The need for and provision of
96. From its formation HBOS had a large
wholesale funding requirement, as both Halifax and BoS had been
already significant users of wholesale funding even prior to the
merger. At the Group's formation in 2001, the Group had a loans/deposits
ratio of 143 per cent and a customer funding gap of £61 billion.
The Retail Division, which had been substantially derived from
Halifax, had customer loans of £137 billion and deposits
of £97 billiona customer funding gap of £40 billion.
The rest of the HBOS Group, substantially derived from BoS, had
a customer funding gap of £21 billion.
97. HBOS's growth strategy meant that
the funding gap increased. Customer deposits grew at a slower
rate than assets. Deposits rose at 8 per cent a year between 2001
and 2008, compared with asset growth of around 13 per cent.
By the end of 2008, the loans/deposits ratio had risen to 196
per cent and the customer funding gap had increased to £212.9
billion. The Retail Division's customer funding gap had risen
to £112 billion, the Corporate Division had a gap of £78
billion, and the International Division a gap of £54 billion.
All three of the Group's principal banking divisions contributed
to the increase in the Group's overall customer funding gap and
the greater need for wholesale funding over the period from 2001
98. The Treasury Division's first priority
was sourcing the funding to support the Group's asset led strategy.
Management papers throughout the period show that the planned
asset growth posed challenges for the Treasury Division in raising
the funding to support it, even before the onset of the financial
crisis. The 2003-07 Business Plan (drawn up in 2002) cited funding
and liquidity as possibly the bank's "greatest single challenge".
The Finance Director explained to the Group Board in November
2002 that their five-year business plan would make HBOS "the
largest wholesale funded clearing bank in the UK", and Sir
James Crosby acknowledged that funding was a "significant
1 March 2005, the Board was told:
Liquidity [...] remained a significant
management challenge. HBOS was structurally illiquid: this needed
to be overcome through ensuring sources of funds were appropriately
diversified, with identified additional capacity in case of need.
Lindsay Mackay, Head of the Treasury
Division, told the Executive Committee in 2006 that the bank's
existing wholesale funding capacity would be reached in 2009 under
their current Plan. HBOS had "the highest wholesale funding
need of any of the UK banks (and was close to the other Big Four
banks combined)". He informed the Executive Committee that,
in the longer term, the position was "untenable and unsustainable".
99. HBOS took steps to mitigate its
reliance on wholesale funding, including: increasing the efforts
to source customer deposits; diversifying wholesale funding sources
by nature, currency and type of investor;
holding a significant pool of liquid assets; and undertaking stress
tests and scenario analyses.
The Group also made efforts to diversify its sources of wholesale
funding, through the issuance in different currencies of covered
bonds, asset-backed securities and senior debt. It also sought
to lengthen the maturity of its wholesale funding. The proportion
of wholesale funding with a maturity of under one year was reduced
from 86 per cent in 2001 to 50 per cent by 2008. However, the
bank used the benefits of its measures to raise longer term wholesale
funding to support asset growth, rather than to reduce short-term
wholesale funding in absolute terms. At the end of 2008 HBOS had
£238 billion of wholesale funding outstanding, of which £119
billion had a maturity of less than a year, compared with £90
billion in 2001.
100. The onset of the financial crisis
in the second half of 2007 led to a shortening of the wholesale
funding profile, as maturing longer term funding could only be
replaced by shorter duration maturities.
In consequence, the proportion of HBOS's wholesale funding with
a duration longer than one year fell from 47 per cent in mid-2007
to just over 40 per cent a year later.
101. Once the financial crisis began,
HBOS did attempt to moderate its overall asset growth plans. However,
several executives indicated in evidence that the reliance on
the markets for wholesale funding made the Group cautious about
the signals it was sending: being too aggressive in scaling back
growth risked worrying the market that the bank might be in difficulty.
In September 2007, Philip Hodkinson, Group Finance Director, outlined
to the Executive Committee steps to reduce asset growth and increase
liabilities, although full-year asset growth would still be above
plan. However, he also indicated, lending "could not simply
be 'turned off'."
Growth targets for 2008 were reduced by £10 billion, largely
in the International Division, and the Group targeted increased
However, as we noted earlier, asset growth in the Corporate Division
was accelerating soon after these measures were agreed.
