Memorandum submitted by Which?
Thank you very much for the opportunity to respond
to the Committee's inquiry into unclaimed financial assets.
Which? believes that banks and other financial
institutions need to put greater effort into reuniting unclaimed
financial assets with their owners. Where the rightful owners
cannot be located we support the money being released to fund
worthy causes, provided the consumer (or their heirs) retains
a legal right to the money should they come forward to claim it.
We welcome the announcement that the Government's
proposed scheme will provide a legal right for account holders
to reclaim their money at any time.
In the longer term the Treasury should examine
the scope to expand the scheme to include unclaimed assets held
by insurance companies and other financial institutions.
We agree with a 15 year definition for dormancy
as this provides a sufficient safeguard to ensure the scheme only
covers genuinely unclaimed accounts, rather than accounts which
are only temporarily inactive.
It will be important that the self-regulatory
nature of the scheme provides sufficient incentive for banks to
The BBA/BSA scheme allowing consumers to fill
out a single form for a number of banks is a useful tool, which
avoids the need to approach each bank individually.
We believe the BBA's "10 pledges from banks
to personal customers on dormant bank accounts" could be
improved by requiring banks to:
Take all reasonable steps to trace
the owners of dormant accounts. This should include writing to
customers more than once and using other methods such as telephone
Apply the principles of cost-benefit
analysis to their efforts to reunite dormant accounts with their
owners. Banks should be required to make greater effort, over
and above the BBA's minimum standards, if the amount of money
in the dormant account is significant.
Publicise and promote the scheme.
Which? believe that the Banking Code should
be amended to prohibit new or unreasonable charges being made
to dormant accounts. Existing charges should be suspended when
an account is made dormant.
We would welcome a debate on how banks and other
financial institutions will be fulfilling the requirement to treat
dormant accounts holders fairly.
There are currently several separate schemes
which consumers have to search to find unclaimed assets. Which?
believes that the option of establishing a central database, which
consumers would be able to search for unclaimed assets, should
be examined. However, the Government and any financial institutions
involved should ensure the establishment of any database does
not breach the requirements of the data protection act, and contains
safeguards preventing consumer detriment.
There should be a full and open consultation
on the possible uses to which unclaimed assets could be deployed.
Which? believes there are strong arguments for investing a proportion
of the money raised from unclaimed assets to promote financial
inclusion and increase access to generic financial advice. Otto
Thoresen, Chief Executive of AEGON, is currently undertaking a
study, on behalf of the Treasury, examining the feasibility of
developing a national approach to generic financial advice. We
believe unclaimed financial assets could be a way of funding,
at least in part, any national approach to the provision of generic
advice identified by this review.
UK UNCLAIMED ASSET
The Treasury has indicated the key principles
underlying the proposed UK scheme will be:
wherever possible, to reunite account
holders with the assets that are rightfully theirs;
to provide a legal right for account
holders to reclaim their money at any time;
to take a light touch approach which
minimises the running costs for the scheme and participating institutions
by, wherever possible, building on the existing infrastructure,
in order to maximise the money available for reinvestment in the
To take account of better regulation
principles. The proposed UK scheme will therefore differ significantly
from other international arrangements in being in part a self-regulatory
scheme. It is proposed that legislation will enable, but not compel,
banks and building societies to transfer funds held in dormant
accounts. Banks and building societies have committed to work
with the Government to design and participate in the UK scheme.
Which? welcomes the confirmation that the scheme
will provide a legal right for account holders to reclaim their
money at any time. We also welcome the intention to minimise the
running costs of the scheme, in order to maximise the amount of
money that can be released to worthy causes.
We have some concerns about the self-regulatory
nature of the scheme. The Government will wish to be confident
that a voluntary scheme will provide sufficient incentives for
banks and building societies to identify and to transfer money
held in dormant accounts. Further action may be necessary if this
proves not to be the case.
The Government should also publish details of
the banks participating in the scheme, the policies they are using
to identify dormant accounts and the amounts of money transferred
to the central reclaim fund. This will enable public pressure
to be brought to bear on any banks not participating in the scheme.
