounts have been used to solicit donations: @jaynesbabybank, @Jaynesbabybank100, and @jaynesbabybankrisca. The primary account is held under the name "Jayne R-Price" — a hybrid surname that does not appear on any formal legal record, combining the Ridsdale surname used in court and enforcement records with the Price surname used publicly. This name variant matches neither the CCJ debtor name (Ceri-Ann Ridsdale), the commercial lease name (Jayne-Anne Carrie-Anne Ridsdale), nor the CIC filing name (Jayne Price). The account description explicitly states "100% of profit goes towards the charity" — a false claim, as no charity registration has ever existed. The full PayPal fundraising analysis is documented in Finding 17.

Earlier trading identity — "Baby Bank and Friends." Prior to the establishment of Jayne's Baby Bank, the operator ran an earlier operation under the name Baby Bank and Friends — confirmed by archived Facebook posts in which items are described as "on loan from the Baby Bank and Friends." The precise dates of this operation are unconfirmed but predate the creation of the Jayne's Baby Bank Facebook group in May 2022.

Documented alias network — at least 13 confirmed or suspected identities. Investigative records compiled from archived posts, whistleblower evidence, IP address tracking, and platform records confirm the following alias accounts in addition to the primary Jayne Price and Carrie-Anne Ridsdale identities:

Investigative reports conclude that this multi-name pattern is not a standard use of a preferred name but a deliberate strategy to obscure accountability across multiple platforms simultaneously. The Peter Mal account's coordinated posting with the main JBB page and the practice of requesting critics' home addresses and employer details from community groups represents a documented pattern of using alias accounts for targeted harassment and intelligence gathering.

Phone number cross-check — verifiable from public filing. The contact telephone number listed on the public CIC36 filing (Companies House ref. 16838920) is 07521789261. A Facebook "Identify your account" recovery search using this number returns three abbreviated account entries: one consistent with C... R... (Carrie-Anne Ridsdale), one consistent with J... B... (Jayne's Baby Bank), and one consistent with D... J... This cross-check is reproducible by any member of the public using the number as published in the official filing. The presence of multiple accounts linked to a single CIC contact number is consistent with the broader documented pattern of parallel identity operation.

Alias accounts — confirmed by investigation. The investigation has confirmed through multiple forms of evidence that the operator has used at least two social media alias accounts: David Jones and Peter Mal. In addition to archived overnight livestreams in which the operator is visibly logged into these accounts, on 8 February 2026 the operator accidentally shared a screenshot of content while visibly logged into the David Jones profile — publicly confirming the attribution. The screenshot is archived and preserved. Both accounts have been used to publish content targeting critics, individuals who have left the operation, and HCT — a registered charity whose operator has been the subject of sustained public attacks documented across 74 unique source files in the investigation corpus spanning March 2023 to January 2026 (see Finding 14). David Jones additionally appears as a candidate match in the Facebook account recovery result described above.

CPUTR 2008 Reg. 5FareShare misrepresentation and Olio ban

FareShare confirmed in writing on 16 October 2025 that Jayne's Baby Bank has never been a member or received food via FareShare Go — directly contradicting repeated public claims. The operator's Olio account ("Cerii") was terminated in April 2022 following misuse. Food collected via Olio was publicly described on Facebook as FareShare-sourced. The operator was subsequently banned from the Olio Food Waste Hero programme following complaints from stores and volunteers. The full mechanics of the Olio operation — including the use of a fabricated identity and a food diversion scheme — are documented in Finding 04a below.

Fraud Act 2006 s.2 / CPUTR 2008The "Cerri" scheme — fabricated identity, food diversion, and volunteer exploitation on OLIO

Following scrutiny and bans of her primary accounts on the food-sharing platform OLIO, the operator created the alias "Cerri" / "Cerii" / "Cerri Price" to continue securing food collection slots from supermarkets including Iceland and Tesco. The account was presented to supermarkets and volunteers as belonging to the operator's daughter, who would attend collections in person. Whistleblower evidence and investigative records confirm that no such daughter exists. In a 2022 public post, the operator explicitly listed "Cerri Price" as one of her children's names alongside other names — the fabricated child was given a public family identity to make the deception sustainable across multiple supermarket relationships.

A documented message thread from 12 July records the "Cerii" account actively coordinating collection slots with messages including "Yes I can collect" and "Ready." The OLIO account "Cerii" was officially terminated with immediate effect in April 2022 following multiple reports of misuse. The misuse consisted of "snagging" collection slots allocated under OLIO's food-sharing terms — under which food is required to be distributed freely — and diverting the collected food to JBB shops or for personal and volunteer use rather than free distribution through the platform.

The food rebranding scheme. Food collected under the Cerri/Cerii OLIO account was subsequently presented on the Jayne's Baby Bank Facebook page as being from "FareShare" or described as "charity donations." When members of the public asked in comments whether the food shown was actually from OLIO, those comments were deleted. This deletion practice was documented by investigators and is consistent with a deliberate effort to maintain the false FareShare narrative — the same narrative that FareShare formally denied in October 2025.

Volunteer exploitation — the "Food Fairies" scheme. The operator recruited volunteers under the title "Food Fairies" to collect food under the Cerri/Cerii account and similar arrangements. Internal instructions permitted these volunteers to "take 20% or a green tray full" of collected food for personal use before the remainder was processed. Investigators note that these volunteers were recruited in good faith and may not have understood that the collection arrangement violated OLIO's terms of service — making them unwitting participants in a scheme that misrepresented the source and destination of donated food to the public.

Following the April 2022 termination of the Cerii account, the operator continued to create new alias accounts on OLIO to re-access food collection slots. A public comment from an independent witness confirms: "She had tried to set up a FareShare Go account. She hasn't stopped stealing food — she just keeps making fake accounts on OLIO and claiming that it's FareShare food." This witness reported the activity directly to OLIO and FareShare and had the account banned, but observed further fake accounts continuing to operate. The accounts operated under a fabricated family structure: the operator presented "Jayne" as an older mother and Carrie, Daniel, and associated names as her children — creating a network of nominally distinct identities all controlled by the same individual.