102. Successive Executive Committee
and Board papers during the financial crisis indicate management
took the funding position seriously. The day after the announcement
that Northern Rock had been granted emergency Bank of England
assistance, HBOS set up a Contingency Planning Group, and Andy
Hornby indicated that planned business growth was no longer prudent.
On 18 September 2007, Lindsay Mackay discussed with the Executive
Committee contingency planning designed to avoid HBOS becoming
"the next Northern Rock".
Initially at least, the management believed the external perception
to be of a bank that had "managed its position through the
liquidity crunch extremely well".
It felt regarded as one of the larger Clearing Banks, distinct
from the monoline or smaller mortgage banks.
Philip Hodkinson said that the responses to stressed conditions,
which the Group had prepared and which took effect in late 2007,
together with other measures, were working and the Group felt
"in good shape".
103. On 13 November 2007, Lord Stevenson
wrote to the Chairman of the FSA about how it was coping with
the pressures of the financial crisis. He said:
[...] You asked how HBOS felt on
the 'ladder of vulnerability'. Answer: without wishing to be complacent
or hubristic, management has done a superb job-a job that started
five years ago and not in August; most recently Andy Hornby has
led his top managers into making some very tough decisions to
ration assets growth next year. Good always comes out of difficult
I and we sense a continual paranoia
within the FSA about the 'ladder of vulnerability' and HBOS [...]
I do believe that our management has done enough [...] not just
over the last three months but the last five years --- to demonstrate
its sense of responsibility and competence and that there could
be some release of the FSA paranoia button!
104. As the crisis progressed, the HBOS
credit default swap levels widened, both in absolute and relative
terms. The Group
suffered an attack from short sellers in March 2008, which led
to the withdrawal of some deposits that stabilised after an FSA
statement. The market was also concerned with the structure of
the HBOS balance sheet, notably its loans/deposits ratio and the
absolute size of its wholesale funding.
105. On 17 March 2008, the day of the
announcement of the acquisition of Bear Sterns by JP Morgan in
a rescue involving the Federal Reserve, the Chairman of the FSA
called Lord Stevenson to ask how he was feeling. Lord Stevenson's
response the next day was bullish:
I and we are feeling about as
robust as it is possible to feel in a worrying environment which
we would rather did not exist! As I said to you we have faced
into the need to be boringly boring for the next year or
two and we are setting out our stall to do that [...]
We have had no problems in financing
ourselves over the past six months even on the hairiest of days
and weeks [...]
My soberly considered view is that
given the extraordinary external environment, HBOS in an admittedly
uncertain and worrying world is in as secure a position as it
could be [...]
How would we fare if liquidity completely
dried up, you asked? Does that keep me awake at night? Well yes
of course one worries about everything, but the answer is no!
First, our close monitoring of those who supply the lines of credit
leads us to the view that the circumstances in which ours would
be withdrawn would either be the 'freak' circumstances outlined
above (but even that is judged to be unlikely) or where the world
has collapsed to the extent that all bets of all kinds would be
off. The commonsense of the situation is that we are dealing
with lenders looking to lend money to a highly conservative institution
The bottom line is that without
wishing to be the slightest bit complacent, we feel that HBOS
in this particular storm and given its business characteristics
is in as safe a harbour as is possible while at the same time
feeling commercially rather frustrated.
By September 2008, it became clear that,
far from being "a highly conservative institution" in
a safe harbour, HBOS was in a storm-tossed sea.
106. It was also holed below the water
line. HBOS's £60 billion liquid assets pool proved ineffective,
because the bank was unable to sell or raise funds against it
in the crisis, due to the nature of its investments and the seizure
of wholesale markets.
Indeed, the market's concerns about potential losses in
HBOS's investment and liquidity portfolios actually contributed
to the market's increasing concerns about the bank.
HBOS was forced to supply liquidity to the Grampian conduit,
which was unable to finance itself on the wholesale markets at
The decision by Lehman Brothers to file for bankruptcy on 14 September
2008 also proved fatal to HBOS. HBOS suffered from a two-fold
crisis. First, there was an outflow of around £30 to £35
billion of customer deposits.