The proposed definition of an unclaimed asset
within the United Kingdom banking sector, and whether the scope
of assets identified for inclusion within the scheme is appropriate;
The Government and the banking industry have
agreed that the definition of an unclaimed asset should generally
cover bank accounts where there has been no customer activity
for a period of 15 years. As can be seen from the table below,
this would mean the amount of time before a bank account is defined
as unclaimed in the UK would be longer than that of many US states
and other countries, but similar to that of Ireland.
|Country or US State||Definition
|New York||5 years
|New Zealand||6 years
Which? agrees that the proposed definition of an unclaimed
asset should generally cover bank accounts where there has been
no customer activity for a period of 15 years. We believe this
provides a sufficient safeguard to ensure the scheme only covers
genuinely unclaimed accounts, rather than accounts which are only
The intention is that in the case of fixed term accounts
or accounts with maturity dates, the 15 year time period will
begin at the end of the fixed term. We can agree to this provided
the banks pay a reasonable rate of interest on fixed term accounts
that have matured.
In Ireland, an account is classified as dormant if during
the dormancy period no transaction has been effected by the account
holder. A transaction is defined as a deposit or withdrawal from
the account. In the US, customer activity is generally defined
as making a deposit or withdrawal, or otherwise communicating
in writing with the bank to indicate a continuing interest in
the account. Many US states require banks to notify customers
that an account is about to be classified as unclaimed, enclosing
a standard form. If customers sign and return this form then the
account is not classified as unclaimed.
The Treasury consultation indicates that as a minimum "there
must be no customer-initiated transaction in relation to an account
in order for it to be transferred. However, institutions may choose,
in addition to treat other activity short of an actual transaction
as an indication that a customer is not dormant".
We are concerned that banks may use this exemption to avoid transferring
assets to the scheme. The Treasury should provide further detail
as to what "other activity" they believe could be used
as an indication that an account is not dormant. Banks should
be required to publish details of their definitions of "other
activity" and to justify any exemptions.
We believe it would be sensible for banks to aggregate accounts
held by one customer. For example, if a consumer holds a current
account and a savings account with the same bank and undertakes
regular deposits and withdrawals on the current account, then
the savings account should not be classified as unclaimed.
»The scope for extension of the scheme, or for another
scheme, relating to unclaimed assets held by other financial institutions,
such as insurance companies and National Savings & Investments;
Which? believes that, in the longer term, there is scope
to extend the scheme to unclaimed assets held by other financial
institutions. In Ireland, the scheme, established by the Dormant
Accounts Act 2001, initially covered bank deposits. The scheme
was expanded to unclaimed assets held by life insurance companies
by the Unclaimed Life Assurance Policies Act 2003.
We have compiled a list of the types of unclaimed assets
that are currently part of schemes operated in other countries
and US states.
|Type of asset||Example
|Bank accounts||Including savings accounts; current accounts; Certificates of Deposit; credit balances held in loan, credit card and mortgage accounts.
|Shares, investment funds, bonds and dividends
||Unclaimed shares, dividends, bonds, mutual funds (unit trusts); money held in trading accounts; proceeds from compulsory acquisitions and takeovers.
|Insurance policies||Matured endowments or other insurance-based savings products; annuities; life insurance policies.
|Demutualisation shares||Unclaimed shares issued as a result of a demutualisation, or the proceeds from the sale of shares.
|Pensions||This can include Individual Retirement Accounts (IRAs). In some states, these are only considered unclaimed if benefits have not been paid by a certain age.
|Contents of Safe deposit boxes||This could include, cash, jewellery, papers, share certificates. Contents are typically held by the State for a number of years before being sold at auction and the proceeds retained should the rightful owner come forward to claim them.
|Other||Unpaid wages and uncashed pay cheques; unclaimed gift certificates, travellers cheques, utility deposits, mineral interests.
In deciding whether to expand the scheme to other types of
unclaimed financial assets the Government could assess:
The scale of the assets currently unclaimed in
a particular sector.
The administrative cost of collecting the money.
The current use to which those unclaimed assets
are being put.
Which? believes the scope of the scheme should be expanded
to include unclaimed funds held by insurance companies in matured
endowment policies and investment bonds. The Government should
also examine the scope for extending the scheme to stockbrokers,
unclaimed dividends and shares not claimed during demutualisations.
We would not advocate the extension of the scheme to unpaid
wages or unclaimed assets held in safety deposit boxes.
The Government should examine whether a 15 year dormancy
period is appropriate for other asset classes. In Ireland, for
unclaimed insurance policies with a specified term, a dormancy
period of five years is applied from the date the policy matured.
The extension of the scheme to unclaimed stocks and shares
may prompt some difficulties, although it should be possible for
these to be overcome. The calculation of money due to an individual
with a bank account is relatively simple, (i.e the return of the
original money plus any accrued interest). For shares, the amount
to set aside could potentially be greater. For example, if shares
are sold to provide money for disbursement to worthy causes and
they subsequently double in value, this could leave a substantial
liability to pay if the consumer comes forward to claim the shares.