The Cerri scheme illustrates the operational relationship between the alias network documented in Finding 03 and the food sourcing misrepresentations documented in Finding 04. The false FareShare claims were not simply opportunistic — they were the public-facing layer of a documented food collection operation that relied on fabricated identities, circumvented platform bans, and diverted donated food away from the free distribution it was sourced under.

Brand rotationDeliberate successor brands after scrutiny

New trading identities have emerged after each episode of scrutiny: Jarmani's Charity Boutique (Caerphilly, June 2025), Second-Hand Land, and Community Shop One — linked by shared social media content, shop interiors, and staff. On 1 October 2025, a Jarmani's sign was found illegally attached to a Salvation Army clothing bank in Morrisons Caerphilly car park. In April 2026, following a Facebook page ban, operations were renamed "Jaynes BabyBank (Baby Jayne)" to bypass the platform ban. As of May 2026, the Caerphilly unit has been reclaimed by the landlord. The operator has publicly described the primary brand as a deliberate decoy, stating in two separate broadcasts: "The baby bank was the decoy all the while" and "So we need a decoy. So we made the baby bank." The investigation has additionally identified that a specific metric claim — describing the operation as moving "thousands of tons of stock" — was taken verbatim from the promotional material of Cwtch-Up, the registered charity (no. 1194295) operated by whistleblower Nicola Williams, whose charity number and name were also used without authorisation in JBB fundraising material. These admissions were made in the context of defending the operation against critics and were recorded in archived transcripts.

A parallel venture — "The New Caerphilly Bird and Small Animal Rescue Sanctuary TM" — was publicly launched in January 2026, with the operator claiming to have "taken over Caerphilly Bird Rescue," a locally known organisation whose original founder publicly and formally refuted this. No animal rescue CIC, charity, or company registration exists or has been confirmed for this venture. A trademark application (UK00004316067, Class 36 — fundraising only) exists with status "Application Published," not registered. A pending application is not a trademark, confers no exclusive rights, and creates no criminal liability despite public claims to the contrary.

On 24 January 2026, a stolen fox image was posted to the official Jayne's Baby Bank Facebook page, presented as if a fox had entered their property, captioned alongside fundraising promotion for the rescue venture. The image originated from the private TikTok account of David Lovett, who publicly confirmed the fox was in his home and challenged the misuse. The post was deleted with no correction or apology. A second stolen fox image, presented as "Our Venue" for the rescue, was subsequently traced to the Forest of Dean — confirmed by the original content creator as entirely unconnected to any rescue premises.

CredentialsNursing qualifications that do not exist — quietly amended after a year

The operator's Facebook profile originally listed the following qualifications: BA Hons Nursing at Cardiff University; Bio-chemistry diploma; CACHE Level 3 Award, Certificate and Diploma in Child Care and Education; Teaching Assistant Level 3 at Aspergers & Autistic Spectrum Disorder & Behavioural Resource Base; Profit Protection advisor at Retail and Profit Protection Management (listed twice); studied at Crosskeys; studied at Ystrad Mynach, Caerphilly; studied at Cardiff University. The "BA Hons Nursing at Cardiff University" entry was displayed publicly for over a year before being quietly changed to "BSc (Hons) Adult Nursing" — with no correction, acknowledgement, or explanation. Cardiff University has confirmed that neither qualification appears in their records for this individual. Cardiff University awards nursing degrees as BN (Hons) or BSc (Hons) only. No registration was found on the NMC, SCWOnline, or Education Workforce Council Wales for either name. A Freedom of Information response from the Education Workforce Council additionally confirms that Carrie-Anne Ridsdale has never been registered as a classroom assistant in Wales — directly contradicting her repeated public assertions of having served in a Special Educational Needs role for twelve years.

A Facebook post in October 2022 claimed "30 year careers" in child protection and safeguarding. The operator was born on 16 May 1980, making her 42 at the time of the post. A 30-year professional career in child protection would require having begun at age 12. Records from 2013 indicate she was listed as a Support Worker with Pride In Care during that year — a support worker role, not a nursing or child protection career. The investigation has established that she attended Crosskeys College (Coleg Gwent) and took a GNVQ in Health and Social Care — a vocational qualification roughly equivalent to two A-levels at Advanced level, and not a direct or guaranteed route into nursing at Cardiff University. Cardiff's nursing degrees have always required A-levels (normally including a science), BTEC Extended Diplomas, or an Access to HE Diploma, alongside GCSEs in English and Mathematics. Cardiff also never offered a "BA Hons Nursing" — their programmes have always been delivered as BN (Hons) or BSc (Hons). No evidence of any registered professional nursing or clinical career has been produced.

Additional specific claims documented across hundreds of archived transcripts and publicly fact-checked include: being "accepted to every university applied to with unconditional offers" — nursing unconditional offers are essentially impossible due to mandatory DBS checks, occupational health screening, and interview requirements; being "offered a Learning Difficulties nurse position during a university interview" — universities do not offer employment during admissions interviews; and completing "mandatory midwifery hours" and "labour ward and theatre hours" as part of nursing training — no verified record of any such placement exists.