The majority of this outflow was by non-bank financial and
large corporate, rather than retail, customers.
Second, as some of the shorter term borrowing taken out
the previous Autumn fell due, HBOS found itself faced with the
closure of wholesale markets, except the overnight market. In
this situation, HBOS was unable to raise sufficient wholesale
market financing to meet its outflows.
The endgame and its consequences
107. Faced with this situation, the
Board soon concluded that it needed to "secure a more stable
long-term solution" in the form of takeover by Lloyds TSB.
The terms for the recommended acquisition were announced by Lloyds
TSB on 18 September 2008. Pending completion of the takeover,
which took place on 16 January 2009, HBOS was forced to accept
Emergency Liquidity Assistance from the Bank of England on 1 October
108. Former HBOS shareholders have seen
96 per cent of its peak value disappear, and what remains is the
result of support from the UK taxpayer and the acquisition by
Lloyds TSB. The Treasury provided £20.5 billion to HBOS,
Lloyds TSB and Lloyds Banking Group (LBG).
These injections by the Treasury were followed by subsequent injections
by LBG into HBOS. Combined, the Treasury and LBG injected a total
of £28 billion of equity into HBOS.
The market value of the Treasury holding in LBG is still £5
billion below the £20.5 billion invested.
In 2009 Eric Daniels maintained that LBG would not have needed
state aid if it had not acquired HBOS.
109. There has also been an adverse
effect on the operation of the banking market. HBOS was weakened
in its ability to continue its retail lending and its support
for SMEs. The banking market has become less diverse and less
competitive in consequence of the merger. UK competition law
was altered in October 2008 to include a new public interest consideration
of "maintaining the stability of the UK financial system".
This consideration was used to support a decision not to refer
the Lloyds HBOS merger to the Competition Commission.
Consumers and the wider economy, as well as shareholders and taxpayers,
have paid a heavy price for the blunders of the HBOS Board.
The full picture
110. All HBOS witnesses accepted that
management did not expect, still less make contingency planning
for, the severity of the financial crisis, including the near
closure of term wholesale money markets to banks for over a year.
All senior management accepted that their failure to plan for
such a severe funding and liquidity crisis as occurred was an
error and many of them apologised for it. However, in evidence
to the Treasury Committee in 2009 and in evidence to this Commission,
senior figures within HBOS have portrayed themselves as victims
of forces beyond their control. According to Sir Ron Garrick:
We were probably optimistic rather
than pessimistic, but even the pessimists never forecasted the
extent to which the liquidity crisis would strike and the impact
it would have [...] We were on the beach when the tsunami came
in; we were not on high ground.
111. Sir James Crosby denied that the
growth in his time as Chief Executive made what subsequently happened
He said that wholesale funding was seen as a risk to the strategy,
but not a risk to the bank.
The events that subsequently unfolded were "not a foreseeable
Andy Hornby suggested that the scale of losses on the corporate
loan book went back to "the unforeseen and unprecedented
total closure of wholesale markets".
112. Lord Stevenson argued that there
was a single cause of the failure of the HBOS:
The problem was the first protracted
closure of wholesale markets since, I believe, 1913 [...] Had
wholesale markets continued not completely closed, I think that
events would have been different, but it was the closure of wholesale
markets that, effectively, did for us.
At the end of 2011, the HBOS Group tangible
ordinary shareholders' funds were £23 billion. However, this
was only after injections first from the Treasury and subsequently
from LBG, totalling £28 billion in 2009 and 2010. It is therefore
clear that without these injections, HBOS would have had, and
still would currently have, significant negative net worth, let
alone insufficient equity capital with which to continue to operate.
When this was put to Lord Stevenson, he rejected outright the
suggestion that the capital provisions resulted from anything
other than the liquidity problems in the particular circumstances
of the closure of wholesale markets.
He went on to say:
As a matter of fact, what brought
the bank down were global wholesale markets the day after Lehman.
That was it.
113. If HBOS's difficulties were solely
the result of funding and liquidity problems, their lasting effects
would have been much more limited, including for the taxpayer.
The impairments on its bad lending continued well after then.
The market's justified fears over the quality of HBOS's lending
were as much a cause of the Group's liquidity problems as the
subsequent impairments were the result of an evaporation of liquidity.