Who should monitor the running of the collection scheme,
and ensure that financial institutions identify, and provide for
use, unclaimed assets;
Whether the collection of unclaimed asset funds should be
organisationally separate from its disbursement;
The commercial skills required for the collection and identification
of unclaimed assets could be substantially different from the
skills required for their disbursement. The running of the collection
scheme and ensuring that financial institutions identify and provide
unclaimed assets will be a largely administrative affair. Disbursement
of the funds will require expertise of the third sector and grant
In other countries a variety of methods are employed to ensure
that banks and other financial institutions comply with the requirements
to identify, and provide for use, unclaimed assets.
USA: Some US states conduct audits of firms to determine
whether they are complying with the provisions of unclaimed assets
Ireland: Under the Dormant Accounts Act 2001, each financial
institution has to provide a certificate of compliance to the
Minister for Social, Community and Family Affairs. The Minister
has the power to appoint inspectors to assess whether institutions
are complying with the act.
Australia: The Australian Securities and Investments
Commission (ASIC) is responsible for handling all unclaimed money
from banks and other financial institutions. Companies are required
to submit an "unclaimed money statement" to ASIC each
It is important that the regulatory system is effective in
ensuring financial institutions identify and transfer unclaimed
financial assets to the central fund.
Since it is intended that the UK legislation will enable,
but not compel, banks and building societies to transfer funds
held in dormant accounts, the Government envisages that the arrangements
will be a self-regulatory scheme. Therefore, there may be a role
for the Banking Code Standards Board in assessing compliance with
the scheme. This could involve an Annual Statement of Compliance,
signed by the Chief Executive, and be backed up by examination
of whether monies are being transferred to the dormant accounts
scheme, as part of the BCSB's regular compliance visits. If this
proves to be ineffective, then there may be a role for the FSA.
Whether enough is being done to ensure that unclaimed assets
will be reunited with their owners, especially after the assets
have begun to be disbursed; and
The BBA web-site has a section devoted to dormant accounts.
This includes a claim form which consumers can submit to the BBA,
a guide to completing the form and a list of Frequently Asked
Questions. Consumers are able to fill out a single form, which
can then be used to submit a claim to several banks. This is a
useful tool for consumers and avoids the need for them to approach
each bank individually. Similar information and claim forms are
available on the web-site of the Building Societies Association
Action taken by the Banks
The Banking code requires that subscribers comply with the
BBA's "10 pledges from banks to personal customers on dormant
bank accounts". These include requirements that:
The bank will write to the customer at least once
at the last address held (unless mail has already been returned
from there) and ask if the customer wants to keep the account
If the bank receives a reply that the customer
wants to keep their account open, the bank will continue to treat
the account as "live", sending out statements and other
correspondence in the normal way.
If the bank receives no reply after a set periodusually
between six weeks and three monthsthe account may be considered
dormant and the bank will treat the account different from a live
If the account is considered dormant, the bank
will retain a record of the account.
While welcoming these minimum standards we believe that they
could be improved in a number of areas.
1) Banks should be required to take all reasonable steps
to try and restore contact, including using forms of communication
other than writing, such as telephone or e-mail. Banks should
also be required to write to customers more than once.
Under the BBA's current scheme banks are only required to
write to the customer once and are not required to attempt to
contact customers by other means such as by telephone or e-mail.
We believe banks should be required to use all reasonable methods
to re-establish contact with their customers.
2) Banks should be required to expend additional effort
proportionate to the amount of money in the dormant account.
We recognise efforts taken by the banks and other financial
institutions to regain contact with their customers should be
proportionate to the amount of assets concerned. For example,
if a dormant account contained £5 we would not think it feasible
or justifiable for a financial institution to expend significant
time and money trying to trace the owner of an account.
Which? believes banks should be required to apply the principle
of cost-benefit analysis to their efforts to reunite dormant accounts
with their owners. This would require banks to make greater effort,
over and above the BBA's minimum standards, if the amount of money
in the dormant account was significant.
3) Banks and/or the BBA should be required to publicise
and promote the scheme.
In Ireland, each year, banks are required to place a notice
in two or more daily newspapers, giving the name and address of
the bank, stating that it holds dormant accounts and that interested
persons should contact the bank to establish if they hold such
an account. In New York State, banks are required to advertise
the names and addresses of the account holders in local newspapers.