B&Q employment — claimed executive role contradicted by photographic and witness evidence. The operator's Facebook profile listed "Profit Protection advisor at Retail and Profit Protection Management" — a role she has described in broadcasts as being "second to CEO," involving telling "the company how to make profits and where they were losing them" for "one of the largest companies in the world," with 20 to 25 years of claimed experience across sales, marketing, and profit protection. Archived photographs show her wearing a standard orange B&Q retail apron at a B&Q store during what appears to be a community or seasonal event. Former colleagues and local residents who worked with her have publicly recalled her as Carrie-Anne Ridsdale and as a sales assistant, not a senior manager. The Facebook profile lists this role as beginning in 1996 — when, given her confirmed birth date of 16 May 1980, she would have been 16 years old. A 16-year-old in a position described as "second to CEO" of a major multinational retailer is not credible. The cumulative arithmetic of her claimed work history is additionally irreconcilable: claimed 25 years in retail combined with claimed 12 years as a teaching assistant would represent 37 years of professional experience prior to university — placing the start of that career in her early childhood.

False authorityFalsely claiming FCA authorisation and regulatory accreditation

Between February 2023 and July 2025, the operator made repeated public claims that Jayne's Baby Bank had been authorised by the Financial Conduct Authority to use the word "charity" in its name. A deleted June 2025 video stated: "We're the only charity in Great Britain that's been authorised by the Financial Conduct Authority to use the word charity in our title." This claim is demonstrably false. The FCA does not regulate charities, does not authorise charitable status, and plays no role in approving the use of "charity" in a business name — that function rests with the Charity Commission and Companies House. The FCA confirmed in July 2025 that JBB is not on the Financial Services Register. Misrepresenting authorisation by a statutory regulator in a fundraising context may constitute a breach of the Consumer Protection from Unfair Trading Regulations 2008.

Separately, across multiple Facebook posts from December 2024 through September 2025, the operator repeatedly claimed JBB had "won a sustainability award by the CRS Accreditation." No body called "CRS Accreditation" exists. The reference is to a commercial self-submitted project award from The Green Organisation (CSR Awards), which does not constitute organisational accreditation, carries no regulatory standing, and is not connected to the Charity Commission or any regulatory body. When the award organiser was contacted for clarification, the justification for the award changed within hours in written correspondence, shifting from "recycling baby clothes" to "food and drink and healthcare" — demonstrating the absence of consistent verification criteria.

Health claims38 documented conditions — pattern of deployment in fundraising contexts

The ovarian cancer claim was embedded into the permanent public-facing identity of the operation from its founding. The original Facebook profile for "JaynesBaby Bank Price" carried the bio: "I have ovarian cancer, I launched a food bank, womens aid and baby bank to help as people in 2020." This statement — appearing in the profile description, not a passing post — means that every person who visited the page, every donor, and every organisation that considered partnering with JBB encountered this claim as a foundational fact about the operator. It was not a claim made once; it was the permanent stated identity of the operation from launch.

Across Facebook, livestreams, and FOI-related correspondence, 38 distinct medical conditions have been documented, including aplastic anaemia, blood cancer, bone marrow cancer, leukaemia, bowel cancer, ovarian cancer, womb tumour, brain tumour, bilateral knee replacement, epilepsy, sepsis, neutropenia, endometriosis, sleep apnoea, diabetes, hypothyroidism, ADHD, dyslexia, dyscalculia, dyspraxia, suicidal ideation, and Pica disorder, among others. No independent clinical verification of any of these conditions has been produced in the public domain.

The conditions listed as sourced from FOI documentation — dyslexia, dyscalculia, and dyspraxia — were self-declared by the operator in a 2022 email to Caerphilly County Borough Council to explain "difficulties with accounts and correspondence." Analysis of the Subject Access Request confirms these were submitted by the operator herself, not assessed by any clinical or official body. Investigators noted they functioned as "rhetorical tools" to excuse hostility and unprofessional behaviour toward the council.

Health claims are consistently deployed in direct proximity to fundraising appeals. In October 2022, the founding of Jayne's Baby Bank was explicitly framed around terminal health status — stating the operation was started because she was "shielding" with a "massive tumor, blood disorder and Aplastic Anaemia." In a post dated 23 December 2022, she stated she was "still in the palliative category" following a recent MRI — and in the same post immediately requested recommendations for a cleaner for both her private home and her Risca shop premises. In September 2025, during a livestream discussing her illnesses, she pivoted directly to: "Unless somebody wants to fund us for a big massive warehouse, what am I going to do?"

The aplastic anaemia cancer claim and retraction. In a Facebook post in 2022, the operator stated she had "aplastic anaemia which is a rare blood and bone marrow cancer." Aplastic anaemia is a bone marrow failure disorder — it is not classified as a cancer. When later challenged by critics on this misclassification, the operator stated on video: "Aplastic Anaemia isn't bone marrow cancer… a quick Google search will tell you that Aplastic Anaemia is not cancer." Both statements are on the public record. The condition was first presented as cancer to the public in a fundraising context, then disowned as "not cancer" when challenged — with no public correction issued to those who had originally been told it was cancer.

The operator has also repeatedly invoked the Cancer Act 1939 as conferring personal legal protection and "registered vulnerable adult" status. The Cancer Act 1939 restricts advertising of cancer treatments and confers no personal protection of any kind. These claims are legally false.

The documented contradictions between stated incapacity and observable activity are significant. While claiming to be "classed as palliative/terminal" and on shielding orders, the operator was concurrently managing five physical shopfronts and a warehouse and describing working "7 days a week" and "20 plus hours a day." She has repeatedly claimed to have "zero knees left" and to be awaiting knee replacement surgery, yet has been filmed running and carrying heavy items while clearing out premises. A medical document she partially revealed during a broadcast showed an endoscopy finding "no abnormalities, no lesions, nothing of any concern" — directly contradicting her bowel obstruction and tumour claims. The same document recorded her ECOG Performance Status as Grade 2, defined as capable of all self-care but unable to carry out work activities — a status she simultaneously contradicts by managing a multi-site retail operation.

