Memorandum submitted by the Institute
of Chartered Accountants in England and Wales
INTRODUCTION
The Institute of Chartered Accountants in England
and Wales (ICAEW) is pleased to be able to submit written evidence
to the Business and Enterprise Committee as part of its current
inquiry into the Government's Enterprise Finance Guarantee (EFG)
scheme support package. This submission builds on the ICAEW's
written and oral evidence to the December 2008 Business and
Enterprise Committee inquiry on "Financial support for small
and medium-sized enterprises", including new research and
our most recent member feedback.
As a public interest body, the ICAEW is committed
to working with Government and regulators, as well as wider market
participants, in order to help restore business confidence. The
SME sector forms a vital part of the UK economy and its resilience
in the current climate will be a key factor in supporting economic
recovery. Our diverse membership gives us a uniquely balanced
perspective on access to finance issues. The ICAEW draws insights
from company finance directors attempting to secure finance for
their companies; from business and investment advisors to businesses;
and from members in the financial services industry. Many of the
ICAEW's 132,000 members either advise or run SMEs.
This submission draws upon the "ICAEW regions
state of the UK economy" report which summarises, on a regional
basis, face-to-face interviews conducted between ICAEW regional
directors and chartered accountants. ICAEW members interviewed
included both those working in a business capacity, normally as
financial director or chief executive, and those in practice advising
businesses.
EXECUTIVE SUMMARY
— The ICAEW approves of the threshold of
an annual turnover of £25 million for all applicants.
The ICAEW believes that the threshold excludes approximately 10,000 UK
businesses, out of a total stock of 4.7 million, from EFG
scheme funding, due to their annual turnovers exceeding the £25 million
threshold.
— Despite being scheduled to run until
31 March 2010, the ICAEW estimates the funds allocated to
the EFG scheme will deplete before the end of 2009 if advances
under this scheme continue at the current rate of £30 million
per week.
— The ICAEW recommends that by a specific
date, such as the 2009 Pre-Budget Report, the future of the
EFG scheme, or its successor initiatives, is made clear by the
Government.
— The ICAEW recognises that banks continue
to face pressure to rebuild their balance sheets and capital ratios,
against conflicting pressure to increase lending to businesses,
and recommend policymakers remain receptive to this.
— The ICAEW does not consider there to
be a "one-method-fits-all" solution for businesses accessing
finance. However, we do support the Government's efforts to guarantee
loans. In particular, the ICAEW welcomes the fact that the EFG
scheme covers overdrafts, unlike the previous Small Firms Loan
Guarantee scheme.
— The ICAEW strongly supports the Government's
encouragement of small scale, private equity finance investment
in businesses, but believes more could be done. We consider the
EFG scheme's £1 million limit appropriate.
— The ICAEW welcomes measures in the Government's
2009 Budget designed to help alleviate the issue of credit
insurance. We recommend that, in the autumn, the Government review
its credit insurance scheme in order to assess whether an extension
of the scheme will be needed in the 2009 Pre-Budget Report.
— The ICAEW recommends the Government works
with the accountancy profession to highlight simple steps that
businesses can take to improve financial management.
— The ICAEW considers there to be a lack
of independent, statistically robust data available to inform
policymakers of the state of lending across sectors and regions,
particularly to the SME sector.
— The ICAEW believes much greater management
of expectations and information sharing on criteria for EFG scheme
is essential. Greater clarity for finance directors, business
advisors and lending institutions will make the application process
more efficient and effective. This includes greater detail on
what constitutes a viable business and what the eligibility criteria
are.
— The EFG scheme is not designed to allow
banks to substitute conventional lending. It should be applied
where an otherwise commercially viable enterprise is currently
suffering liquidity problems and is not otherwise eligible for
a bank loan. The ICAEW recommends that the Government ensures
these conditions are understood and applied by banks at all levels.
— In principle, the ICAEW believes that
asking a business owner/director for a commitment to the success
of the venture is reasonable. The ICAEW recommends that literature
and publicity on the EFG scheme state explicitly that personal
guarantees may be a prerequisite to receiving finance under the
EFG scheme and that the fact that the taxpayer is underwriting
the loan does nor absolve the owner/director from being required
to provide security.
— The ICAEW proposes the Government look
into setting an upper limit on the proportion of the loan that
can be subject to personal guarantee.
CONSULTATION ISSUES
1. The threshold of an annual turnover of
£25 million for applicants
1.1 The ICAEW approves of the threshold
of an annual turnover of £25 million for all applicants.