While we would not necessarily advocate the introduction of a
similar requirement in the UK, we believe the BBA and individual
banks must go to greater efforts to promote the scheme. We welcome
the intention that both the BBA and BSA schemes and the banks
and building societies own activities will be actively promoted
in the 12 months leading up to the introduction of the unclaimed
asset scheme. We believe this promotion should start immediately
and continue after the unclaimed asset scheme has been established.
Application of charges to dormant accounts
Which? believes that it is important to control any action
by banks that seek to recover unreasonable charges from dormant
accounts. The application of charges to dormant accounts will
result in consumer detriment and could reduce the amount of money
released to good causes. We have observed three examples over
the past six months of charges being introduced that could hit
consumers with dormant accounts:
First Direct (part of HSBC) has introduced a £10
a month administration fee for current accounts unless consumers
pay in £1,500 a month, maintain an average balance of over
£1,500 or take up an additional First Direct product. The
Chief Executive of First Direct was quoted as saying that the
move was aimed at the bank's 40,000 dormant accounts and at those
customers who use the bank for five to 10 transactions a year.
Citibank has moved to automatically "upgrade"
its Sterling current account customers to a "Citibank plus"
packaged account costing £10 per month. Customers who do
not wish to be upgraded had to contact Citibank before 1st April
2007 to switch to a different account in the Citibank range.
MBNA has introduced a £10 annual charge for
credit card accounts that are in credit.
It is important to note that if an account is classified
as dormant banks will typically no longer be sending out statements
or incurring any costs in relation to transactions on that account.
Many dormant savings accounts will be older accounts that could
well be paying low rates of interest. In these occasions banks
could be making profits from lending this money at higher rates
The Banking Code requires consumers to be notified of new
or increased charges. The provision states that if banks increase
any charges or introduce a new charge they are required to tell
the customer personally at least 30 days before the change comes
into effect. Personal
notification can be by one of a variety of methods; for example,
letter, statement insert, e-mail or secure internet messaging.
In many cases this will mean a letter from the bank to the consumer
outlining the details of any changes. We question how banks can
meet this requirement if they no longer have contact with the
customer. Which? recommends that the Banking Code should be amended
to prohibit new or unreasonable charges being made to dormant
accounts. Existing charges should be suspended when an account
is made dormant.
Treating Customers' Fairly
The FSA requires all financial services firms to comply with
the principle to "have due regard to the interests of their
customers and treat them fairly". In our submission to the
Banking Code review we have called for the Code to include an
overarching commitment to treat customers fairly. We would welcome
a debate on how banks and other financial institutions will be
fulfilling the requirement to treat dormant account holders fairly.
This could include factors such as, how they treat dormant account
holders whose assets are invested in current accounts or other
superseded savings accounts paying low rates of interest.
The Swiss Bankers Association has issued guidelines which
state that: "The Bank has a clear duty to protect the customer's
interests or those of his heirs concerning dormant assets."
The guidelines contain a number of principles banks are required
to respect including that "Current accounts and similar assets
are to be invested in the interest of the customer, ie carefully
and profitably (eg as savings accounts, medium-term notes or unit
trusts with low-risk profiles)."
We were unable to find any information on the ABI web-site
concerning what action consumers should take if they wanted to
reclaim funds held by an insurance company. However, the web-site
did contain a link to the Unclaimed Asset Register.
We are not aware of any minimum standards or ABI guidance
which specifies what action insurance companies should take to
track down the rightful owners of unclaimed insurance and savings
How unclaimed assets that have been disbursed can be reclaimed
should their owner be found, and who should bear the final burden
of repaying such monies owed.
Which? believes a fundamental principle of the scheme must
be that the account holder (or their legal heirs) should retain
the legal right to the money in any dormant accounts (and any
accrued interest), and that it should be paid back to them if
they come forward to claim it. Any unclaimed money transferred
from banks to the body responsible for disbursing the money must
be handled and invested prudently. Sufficient funds must be set
aside to pay any claims. Consumer rights must be safeguarded in
any legislation brought forward to introduce the scheme.
We welcome the intention that the scheme will safeguard consumers
legal rights to the money in dormant accounts transferred to the
central fund. We also welcome that the consumer will retain the
right of appeal to the Financial Ombudsman Service in respect
of disputes relating to the reclamation of funds.
