What he is saying is clear. But is this true? It drives the proverbial coach and horses through the stakeholder cap on charges. If it is not true, what is the purpose of: "13. .. result in the provision of benefits for or in respect of members"?

IMHO, he has drawn the wong inference from the wording. I was invlved in all of this back in the Stakehoder development days. A very restricted list of things are specifically defined as "expenses" which can be charged in addition to the originally 1% now AFAIK 1.5%.

IIRC Audit fees and Stockmarket spreads were "expenses" which could be charged but Stamp Duty Reserve tax could not be charges unless it was applied on the day incurred and did not exceed with all other charges the 1/365 of 1%. As SDRT was not usually known until a week or two after transactions it could not be applied late as it might hit funds not invested at the time the cost was incurred and miss funds which had exited in the meantime. The fund providers were not permitted to take "Stocklending" profits on shares within the OEICs used for Stakeholder as this would have breached the "not for provision of benefits to members" rule referred to above.

In short; IMHO there are "expenses" in excess of the "charges" cap which can be recovered in addition to the "Charges" but these are very strictly limited and did not "drive a coach and horses" through the regs.