The operator presents herself as "fully work-limited" and eligible for Personal Independence Payment (PIP), while declaring no salary from JBB. A Motability Finance Ltd lease agreement (ref. 96182837, commenced 6 September 2023, 36-month term) has been documented against the operator's details — confirmed via an Experian outstanding finance check showing "Record Found." Motability vehicles are exclusively available to recipients of the higher rate mobility component of PIP or equivalent qualifying disability benefit. The vehicle was therefore financed directly through a disability benefit entitlement, while the operator was simultaneously managing multiple retail premises and describing working "20 plus hours a day." She has stated that taking a formal wage would require JBB to pay sick pay during her frequent illnesses, which would result in "less mothers being helped." In a separate broadcast she described herself as: "Retired. Director of one of the largest children's charities in Wales and an influencer." The use of health status to simultaneously justify benefit reliance, explain non-payment of a director salary, and solicit public donations represents a documented pattern across the full period of the investigation.

EnforcementCCJ, council fines, fire prohibition orders, trading in violation

A County Court Judgment for £7,141 (case ref. 521MC287, County Court Online) was registered on 23 May 2024 against "Ceri-Ann Ridsdale T/A Jayne's Baby Bank" at 7 Meadow Road. As of 26 January 2026, court records confirm the judgment remains unsatisfied. The use of the "Ceri-Ann" name variant in this formal financial liability directly contrasts with the "Jayne Price" persona used for public fundraising.

Torfaen County Borough Council has issued fines to Carrie-Anne Ridsdale. A court summons for £1,105 in unpaid business rates was accidentally displayed live on camera in August 2025. A witness statement documents rent unpaid for over one year at the Pontypool premises, with landlords attempting to locate the operator.

Motability vehicle used for commercial purposes. The vehicle consistently used for JBB operations — documented at car boot sales, stock collection runs, and commercial activities — has been confirmed as a Motability Finance Ltd vehicle. Under the Motability Scheme's terms, vehicles must be used for the disabled person's benefit; use for business, deliveries, or commercial transport is explicitly prohibited and constitutes misuse. Motability Operations confirmed it investigated nearly 36,000 possible misuse cases in a single year, terminating vehicles in approximately 5,300 cases including unauthorised commercial use. Whether a formal misuse report has been made to Motability Operations in respect of this vehicle is not publicly known.

An independent Fire Risk Assessment at 5 Crane Street, Pontypool (September 2025) graded the overall risk to life as "Substantial Risk" with potential consequences described as "Extreme harm." Documented failures included extreme fire loading blocking escape routes, no valid electrical installation report, PAT testing carried out by an unqualified volunteer, a fire door found damaged and propped open, a faulty fire alarm panel described as "not operational," and zero evacuation procedures or staff training records. South Wales Fire and Rescue Service spent 15 months attempting to bring the premises into compliance. A return visit in September 2025 found more stock than on both previous visits with zero actions taken from an April 2025 Schedule of Works. SWFRS issued Prohibition Notice PNO1/0151 on 3 March 2026. On 7 April 2026, a spot check confirmed the shop was trading in violation — two members of the public were observed entering the premises, with stock and advertising boards on the pavement. Separately, an AD01 filing at Companies House dated 14 November 2025 records that the CIC's registered office was formally changed from 7 Meadow Road, Blackwood to 5 Crane Street, Pontypool NP4 6LY — the same premises that was subsequently subject to Prohibition Notice PNO1/0151 from 3 March 2026. As of the date of prohibition, the CIC's own registered office was an address where members of the public were legally prohibited from entering. The enforcement register was subsequently updated to "Enforced" and the premises remains subject to an Article 30 Enforcement Notice for ongoing breaches of Articles 8, 13, and 17 of the Fire Safety Order.

The Newbridge Road warehouse (The Donation Centre) was separately prohibited after SWFRS officers attending in March 2026 found the premises completely inaccessible — officers reported being "unable to enter without climbing onto a wooden unit and over stacked materials." Access was restricted solely to removal of materials. Management had previously refused officers entry in November 2025, claiming the site was not in use.

Pontypool Community Council declined a 2026 funding request after due diligence, stating JBB is "not the type of organisation that should receive funding." Caerphilly Social Services have formally stated JBB is "NOT endorsed and NOT allowed to make referrals" on their behalf.

Ongoing criminal investigation — Caerphilly. A Freedom of Information request for Environmental Health records relating to 14 Pentrebane Street, Caerphilly (FOI 25/1498) was refused by Caerphilly CBC on 9 January 2026 under Section 30(1)(a)(i) — investigations a public authority has a duty to conduct with a view to ascertaining whether a person should be charged with an offence. The council's decision states: "Part of the information requested is in relation to an ongoing investigation which the authority may be required to rely upon should it be necessary to instigate legal proceedings." The exemption was applied to protect the integrity of that investigation. This confirms that as of 9 January 2026, Caerphilly CBC had an active ongoing investigation at 14 Pentrebane Street with potential criminal proceedings in view.

A separate FOI request (ref. FOI 25/1318, Caerphilly CBC) sought confirmation of whether charitable rate relief (80%) or discretionary relief had been applied to three JBB premises — the Newbridge Road HQ, 68 Tredegar Street Risca, and 14 Pentrebane Street Caerphilly. Caerphilly CBC refused to confirm or deny under Section 41. The question of whether charitable rate relief — applicable only to registered charities or qualifying organisations — was applied to any of these premises therefore remains publicly unresolved.

A further FOI request to Torfaen CBC (ref. 25/418) sought confirmation of whether charitable rate relief or discretionary relief had been applied to the Pontypool premises. In the internal review, the Head of Legal Services confirmed the refusal under Section 40(2) personal data — noting: "The requested information is personal data as it relates to an individual as the entity known as Jaynes Baby Bank is not a registered company." This is a formal legal confirmation from Torfaen's own legal services that JBB, as an unregistered entity, is treated in rates law as an individual rather than a corporate entity.

TrademarkTrademarking "charity" without charitable status — and false legal threats

On 10 May 2023, a trademark application was filed for "JAYNE'S BABY BANK & CHARITY SHOP." At the time of application, no Charity Commission registration existed and the second application had not yet been submitted. The word "charity" was being trademarked while no legal basis existed for its use in the name.