We believe the process consumers should undertake to reclaim
funds should be clear and simple, while containing sufficient
safeguards against fraud. A key decision to be made will be as
to whether consumers should continue to approach the individual
banks involved or directly approach the body responsible for managing
and/or disbursing the money. The Government proposes that banks
and building societies will continue to maintain customer records
and will process reclaim applications on behalf of the central
reclaim fund. This seems a sensible decision, given that consumers
who are unsure which bank or building society held the account
will be able to make use of the BBA's central tracing facility.
If the scheme is expanded to include financial assets held by
other types of financial institutions then this may need to be
In Ireland, money transferred from financial institutions
is placed in a dormant accounts fund before disbursement. The
National Treasury Management Agency is responsible for managing
and controlling the fund. Sufficient funds must be maintained
in a reserve account to provide the right of reclaim of account
holders whose funds have been transferred. The NTMA determined
that this reserve should be 15% of the total fund, and this approach
was approved by the Irish Minister for Finance. Consumers who
want to reclaim money approach the individual financial institution
involved, which is then responsible for claiming back the money
from the dormant accounts fund.
In the US, unclaimed money is transferred into a fund administered
by a State official (typically the Treasurer or Comptroller).
It is the State official's obligation to return the unclaimed
assets to their owners wherever possible. Many State officials
are required to make a diligent effort to find the owner of the
money. They fulfil this obligation by advertising in local newspapers
and maintaining an inventory of unclaimed assets, which may be
available on the internet. Claims can be made directly to the
State official or to the specific financial institution who claimed
In Australia, the Australian Securities and Investments commission
has established a consumer education web-site known as "Fido".
This web-site maintains a central database of unclaimed accounts
and promotes the ability for consumers to search for unclaimed
funds using the slogan "Let Fido dig up your lost money".
A feature of the Australian and US systems is that information
is stored on a central database which consumers are able to search
on the internet. This lists the name of the name of the bank/financial
institution, the name of the account holder and their last known
address. In the case of Australia, the actual amount of unclaimed
assets are listed, where as in the US the database merely states
whether the amount unclaimed is more than or less than $100. In
New York State, 62% of all claims were identified via searches
of the New York State Comptroller's electronic database.
The table below shows an example of the type of information
available from the US Web-site www.missingmoney.com. The web-site
indicates that "To enhance the states' outreach efforts to
locate lost owners, MissingMoney.com, a national database, was
established in November 1999 by the National Association of Unclaimed
Property Administrators (NAUPA). MissingMoney.com enables owners
to perform comprehensive searches for lost assets required by
law to be turned over to the states."
FROM US DATABASE
||Last Known Address
||Not Disclosed||COTTON STATES MUTUAL INS CO
||343 N SAGE ROAD
TUCSON, AZ, 56789
|LINDLEY, A W||TN
MADISON, TN, 56898
|LINDLEY, A A||WA
||NATION HOTEL ANNEX
SPOKANE, WA, 99210
|OLD NATIONAL BANK OF WA
|LINDLEY, A B S||MI
|AUTO CLUB INSURANCE ASSOCIATIO
|BECKLEY NATIONAL BANK
||11 WOOD LN
FAYETTEVILLE, NC, 35456
|BANK OF AMERICANORTH CAROLI
However, not all countries have gone down the route of making
information about dormant accounts publicly available. The Irish
legislation specifies that any register of dormant accounts "shall
not be open to public inspection".
Which? believes the option of establishing a central database,
which consumers would be able to search for unclaimed financial
assets, should be examined. This could provide an opportunity
to rationalise the separate schemes that have been established
across a number of sectors. However, the Government and any financial
institutions involved should ensure that the establishment of
any database does not breach the requirements of the data protection
act, and contains sufficient safeguards against consumer detriment.
Avoidance of scams
In the run-up to the transfer of money in dormant accounts
to good causes, we anticipate significant media and consumer attention.
This may provide opportunity for fraudsters to prey on consumers
by offering to reunite them with their money for an upfront fee.
We believe there is a need for clear information to help consumers
understand the consequences of the scheme and avoid them falling
victim to fraudsters. We believe consumers should:
Never ring premium rate numbers or respond to
unsolicited e-mails stating that you have a significant amount
of money unclaimed.
Unless using the "Unclaimed Asset Register".
Never part with any money up-front on the promise of being reunited
with your unclaimed assets.
Combating scams is one of the OFT's priority areas for action.
We believe that, in the run-up to the implementation of any scheme,
the OFT should work with the Government and industry trade bodies
to develop a public information campaign. This should provide
consumers with clear information about how to search for any unclaimed
assets and help them avoid scams.