This constitutes a significant threshold increase in comparison
to that of the EFG scheme's predecessor—the Small Firms
Loan Guarantee scheme—which had a £5.6 million
turnover threshold. The ICAEW estimates that only 10,000 UK
businesses, out of a total stock of 4.7 million,[46]
will be excluded from EFG scheme funding, due to their annual
turnovers exceeding the £25 million threshold. This
refers principally to medium and larger sized businesses. However,
it is worth noting that some small businesses may exceed the £25 million
turnover threshold mark.[47]
2. Whether the amount of money available is
reasonable to enable businesses to continue operating
2.1 The ICAEW believes that the £1 million
limit in the financing facility available under the EFG scheme
is appropriate. Where requests for funding run into the millions,
businesses should have more assets available as security and other
types of finance such as equity might be more appropriate.
2.2 Despite being scheduled to run until
31 March 2010, the ICAEW estimates the funds allocated to
the EFG scheme will deplete before the end of 2009 if advances
under this scheme continue at the current rate of £30 million
per week.[48]
2.3 The ICAEW believes that the Government
and policymakers should consider the sustainability of Government
assistance to UK businesses, whether the EFG scheme can continue
in its current form and whether there is scope for the return
of the Small Firms Loan Guarantee scheme—if so, in what
form, and if not, what would succeed the EFG scheme.
2.4 The ICAEW also recommends that by a
specific date, such as the 2009 Pre-Budget Report, the future
of the EFG scheme, or its successor initiatives, are concretely
announced.
3. Whether loan guarantees are the best method
of addressing the difficulties in businesses accessing finance.
If not, what is the best method?
3.1 The ICAEW recognises that banks continue
to face pressure to rebuild their balance sheets and capital ratios,
against conflicting pressure to increase lending to businesses.
Policymakers must remain aware of this issue.
3.2 However, ICAEW quantitative and qualitative
research indicates the extent to which businesses are experiencing
difficulty accessing finance. In January 2009 the ICAEW completed
its "Bank Finance" report, interviewing company finance
directors about their credit arrangements. The results reflect
increased difficulty for businesses of all sizes to secure existing
financial arrangements with their banks. Approximately 25% of
micro, small and medium-sized enterprises were contacted by their
banks in order to renegotiate the terms associated with their
overdraft facility. In 1% of cases this resulted in the facility
being cancelled. The comparable percentage of large businesses
being contacted by their banks to renegotiate facilities is much
lower—only 12% of large businesses and 9% of very large
businesses. It also revealed that 26% of SMEs and 35% of large
firms have renegotiated their largest term loan in the last year.
Approximately half of these negotiations resulted in stricter
terms. Moreover, 18% of SMEs and 11% of large businesses report
their largest term loans are up for renewal in 2009. For businesses
of all sizes to secure these loans on acceptable terms will be
critical to the economy as a whole due to the supply chain relationship
between larger and smaller firms.
3.3 The best method of accessing finance
depends on a number of factors, for example: the type of business
accessing the finance, the quantity of finance the business needs
to secure and how the business will use the money in order to
generate a return on investment. The ICAEW's January 2009 "Bank
Finance" report concludes both SMEs and large businesses
currently hold a range of different sources of finance. Overdrafts,
leasing/hire purchase and term loans were found to be the most
commonly accessed forms of finance. Asset finance, loan notes,
and factoring and invoice discounting are popular amongst a smaller,
yet nonetheless significant, numbers of SMEs. The ICAEW does not
consider there to be a "one-method-fits-all" solution.
3.4 The following issues, in particular,
are worthy of further discussion: loan guarantees, credit insurance,
private equity and improved understanding amongst businesses about
access to finance issues.
(I) Loan guarantees
3.5 The ICAEW supports the Government's
efforts to guarantee loans. By definition for "viable"
businesses, loan guarantees theoretically offer low risk to the
guarantor. Under the EFG scheme, the Government will indemnify
the finance provider against 75% of the total cost of the losses
should a business fail. Therefore, the bank would only have to
cover 25% of the losses. Decreasing the cost of the loan default
has the potential to deliver immediate impact and thus improve
the credit environment.
3.6 However, the Government will only cover
9.5% of loans that default under the EFG scheme. Therefore, banks
remain under pressure to ensure EFG scheme funds are advanced
to commercially viable businesses. The ICAEW supports some limit
on the exposure of the taxpayer to reckless lending under the
EFG scheme.