The trademark has been used repeatedly to issue false legal threats. A public Facebook post stated: "Can I remind people that the Baby Bank is TRADEMARKED. Breach of Trademark Law is a CRIMINAL OFFENCE. No unauthorised photos/videos/usage without my permission." A separate post demanded: "Breach of our trademark — settle out of court will be £2,500 and a public letter of apology on to social media. I think that's fair." Both claims are legally false. Trademark infringement in the UK is a civil matter, not a criminal offence in most circumstances. A pending trademark application — which had not been registered at the time of these posts — confers no exclusive rights and cannot form the basis of any settlement demand. These public statements appear designed to intimidate critics and the public from documenting or discussing the operation.

LotteryUnlicensed raffles continued after registration lapsed

JBB formerly held a Small Society Lottery registration tied to the Aberbargoed premises from which the operator was evicted in November 2023. A Caerphilly Council FOI response confirmed no active raffle or lottery licence existed during relevant periods of 2025 and 2026. The operator publicly admitted she had never renewed the prior licence. Despite this, "grand raffles" and "football cards" at £5 per stake continued to be promoted online without required statutory disclosures.

GovernanceConcentrated control, blank filings, self-set pay, safeguarding concerns

The sole PSC holds over 75% of voting rights and the right to appoint or remove the majority of the board. The surplus use and asset-locked body fields on the CIC36 were submitted blank. The Articles permit directors to set their own remuneration including pension, sickness, and disability benefits. A member expulsion clause grants unilateral power to remove critics or whistleblowers where directors deem continued membership "harmful to the interests of the Company."

A Torfaen CBC FOI internal review (ref. PE/23245, 8 September 2025) confirmed that the council notified Jayne's Baby Bank of the content of an FOI request — including the specific documents to be disclosed — before the statutory recipient received the response. The council sent the full request details and a list of intended disclosures to the subject of the investigation on 22 August 2025, giving the operation advance notice of what official inspection records were about to be released. The internal review upheld this as standard third-party consultation practice. No consultation log was found to exist.

A separate internal review by Torfaen CBC (ref. 25/418, 6 October 2025) confirmed that JBB is not a registered company, and that business rates information therefore attaches personally to the individual operator rather than to a corporate entity. The Head of Legal Services stated: "The requested information is personal data as it relates to an individual as the entity known as Jaynes Baby Bank is not a registered company." This formal legal determination has implications for the accountability of any financial liabilities, rate reliefs, or public obligations connected to the operation.

Facebook creator monetisation income has been documented as being used to fund commercial premises costs. In a publicly archived transcript, the operator stated: "Dan set it up now so that the money that we earn from the Facebook goes straight into the money that we'll pay for the rent for the shop. So that's brilliant, isn't it? Because this month we've paid for at least one shop rent out of the Facebook money." The same transcript includes: "I am the influencer for it. So, you know, technically it should be my wage, but I don't..." — an admission that social media income is being treated as personal income while simultaneously claiming no wages are taken. Documented Meta creator payments range from approximately $51–$506 per month across recorded periods in 2025. In a separate broadcast, the operator publicly stated that critical engagement from those opposed to the operation directly increases her income: "Facebook pays me to put up with these people. By unblocking them, we should triple how much we're going to get paid for all their comments on Facebook." The operator has separately stated: "When you are running a 6 figure business with no business plans, out here winging it 7 days a week, giving all the profits to Mothers and babies in need." A claimed six-figure turnover is inconsistent with the financial picture presented to regulators and the public.

Volunteers were offered structured store credit payments across a documented rate card: £40 for an 8-hour day shift, £50 for a 5pm–10pm evening shift, and £20–£25 for shorter weekday shifts. The operator publicly described these as a "gesture of goodwill" declared to HMRC and DWP. Under HMRC guidance, calling a structured payment "goodwill" does not alter its legal classification — if it functions as payment, it will be treated as such. This may reclassify volunteers as workers entitled to the National Minimum Wage, holiday pay, and employer tax obligations, and may expose benefit-claiming volunteers to undeclared income sanctions.

Unlicensed collection jar activity — vulnerable volunteer. The investigation documented a case in which a volunteer described by observers as having cognitive impairments was sent out to solicit public donations using unlicensed collection jars. A Freedom of Information response confirmed that no active raffle or lottery licence existed during the relevant period. Street and public collections require a licence under the Charities Act 1992; directing a vulnerable individual to conduct unlicensed collections without legal oversight raises concerns under both charitable fundraising law and the duty of care owed to volunteers.

House fire donation collection — pattern of conduct. On at least one documented occasion, Jayne's Baby Bank publicly announced itself as "the only official collection point" for donations intended to support a local family who had lost everything in a house fire. Following the collection, the affected family confronted JBB regarding items they had not received. The family was subsequently blocked and publicly ridiculed on social media. This pattern — public charitable appeal, disputed distribution, blocking and dismissal of those who challenged the outcome — is consistent with the conduct documented in the Ukraine appeal material in Finding 18 and the Cerri food diversion scheme in Finding 04a.

Council enforcement — reported arrest of official. The operator publicly broadcast an incident in which she claimed to have had a council representative arrested at her doorstep while the individual was attempting to carry out official duties. Following the incident, she stated publicly that she was protected from such actions by virtue of her status as a cancer patient and as the director of a charity. Both of those claimed statuses are contested throughout this document. Separately, Gwent Police confirmed they had no knowledge of a subsequent police-related claim she made on her public platform in connection with the same period, indicating a pattern of misrepresenting official engagement.