Where the owners of unclaimed financial assets cannot be
found, Which? supports the release of the money to fund worthy
causes. We believe there should be a full and open consultation
on the possible uses to which unclaimed assets can be deployed.
This should be informed by work undertaken to estimate the level
of resources that could be released by any scheme.
In the 2005 Pre-Budget Report it was suggested that the funds,
once released, should be focused on engaging young people, financial
education and inclusion, and community regeneration. We agree
with the conclusion in the Treasury's consultation document that
it is "appropriate that some of the money released for distribution
in this scheme should be used to tackle financial capability and
As the Treasury Committee concluded in its inquiry into financial
inclusion, lack of access to financial services can expose consumers
to additional cost, and entrench poverty and social exclusion.
A lack of access to affordable credit can lead to people turning
to loan sharks. A lack of access to financial advice can lead
to poor financial decisions and impose costs on individuals and
the Government. In 2002, Which? published a policy paper calling
for the creation of a National Financial Advice Network, which
could extend access to impartial, consumer-focused financial advice
to all consumers in society. In the Treasury document outlining
the Government's long-term approach to financial capability, the
Government agreed that "there is a gap in the market for
affordable `generic' financial advice" and considered that
a "national approach to the provision of generic advice is
Government established an independent feasibility study, led by
Otto Thoresen, Chief Executive of AEGON UK, to research and design
a national approach to generic financial advice.
Which? believe there are strong arguments for investing a
proportion of the money raised from unclaimed financial assets
in promoting financial inclusion and increasing access to generic
financial advice. In particular, we believe unclaimed financial
assets could be a way of funding, at least in part, any national
approach to the provision of generic advice identified by the
The Commission on Unclaimed Assets has proposed the establishment
of a Social Investment Bank (SIB). This would be a new independent
financial institution, which would be capable of combining the
strengths of the social investment world with the knowledge of
sophisticated financial tools and capital markets. The equity
base provided by capital from unclaimed assets would be multiplied
several times by attracting private investment. It would provide
a variety of support including grants, equity investments and
loans to third sector organisations. Support would be for the
long-term and would include technical assistance and advice alongside
While welcoming the proposal as a contribution to the debate,
Which? believes a number of further questions would have to be
answered before coming to a view on the viability of the proposals.
These could include:
What is the extent of the existing funding and
technical support gap for third sector organisations? Is there
sufficient demand from third sector organisations for the services
How much would a Social Investment Bank cost to
establish? Are the necessary skills available?
What are the prospects of attracting additional
private investment into a social investment bank?
Other countries have developed a variety of methods for disbursing
unclaimed financial assets.
USA: Some States automatically pay money raised from unclaimed
assets into the school system, others use it to subsidise general
expenditure. In Texas, the money is shared between the school
system and general expenditure. In Colorado, the money is used
to help people who lack access to health insurance.
Ireland: The dormant account disbursement board developed
a plan for disbursement of the money transferred from financial
institutions to the Dormant Accounts Fund. Having regard to its
statutory remit, the board decided to concentrate its funding
on projects or programmes designed to assist the following three
categories of person:
Those affected by economic and social disadvantage.
Those affected by educational disadvantage.
Persons with a disability, in particular those
who require more intensive levels of support, in the areas of
health and personal social services.
However, at a meeting on 16 December 2003, "the Government
reviewed arrangements in relation to Dormant accounts in the context
of ensuring appropriate capacity to evaluate and process applications
in the light of the emerging scale of the Dormant accounts Fund
... In the context of the need to ensure appropriate capacity
to evaluate and process applications, and so as to secure maximum
transparency on disbursements, the Government decided that the
objectives of the disbursements scheme would remain unchanged
but that it would make decisions on disbursements".
HM Treasury, A UK unclaimed asset scheme: a consultation, March
2007, para 3.22. Back
Guardian, Wednesday 15 November 2006. Back
The Banking Code, Section 5.3, Guidance for subscribers, page
Guidelines of the Swiss Bankers Association on the treatment
of dormant accounts, custody accounts and safe-deposit boxes held
in Swiss banks, page 6. Back
Unclaimed Funds, State of New York Comptroller, February 2006,
page 11. Back
Ireland, Dormant Accounts Act 2001, section 14, subsection 5(a). Back
HM Treasury, A UK unclaimed asset scheme: a consultation, March
HM Treasury, Financial Capability: The Government's long term
approach, January 2007. Back
Ireland, Dormant Accounts Fund Disbursement Board, Annual Report
2003, page 13. Back