3.7 The ICAEW welcomes the fact that the
EFG scheme covers overdrafts, unlike the previous Small Firms
Loan Guarantee scheme. Our January 2009 "Bank Finance"
report indicates that overdraft facilities are critical to many
SMEs for managing cashflow in the current credit environment,
with 54% of SMEs surveyed having an overdraft facility compared
to 37% having a term loan. The flexibility of overdrafts is critical
for many SMEs to manage cashflow.
(II) Private equity
3.8 The ICAEW strongly supports the Government's
encouragement of small scale, private equity finance investment
in businesses. As detailed under consultation issue 2, the ICAEW
considers the EFG scheme's £1 million limit appropriate
due to the fact that, with regard to businesses that require quantities
of investment exceeding £1 million, other forms of finance,
including equity finance, may be more appropriate funding methods.
3.9 A notable private equity scheme, announced
by BERR in January 2009, is the £75 million Capital
for Enterprise Fund, for which the Government has provided £50 million.
Barclays, HSBC, Lloyds TSB and RBS have put forward the remaining
£25 million. The Capital for Enterprise Fund supports
businesses with turnovers of up to €50 million that
are deemed to have viable business models reflecting long-term
growth potential. Another public scheme that encourages equity
investment is the Enterprise Investment Scheme (EIS). The EIS
is designed to help higher-risk SMEs access finance by offering
tax reliefs to investors. These schemes have provided significant
investment to smaller sized businesses, particularly those in
the start-up stage. The capacity for businesses to attract private
investment will increase if tax incentives are enhanced to coax
greater levels of private investment in the form of small scale
equity finance. In turn, this would offer debt finance providers
greater security by increasing the net assets of businesses receiving
investment.
3.10 To further illustrate the importance
of equity finance, it is worth noting that the UK Government is
placing increasing emphasis on the creation of a higher value-added
economy, and the need to support the development of a globally
competitive high-tech sector. A large number of high-tech enterprises
are SME start-ups or university spin-offs. The majority of these
ventures will therefore lack sufficient collateral to support
debt finance. Compounding this difficulty is the fact that many
high-tech businesses are loss-making and cash consuming in their
early years. Equity finance has a greater role to play in creating
a more sustainable credit environment for high-tech SMEs, and
many other high growth businesses.
3.11 The ICAEW does not generally support
initiatives where the Government takes direct equity stakes in
businesses that have been refused bank credit. Past experience
of Government taking equity stakes in private enterprise has not
proved a great success. In the long run, decisions on the allocation
of capital are best left to the marketplace. The Government's
role lies with ensuring that there is an adequate supply of risk
capital, particularly small scale equity finance.
(III) Credit insurance
3.12 The ICAEW supports the initiative announced
by the Government, in the 2009 Budget, to increase the accessibility
of trade credit insurance. Under the scheme, suppliers can purchase
Government-backed insurance to either restore cover to the original
level, double the amount they are able to obtain from the private
sector, or £1 million, whichever is the lower. The anecdotal
"ICAEW regions state of the UK economy' report indicates
the difficulty businesses face when applying for credit insurance.
An interviewee from the ICAEW's North West region stated that,
"credit insurance is not freely available and is causing
problems where banks are willing to lend. The cost is also prohibitive
in many cases". Another interviewee from the South West
said, "we cannot get bad debt protection—premiums
have doubled whilst potential claims have halved".
3.13 The report also indicates that finance
directors currently doubt the value of buying credit insurance.
An interviewee from the West Midlands stated that, "credit
insurance is becoming a serious worry—we have a nine month
contract with a supplier, but he will not supply any more because
insurers will not insure him. It creates a downward spiral".
The ICAEW strongly recommends the Government ensure credit insurance
schemes support SMEs during the recession.
3.14 We recommend that in the autumn the
Government review its scheme, whether credit insurance remains
a problem, and be prepared to announce an extension of the scheme
in the 2009 Pre-Budget Report.
(IV) Improved financial management
3.15 Policy examination of what constitutes
a good method for addressing the "difficulties in businesses
accessing finance" should not be limited to types of external
finance—whether in the form of a loan guarantee, an overdraft
facility or private equity investment. Businesses, especially
SMEs, should be helped to improve their financial management.
3.16 Evidence of sound financial management
is essential when approaching lending institutions. Businesses
whose financial operations are structured and reasoned will be
in a stronger position to benefit from all forms of external finance.