Morphine — public promotion and driving concern. In a January 2026 livestream, responding to an investigation commentary about a post referencing alcohol combined with prescription morphine, the operator stated: "Can I not have a night off and get shitfaced in a hot tub with a Baileys and a morphine pill that I'm prescribed?" and later in the same broadcast: "Any donations that go in the box go to my Baileys hot tub and morphine fund." The operator has referenced morphine use across multiple broadcasts and transcripts. Separately, archived footage — referenced in the investigation's YouTube archive under "DELETED Morphine Behind Wheel" — raises concerns about the operation of a motor vehicle while under the influence of prescription medication. The vehicle used for operational activities has been confirmed as a Motability Finance Ltd vehicle (see Finding 09). Driving under the influence of morphine is an offence under Section 5A of the Road Traffic Act 1988, regardless of whether the substance is prescribed.

Documented instances exist of the operator publicly advising vulnerable mothers not to engage with social services, in a context where Caerphilly Social Services have formally confirmed JBB is not endorsed and is not authorised to make referrals on their behalf. A Facebook post dated 3 October 2022 made the opposite claim — stating that social services had "acknowledged we are registered with CCBC" and had "asked us to make referrals." This is directly contradicted by the formal denial from Caerphilly Social Services. Directing vulnerable individuals away from statutory services without professional qualification or oversight, while simultaneously claiming false endorsement from those same services, represents a serious safeguarding concern.

A documented pattern exists of serious public allegations against individuals who questioned the organisation or left its operation. In one documented case in 2022, a member of the public who challenged whether JBB was a registered charity was publicly labelled a paedophile and compared to Jimmy Savile on the JBB Facebook page — his DBS certificate, published in response, showed "NONE RECORDED." In a separate incident, a former volunteer was publicly named on Facebook and accused of stealing approximately £5,000 in cash and stock, lying about a prison record on his DBS form, and making female staff uncomfortable. The post was publicly visible and unredacted. Making serious criminal allegations against named individuals on a public social media platform raises significant concerns under defamation law and UK GDPR.

Offensive Weapons Act 2019Unsanctioned knife amnesty — no police authorisation, CCTV disabled

In April and May 2024, the operator announced and ran a knife and weapon surrender scheme for young people from the Pontypool premises. In her own words on a public livestream: "We're gonna turn the CCTV off. I'm not interested in your name." A follow-up video showed her handling a surrendered knife in a bag, stating: "I grabbed a bag because I thought, well, I don't want my fingerprints all over it." She also publicly stated: "If you feel like you wanna stab somebody… can you go in contact with us? We can give you a number and set up counselling."

Under UK law, knife amnesty schemes may only be run by police or organisations formally coordinated and authorised by police forces. Private collection, handling, or storage of surrendered weapons without such authorisation may constitute an offence under the Offensive Weapons Act 2019. Deliberately disabling CCTV during collection of potentially illegal weapons could obstruct future investigations. Handling weapons without proper protocols compromises forensic integrity. Offering unqualified counselling referrals to young people experiencing violent ideation — without clinical training, safeguarding clearance, or a formal partnership with a qualified mental health organisation — places vulnerable young people at significant risk. The operator claimed this was "the first time anybody's ever done this in the UK for children" — a claim implying official endorsement that did not exist.

Platform conductFacebook ban, immediate profile rename, and TikTok conduct during active investigations

On 21 April 2026, the primary Jayne's Baby Bank Facebook page was removed by Meta. Within days, the operation reappeared via a renamed profile — a documented pattern of platform identity-switching consistent with the broader name-variant history documented in Finding 03. As of 8 May 2026, the Facebook ban remains in place.

The associated TikTok account (@communityshopone) has continued posting throughout this period. In the week of 12 May 2026 — while the operator is subject to an active Caerphilly CBC criminal investigation, a live fire safety Enforcement Notice, and an unsatisfied £7,141 CCJ — content was published on the TikTok account that mocked the deaths of workers associated with HCT, a registered charity. No retraction or apology has been issued.

This conduct sits within a documented pattern of public attacks on HCT and its operator Hayley Thomas spanning from at least March 2023 — recorded across 74 unique source documents in the investigation corpus, with named references to Hayley Thomas appearing in 74 files and HCT referenced in 103 files. Attacks include allegations about charity vehicle use, personal benefit claims, and coordinated attempts to associate HCT with unrelated controversies. The corpus also records 78 harassment-related references across 49 unique source files, with the operator repeatedly threatening critics and members of the public with malicious communications complaints and police referrals — a pattern of using legal threats to deter documentation of the operation.

The investigation has further confirmed through archived livestream footage that alias accounts including David Jones and Peter Mal — attributed to the operator — have been used to publish content targeting HCT, Hayley Thomas, and individuals who have left or criticised the operation. The use of alias accounts for this purpose is consistent with the identity-switching pattern documented in Finding 03 and the platform ban evasion documented above.

Environmental Protection Act 1990 / Protection from Harassment Act 1997Retaliatory fly-tipping — on-camera admission, targeted at a registered charity's premises

In approximately April–May 2023, waste was deposited at Station Place, Risca — immediately adjacent to the Big Risca shop — and subsequently moved to the doorstep of The Pantri, the premises of Community Volunteers Wales (CVW), a registered charity (Charity Commission no. 1191383). Photographs dated 27 April and 4 May 2023 document both the waste at Station Place — where a Jayne's Baby Bank & Charity Shop A-board is visible in the foreground — and the waste deposited outside The Pantri the following morning, which included mixed refuse, cardboard, and rusting paint tins constituting controlled waste under the Environmental Protection Act 1990. A delivery receipt found in the dumped waste was traced to items previously donated to Jayne's Baby Bank.

On-camera admission — made in advance. The operator filmed herself on her private Instagram account (TheAlchemistMagician) outside the Big Risca shop while the waste was lined up, making an explicit verbal announcement of what she was about to do and why. The videos were subsequently leaked to the investigation and published on the Sherlock YouTube channel on 23 February 2026. The verbatim transcripts of the two clips are as follows:

Context and motivation. The transcripts make the motivation explicit: the fly-tipping was a direct response to a council fly-tipping report made against the operator by the recipient. The statement "even the council told me you were reporting me" — if accurate — raises a separate concern about the disclosure of complainant identity by a local authority, noted here without assertion. The waste outside the Big Risca shop is described in the video as items the operator no longer needed, presented as material for the retaliatory dump.

