House of Commons - Treasury - Written Evidence

Select Committee on Treasury Written Evidence

Memorandum submitted by Which?

SUMMARY

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 participate.

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 or e-mail.

— 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.

THE PRINCIPLES FOR THE UK UNCLAIMED ASSET SCHEME

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 community; and

— 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 DEFINITION, IDENTIFICATION AND COLLECTION OF UNCLAIMED ASSETS

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

Nevada	3 years
California	3 years
Texas	5 years
Ohio	5 years
New York	5 years
New Zealand	6 years
Australia	7 years
Switzerland	10 years
Ireland	15 years
UK	15 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 temporarily inactive.

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".[18] 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 making functions.

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 legislation.

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 year.

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 BANKING SECTOR

Consumer information

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 (BSA).

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 open.

— 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 period—usually between six weeks and three months—the account may be considered dormant and the bank will treat the account different from a live account.

— 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:

— 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 of interest.

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.[21] 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)."[22]

THE INSURANCE SECTOR

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 policies.

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 reconsidered.

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 the money.

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".

Searchable databases

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.[23]

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."

INFORMATION AVAILABLE FROM US DATABASE OF UNCLAIMED ASSETS


Name	Held In	Last Known Address	Reported By	Amount

LINDLEY	WY	Not Disclosed	COTTON STATES MUTUAL INS CO	Over $100
LINDLEY, A	AZ	343 N SAGE ROAD TUCSON, AZ, 56789	Not Disclosed	Unknown
LINDLEY, A W	TN	Not Disclosed MADISON, TN, 56898	TRANSPORTATION	Over
LINDLEY, A A	WA	NATION HOTEL ANNEX SPOKANE, WA, 99210	OLD NATIONAL BANK OF WA	Over $100
LINDLEY, A B S	MI	Not Disclosed DETROIT, MI	AUTO CLUB INSURANCE ASSOCIATIO	Unknown
LINDLEY, ARNOLD	WV	Not Disclosed BECKLEY, WV	BECKLEY NATIONAL BANK	Unknown
LINDLEY, ALAN	NC	11 WOOD LN FAYETTEVILLE, NC, 35456	BANK OF AMERICA—NORTH CAROLI	Over $100

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".[24]

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.

Other issues

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.

THE DISTRIBUTION AND USE OF UNCLAIMED FINANCIAL ASSETS

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 inclusion challenges".[25]

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 required".[26] The 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 Thoresen review.

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 funding.

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 proposed?

— 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?

INTERNATIONAL COMPARISONS

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".[27]

May 2007

18 HM Treasury, A UK unclaimed asset scheme: a consultation, March 2007, para 3.22. Back

19 Guardian, Wednesday 15 November 2006. Back

20 http://www.citibank.co.uk/personal/banking/bankingproducts/currentaccounts/sterling/changes.htm Back

21 The Banking Code, Section 5.3, Guidance for subscribers, page 23. Back

22 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

23 Unclaimed Funds, State of New York Comptroller, February 2006, page 11. Back

24 Ireland, Dormant Accounts Act 2001, section 14, subsection 5(a). Back

25 HM Treasury, A UK unclaimed asset scheme: a consultation, March 2007. Back

26 HM Treasury, Financial Capability: The Government's long term approach, January 2007. Back

27 Ireland, Dormant Accounts Fund Disbursement Board, Annual Report 2003, page 13. Back