The ICAEW believes that smaller entities can act to improve their
position, in particular, by adopting improved practices for managing
working capital.
3.17 Where possible, SMEs should take steps
to reduce their risk profile, for example by improving the quality,
quantity and transparency of information they provide to lending
institutions and other stakeholders. SMEs, particularly micro
businesses and sole traders, often have difficulty managing their
cash flow, sometimes due to their position in the supply chain,
but also due to limited financial management skills. SMEs need
to be extra diligent about sound financial management in the current
climate, particularly in managing working capital. Improved cash
flow forecasting, allowing for unforeseen events and better credit
management are some of the measures which may help with working
capital management.
3.18 The ICAEW recommends that the Government
works with the accountancy profession to highlight simple steps
to improve financial management. Improving financial management
will provide a greater long term benefit given that public intervention.
The EFG scheme (total impact of £1.3 billion), is a
relatively small percentage of the overall term loan and overdraft
lending to the small business sector (£54.4 billion
at February 2009).[49]
3.19 There are a number of other common
practices which need to be reviewed in the current context:
— SMEs can often improve their basic credit
management—how they chase up their debts, the speed at which
they invoice for goods or services, and the payment monitoring
arrangements they have in place to check invoices on a regular
basis.
— Some SMEs could improve reporting of
financial performance coupled with better forecasting systems
of future trading and cash flow.
— Many SMEs are inappropriately financed,
placing too much reliance on term loans and overdraft. Expanding
businesses should be encouraged to consider factoring, invoice
discounting, leasing and hire purchase.
— Some businesses concentrate on trying
to achieve good seasonal or quarterly results. Concentration on
performance in this way can lead to lack of attention to working
capital performance.
— Many SMEs fail to prepare or put in place
financial contingency plans to help tide them over unexpected
events.
— It is crucial that SMEs work to maintain
good credit ratings and a credit file that demonstrates to others
that they have successfully managed credit previously. Having
a good credit rating helps to reduce the cost of borrowing and
makes it easier for an SME to access funds.
— Good communication with customers and
suppliers is essential for avoiding disputes. Greater understanding
and discussion of customers' and suppliers' terms and conditions
of trade, business projects, etcetera, can go a long way in helping
to manage working capital.
4. To what extent the loan guarantee will
encourage new lending by banks
4.1 Following the initial "teething
problems" normally associated with new schemes, lending under
the EFG scheme is increasing according to information provided
by BERR. Some ICAEW members raised concern over whether the EFG
scheme promotes new lending or replaces existing lending. However,
there is a lack of independent and robust statistical data available
on this issue.
5. The extent to which banks are making this
scheme available
5.1 In general, there is a lack of statistical
data on the extent to which banks are making the EFG scheme available.
The British Bankers Association (BBA) publishes aggregate data
on bank lending to small businesses; which it defines as a business
with a turnover of less than £1 million. These statistics
exclude a significant number of businesses eligible for the EFG
scheme—those with turnovers between £1 million
and £25 million.
5.2 According to the April 2009 "BBA
Statistics Release", term loan and overdraft lending mechanisms
to small businesses totalled £54,409 million at the
end of February 2009. At the same date, deposits from small businesses
totalled £52,717 million. However, there are no statistics
revealing the number of businesses in receipt of accessing bank
finance; let alone how many businesses had received EFG funding,
whether these advances were replacing existing facilities, or
whether they were new advances.
5.3 As mentioned above, BERR have published
statistics on advances under the EFG scheme. However, analysis
that can be derived from this information is limited. The statistics
available on advances under the EFS are not broken down into numbers
of businesses, sectors, whether the scheme is replacing existing
facilities or providing new finance, or how individual banks are
delivering the scheme. Such information would add substantial
value to an analysis on the extent to which banks are making the
EFG scheme available. Individual banks have issued press releases
stating amounts they will be advancing to businesses, usually
over the following year. For example, RBS' "A Practical Guide"
states: "We're making £3 billion of additional
funds available this year for SMEs". However, as far
as we are aware there are no official statistics on advances to
date.
5.4 Moreover, the ICAEW believes that independent,
statistically robust data is required to inform policymakers of
the state of lending, particularly to the SME sector. Awareness
of the EFG scheme is progressively filtering down to businesses
and lending instituions at regional and branch levels. Anecdotal
evidence from our members presents a mixed response as to whether
the EFG scheme was communicated effectively by the Government
. One interviewee, a partner at an accountancy practice in the
South West, stated, "still no progress on the EFG scheme.