Police response. Gwent Police were contacted following the incident. Despite the videos, photographs, and provenance receipt, police advised that prosecution was not possible on the available evidence — stating that the operator cannot be clearly seen in the footage (only her shadow, voice, and vehicle) and that the advance announcement combined with the next-morning fulfilment was not considered sufficient proof of responsibility. Police recommended installation of additional security cameras and noted that direct intervention in similar situations had in some cases led to escalation including arson. No charges were brought.

This incident predates the Newbridge fly-tipping documented in Finding 15 by approximately three years and involves the operator herself rather than an associate. The targeting of a registered charity's premises — announced on camera, executed overnight, and confirmed by photographic evidence the following morning — represents a documented pattern of using physical environmental offences as a tool of intimidation against organisations that have made formal complaints about JBB.

Environmental Protection Act 1990Fly-tipping at St David's Hospice Care — and a false partnership claim denied in writing

Residents and members of the public raised concerns about repeated fly-tipping outside the St David's Hospice Care charity shop in Newbridge. Video footage and CCTV images, sourced from the investigation group and the Newbridge premises, document waste being deposited outside the shop during late evening hours when the premises was closed. Items observed include multiple black refuse sacks, donation bags, and bulky household goods including duvets. The individual responsible has been identified by those familiar with him as Daniel-James Ridsdale — listed as a subscriber on the Jayne's Baby Bank C.I.C. incorporation documents (Companies House ref. 16838920) at the same address as Director 1. A silver Honda vehicle, registration WF11 TZH, is consistently seen at the location during the relevant incidents.

Fly-tipping is a criminal offence under Section 33 of the Environmental Protection Act 1990. Local authorities are empowered to investigate, issue fixed penalty notices of up to £1,000, and pursue prosecution — with a maximum penalty on conviction of an unlimited fine and/or 12 months imprisonment on summary conviction, or up to 5 years on indictment for the most serious commercial cases. The identification of both the individual and the associated vehicle provides a clear evidential basis for referral to the local authority environmental enforcement team and, where applicable, Gwent Police.

False partnership claim — denied in writing. In a public social media post, the operator claimed that JBB were "designated collectors" at St David's Hospice Care, attending "daily at 4:30pm" to collect items the charity "can't sell," stating this was done "with permission" as part of a "partnership to cut down on waste." St David's Hospice Care has confirmed in writing: "We can confirm that St David's Hospice Care does not work collaboratively with Jaynes Baby Bank." No partnership, designated collector arrangement, or permission to attend the premises exists. This is the eleventh documented instance of a claimed affiliation or partnership being formally denied by the named organisation.

Separately, Carrie-Anne Ridsdale herself has been observed engaging in fly-tipping during a livestream on her private Instagram account "TheAlchemistMagician," recorded and archived as part of the investigation. This represents fly-tipping conduct documented across two members of the same household, both named in the CIC incorporation documents.

Police contactReported police involvement, harassment investigations, and 18 documented public denials

Multiple sources from early 2026 reference reported police contact in connection with the operation's online conduct. In February 2026, whistleblowers noted that police were actively monitoring the operator following a series of criminal accusations she had published online. On 25 March 2026, the operator publicly posted that content had been "passed onto the police as continued malicious communications from the SAME CHARITIES AGAIN" — one of multiple documented instances in which the operator referenced active police files. In a separate undated broadcast, the operator stated: "because as soon as we got the number, we sent in a document to say, these police files are open on these people for malicious communications, and harassment, and all the rest of it."

From March 2026, investigative monitors noted a 24-hour period during which the operator was absent from her home, with the property in total darkness while her vehicle remained parked outside — described as inconsistent with her established patterns. This period coincided with community reports of a possible police detention and the subsequent reported use of a name variant. The name "Hannah" — previously associated with a named JBB worker who left the operation in 2023 — reappears in two signed posts dated 9 and 17 March 2026, after an absence of over two years from the corpus. Whether this represents a coincidental reuse of a staff name or reflects a reported bail condition is a matter for official record. The investigation notes the timing without asserting a conclusion.

Alias accounts used to amplify health claims. The Daniel James alias account has been documented deploying the same illness narrative used by the operator herself — posting in response to critics on third-party pages that the operator has "a massive tumor and aplastic anemia and has to have regular treatments of tumor suppressors and blood transfusions." This represents the health claim apparatus operating across multiple nominally separate accounts simultaneously — the operator making the claims in her own name, and alias accounts repeating and defending them in external forums where the operator's own account may not be present or credible.

18 documented public denials. Across 16 video transcripts and 2 written posts, the operator has made at least 18 distinct public statements denying arrest, charge, or interview by police. These span multiple specific categories of allegation — assault, bank card theft, criminal damage, scamming, baby bank operations, and statements made about named individuals online. Two written denials are dated 16 February 2026. The remainder are undated video transcript entries from archived broadcasts. The volume, specificity, and repetition of these denials — each responding to a different specific allegation — is itself a matter of public record.

Selected documented denials from the corpus: "I've never been arrested or interviewed by anything, by the police whatsoever" — "That's why I've never been arrested because there is nothing to be arrested for" — "The police have never arrested us on anything to do with anything going on here in our baby banks, anything, or our rescues" — "I've never been arrested for scamming any money" — "I was never arrested or charged for assault or theft and use of her bank card. I have never even been interviewed over it" (written post, 16 February 2026). Whether any of these statements remains accurate is a matter for official record. What is documented is that they were made — repeatedly, publicly, and on specific dates.