Banks do not seem to know what the rules are". Another
source from the East Midlands said that, "the Government's
EFG scheme appears not to have made any perceptible difference
to the bank's attitude towards lending". On a positive
note, we interviewed respondents who knew of successful EFG funding
agreements. One particular example from the West Midlands claimed
to know of a £1 million EFG scheme deal. A representative
from Advantage West Midlands stated, at the ICAEW's Regional Finance
Forum meeting, that "the average level of EFG loans is
£85,000, but it varies between the banks".
6. Whether businesses in some areas of the
UK have more difficulty in accessing the scheme than businesses
in other areas
6.1 The ICAEW does not have statistics detailing
the regional breakdown of EFG applications, or compelling evidence
of regional disparities.
7. Whether applying to the scheme creates
an administrative burden on those applying
7.1 Since the onset of the recession, banks
have become considerably more risk averse. Therefore, banks are
more likely to impose additional requirements when reviewing applications
from businesses seeking to access finance. This is an understandable
reaction in light of pressure to increase lending whilst maintaining
capital ratios. However, such additional requirements will compound
any administrative burden imposed by the EFG scheme. A finance
director from the ICAEW's North West region said, "the
Enterprise Finance Guarantee scheme is not working. Companies
complain that different banks have varying levels of understanding
regarding eligibility, and the process is time consuming and onerous
with examples of paperwork taking up to eight weeks to complete".
Feedback from the ICAEW's regional bodies suggests that, as
a direct result of the economic downturn, local bank staff exercise
less discretion and must refer more decisions to area or regional
offices. Consequently, the period from the initial application
for finance through to the final decision has been lengthened.
This delay can prove very burdensome to businesses suffering a
shortage of capital.
8. Whether the scheme has been effectively
promoted to the private sector
8.1 The ICAEW acknowledges the steps that
DBERR has taken to ensure the EFG scheme is publicised to businesses,
a notable channel being: www.businesslink.gov.uk/realhelp.
However, we feel that more could be done.
(I) Managing expectations: eligibility
8.2 The ICAEW recommends much greater management
of expectations and information sharing on criteria for EFG scheme
applications to assist finance directors, business advisors and
lending institutions, and thus make the application process more
efficient and effective.
8.3 There is a danger that lending institutions
may manage EFG scheme funds inconsistently due to a lack of understanding
as to where the scheme applies. The EFG scheme is not designed
to substitute conventional lending. The EFG scheme might apply
where an otherwise commercially viable enterprise is currently
suffering liquidity problems and, therefore, is not eligible for
a bank loan.
8.4 The ICAEW recommends all is done by
the Government to communicate the conditions of the EFG scheme
thoroughly, and to ensure these conditions are understood and
applied by banks at all levels.
8.5 The ICAEW believes that there is room
for the Government to provide support on a continuous basis to
assist enquiries on EFG funding. There are many occasions when
finance directors and business advisors would benefit from direct,
personal contact—through a telephone helpline, for example.
We note that some banks, such as RBS/NatWest, have provided practical
guidance which includes a "Business Lifeline". The ICAEW
believes that BERR should provide such a service, as it did for
the Small Firms Loan Guarantee scheme.
8.6 Much of the literature on the EFG scheme
states that businesses must be "viable" to qualify.
There is a lack of clarity regarding the definition of a viable
enterprise. This creates uncertainty amongst businesses over eligibility
criteria and may be encouraging applications from inappropriate
businesses, therefore, threatening to undermine the efficiency
and effectiveness of the EFG scheme.
8.7 It is imperative that businesses of
all sizes know the viability requirements that lending institutions
expect. The ICAEW believes that in order to encourage lending
institutions to operate loan guarantees, banks and the Government
should detail clearly and consistently what a viable business
constitutes and what the required eligibility criteria are. Such
common understanding would help to reduce undue administrative
burden. Understandably, each case must ultimately be judged upon
its own merits. The ICAEW believes the onus is on the banks to
communicate directly to businesses whether they are eligible for
EFG scheme funding. Nevertheless the Government should offer guidance
or, at the very least, useful case studies to illustrate an appropriate
business that complies with the eligibility criteria.
(II) Managing expectations: personal guarantees
8.8 The fact that lending institutions,
at their own discretion, may request personal guarantees from
business owners before agreeing to advance EFG funding, has attracted
much criticism. In principle, the ICAEW believes that asking a
business director for a commitment to the success of the venture
is reasonable. Under the EFG scheme, the level of personal guarantee
required from borrowers will differ according to the amount and
risk attached to each individual case. The ICAEW agrees that lenders
should not be permitted to take any form of direct charge against
an individual's primary residence. The fact the Government will
guarantee 75% of the loan should neither encourage entrepreneurs
to avoid committing a personal contribution to financing a venture,
nor encourage them to take taxpayers' money light-heartedly.
8.9 However, due to the Government's "cap"
of 9.5% on defaulting loans under the EFG scheme, banks will obviously
seek to ensure the balance of the facility does not burden them
with bad debt. There are no obvious solutions to this uneasy situation—either
taxpayer liability is limited or the banks seek whatever security
they can obtain. The ICAEW would like to propose that a resolution
could be to judge the total commitment of the directors. If entrepreneurs
are seeking to avoid assuming any risk, it is unacceptable to
expect the banks to absorb it. Even though a director's primary
home may not be taken as a guarantee, it may nevertheless be endangered
if the business fails. At an ICAEW Regional Finance Forum meeting,
a small business owner from the West Midlands stated: "Peter
Mandelson said that homes should not be included in personal guarantees,
but the evidence is that our houses are on the line".
The EFG facility may not be appropriate if the only asset a business
owner can offer as further security endangers the primary residence.
If the directors have demonstrably put up a reasonable amount
of security, that should be deemed sufficient.
8.10 In addition, the ICAEW proposes the
Government look into setting an upper limit on the amount of the
loan that can be subject to a personal guarantee.
8.11 The ICAEW strongly recommends that
literature and publicity on the EFG scheme state explicitly that
personal guarantees may be a prerequisite to receiving finance
under the EFG scheme and that the fact that the taxpayer is underwriting
the loan does nor absolve the owner/director from being required
to provide security. This is a key component of managing expectations.
(III) The ICAEW's commitment
8.12 The ICAEW continues to play its part
in the effort to improve the availability of finance for SMEs.
We have promoted the EFG scheme widely to our members, including
business advisors and those working in the SME sector, so that
they are aware of the relevance of the EFG funding. Methods we
have used to communicate with members include: member alerts,
emails and—most recently—the "viable business
lending" article in the May 2009 edition of the ICAEW
in Accountancy Magazine. This publication is co-edited
by the ICAEW and is one of the largest business to business monthly
publications in the world.
8.13 The ICAEW's Corporate Finance Faculty
published, in conjunction with BERR and Business Link, SME
Finance Guidelines in March 2009. BERR recommended SME
Finance Guidelines be made publicly accessible on the ICAEW
website. Currently, the document can be accessed on our Corporate
Finance Faculty webpage, the "News" section of the website
and the ICAEW SMEs webpage.
8.14 The ICAEW continues to work with its
members to advise SME finance issues. We actively support awareness
of alternative forms of finance, for instance, through the SME
Funding Adviser Scheme—which HM Treasury and BERR were actively
involved in developing. The objective of the scheme is to ensure
that businesses receive independent advice on the most appropriate
form of business finance out of the range of available options
and to assist businesses to meet finance provider requirements
for financial reports and forecasts, such as profit, cashflow
and balance sheets.
8.15 The ICAEW also works to improve SME
and other businesses' awareness of different forms of financial
support, On 28 May 2009, the British Business Angels Association
will launch their awareness campaign at Chartered Accountants'
Hall. The ICAEW monitors lending at its Regional Finance Forums
and publicises the results of the ICAEW regions state of the
UK economy report.
May 2009
46 "4.7 million" is citied from the
Department for Business, Enterprise and Regulatory Reform's (BERR)
website:
http://stats.berr.gov.uk/ed/sme/ Back
47
In the context of this submission, the ICAEW defines the size
of a business according to its number of employees-a small business
has no more than 50 employees, a medium sized enterprise
has no more than 250, and a large business employs in excess of
250. We have applied the definitions presented on DBERR's website:
http://www.berr.gov.uk/whatwedo/enterprise/enterprisesmes/research-and-statistics/statistics/page38563.html Back
48
The £30 million per week statistic was cited on 23 March
2009 in a press release made by the DBERR. Back
49
British Bankers Association, BBA Statistics Release, April
2009. Back
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