Fraud Act 2006 s.2 / Charities Act 1992 s.63PayPal fundraising — false charitable claims, multiple accounts, and identity concealment on live donation platforms

At least three distinct PayPal accounts have been used to solicit public donations for Jayne's Baby Bank: paypal.me/Jaynesbabybank, paypal.me/Jaynesbabybank100, and paypal.me/jaynesbabybankrisca. All three operated under charity-adjacent branding while no Charity Commission registration existed. PayPal's UK User Agreement generally limits individuals to one personal and one business account; operating multiple accounts under similar charity branding without clear disclosure as to which legal entity receives funds materially complicates financial accountability.

False charitable claims on live fundraising accounts. PayPal profile descriptions have explicitly stated: "Jayne's Mother and Baby, Food Bank and Charity shop. 100% of profit goes towards the charity" and "We run charity shops and foodbanks in Wales… 100% of the profits go back into helping and feeding families." Both statements were made under a charity framing on a live fundraising instrument at a time when the Charity Commission had already confirmed — following two failed applications — that JBB does not meet the threshold of being a charity. Soliciting donations while representing an organisation as a charity when it is not may constitute an offence under Section 63 of the Charities Act 1992.

Identity concealment on the primary donation account. The primary account (@jaynesbabybank) is held under the name "Jayne R-Price" — a hybrid surname constructed from the Ridsdale surname appearing in court records and the Price surname used for public branding. This name appears on no formal legal record. It does not match the CCJ debtor name (Ceri-Ann Ridsdale), the commercial lease name (Jayne-Anne Carrie-Anne Ridsdale), the CIC filing name (Jayne Price), or any of the seven name variants documented in official records. A person donating via this link has no straightforward means of identifying the legal entity or individual who has received their money, or of connecting that recipient to outstanding liabilities including an unsatisfied £7,141 County Court Judgment.

"Friends and Family" payment instruction. The operator has publicly encouraged donors to use the PayPal "Friends and Family" option when making payments. While voluntary gifts via this mechanism are not inherently improper, directing payments for goods or services — including shop stock — through the Friends and Family route avoids commercial transaction fees and removes standard buyer protections. Where this instruction was applied to payments that were not genuine voluntary gifts, it would constitute a breach of PayPal's terms of service and potentially misrepresent the nature of the transaction.

The operator has stated publicly that using digital payment methods makes the operation transparent: "not a money launderer because it's traceable." This claim is made in the context of operating multiple PayPal accounts under a name that appears on no formal record, linked to an organisation whose two Charity Commission applications both failed, and whose CCJ remains unsatisfied. The traceability of individual transactions does not address the accountability questions raised by the identity and charitable status issues documented above.

Fraud Act 2006 s.2 / Charities Act 1992Donation diversion, charity number misuse, and the Ukraine appeal — whistleblower account

Nicola Williams, founder of the now-closed registered charity Cwtch-Up (no. 1194295), has provided documented evidence of a series of incidents spanning 2022–2023 in which the operator used Cwtch-Up's name and charity registration number without consent in JBB fundraising material. In documented message exchanges, Williams repeatedly demanded removal of her charity details — on 1 April 2022 stating: "Take my fucking name off anything you share. I am not involved in any of your dodgy dealings. If it's not off within the next half hour I'm ringing the police. Stop using my charity name and number too." The operator responded: "Ring the police. I will tell them everything." Despite repeated explicit withdrawal of consent, the association continued.

Fabricated correspondence on Cwtch-Up letterheaded paper. Williams alleges that the operator produced letters on Cwtch-Up headed paper to present to businesses as authorisation for donation collections — without Williams' knowledge or consent. These letters were used to solicit items from businesses under the false impression that Cwtch-Up was involved. Williams states: "She had made letter headed paper and written a letter to give to businesses to collect stuff for me to take to Ukraine. I told her countless times to stop because she was using my charity number and keeping the donations herself."

Ukraine appeal — donations disputed, counter-narrative refuted by video evidence. JBB has repeatedly claimed, across multiple broadcasts from 2024 through September 2025, that Williams ran a "fake Ukraine appeal" and stole JBB donations. Williams categorically denies this and has provided video footage recorded at the refugee centre in Przemyśl, Poland — approximately 10km from the Ukrainian border — showing her delivering aid to a midwife operating a Polish Red Cross ambulance evacuating Ukrainians in urgent medical need. This footage, archived and published by the investigation in September 2025, directly contradicts JBB's repeated "fake Ukraine" claims. The investigation notes that JBB continued to repeat the fake Ukraine narrative in public broadcasts after this counter-evidence was published.

Uganda container claim. The operator publicly solicited sponsorship for a shipping container to support "Mothers in Uganda," claiming to have been doing this "unofficially for 5 years" — a claim that predates the 2022 Russian invasion of Ukraine. Williams alleges the Uganda appeal was introduced after the Ukraine appeal came under scrutiny, as a means of diverting attention from the destination of collected goods. She states: "I don't believe she had any contacts or sent anything to Uganda. She said it to one up Ukraine. She needed shipping containers to fill with the stuff she was hoarding." The operator was at the relevant time in possession of a 7.5-tonne box lorry parked at her home address.

Police and social services reference — operator's own words. In a transcript of message exchanges, the operator herself wrote: "Police have referred me to social services. Do you think that's because they arrested me and fucked up big time?" This statement — made in private correspondence, not a public broadcast — is inconsistent with the repeated public claim of no police involvement in connection with the operation.

Cwtch-Up (registered charity no. 1194295) closed in early 2023. Williams has attributed the closure to sustained harassment, reputational damage, and investigation pressure resulting from her association with JBB activity. During its period of operation, the charity documented delivery of over 200,000 meals locally. The investigation notes that the operator has publicly claimed credit for "shutting down" Cwtch-Up — a claim that is directly contested by Williams and is unsupported by any regulatory decision.