Michael Foot pointed out that banks which caused the markets the
biggest concerns about asset quality tended to have the greatest
problems refinancing wholesale funding.
This point was also acknowledged by George Mitchell, who said:
It was the rapid rate of loan growthnot
just in corporate, but in HBOS as a whole, when others had pulled
backthat spooked the market and caused the collapse in
the first place.
114. The other major bank failure which
took place in the UK in 2008, that of RBS, was in considerable
measure precipitated by a decision taken by the RBS Board after
the onset of the financial crisis, namely the disastrous decision
to acquire ABN AMRO. This acquisition was part of the story of
how RBS weakened its mainstream bank through the growth of its
investment banking business. As a home-grown banking failure
in traditional banking, HBOS stands alone.
115. The problems of liquidity were
the occasion for the failure of HBOS, not the cause. If HBOS's
difficulties were solely the result of funding and liquidity problems,
their lasting effects would have been much more limited, including
for the taxpayer. LBG has now repaid all the Government backed
funding raised during the financial crisis. Without solvency pressures,
HBOS would not have needed equity support from the taxpayer.
116. The HBOS failure was fundamentally
one of solvency. Subsequent results have shown that HBOS would
have become insolvent without capital injections from the taxpayer
and LBG. At the end of 2011, the HBOS Group tangible ordinary
shareholders' funds were £23 billion. However, this was only
after injections, first from the Treasury and subsequently from
LBG, totalling £28 billion in 2009 and 2010. It is clear
that without these injections, HBOS would have become insolvent.
117. The bank's solvency pressures
reflect substantial operating losses. HBOS reported pre-tax losses
each year in the period 2008-11; the aggregate pre-tax losses
for this period totalled £30 billion. These losses were the
result of very large asset impairments. Aggregate impairments
for the same period were £50 billion, concentrated in customer
loan impairments, which totalled £46 billion. Losses on this
scale necessitated the recapitalisations.
118. Table 3 compares the HBOS impairments
with those of the other large UK based commercial banks.
119. The total 2008-11 HBOS loan
impairments were equivalent to 10.5 per cent of the end 2008 customer
loan book. This percentage was more than twice as high as the
next largest proportion of loans incurred by a leading UK domestic
commercial banking group, RBS, which also required Government
equity injections. The disproportionate scale of impairments at
HBOS compared to the UK banking industry, even to RBS, indicates
the appalling condition of HBOS's asset base.
120. The poor quality of HBOS's assets
becomes even more stark when account is taken of the fact that
more than half of the bank's loan portfolio was in residential
mortgages, where impairments were proportionately substantially
lower than for other types of lending. The group figures therefore
contain much higher impairments as a proportion of loans in the
corporate lending portfolios, both in the UK and abroad.
121. Several leading former HBOS executives
suggested to the Commission, that the company's impairments were
the result of the financial crisis and the seizure of wholesale
funding markets, which particularly affected its customers. The
Chairman and both former CEOs acknowledged that the impairments
and Sir James Crosby accepted that the HBOS impairments indicated
"incompetent" lending. However, all three put the emphasis
on the unprecedented closure of the wholesale markets.
In contrast, former FSA Managing Director, Michael Foot gave an
alternative interpretation, pointing out that the banks where
the market had concerns about their asset quality were the ones
which tended to have the greatest problems refinancing wholesale
122. The explanation by senior HBOS
management given to the Commission for the scale of the Group's
losses is entirely unconvincing. The impairments and losses incurred
were substantially worse than for the peer group. Losses have
been sustained over a period of at least four years, indicative
of fundamentally poor asset quality, rather than the result of
temporary liquidity pressures. The losses were also incurred in
three divisions, rather than concentrated in one area, indicative
of more general asset quality weaknesses.
123. Poor asset quality was the direct
result of the company's strategy, which pursued asset growth in
higher risk areas. This asset growth was compounded by a risky
funding strategy. The combination of higher risk assets and risky
funding represents a fundamentally flawed business model and a
colossal failure of senior management and of the Board.
124. Their misjudgements were toxic
for HBOS. The problems of solvency were a direct consequence
of the strategy set by the Board and the failure of controls on
the practices that were fostered by its commitment to an asset-led,
high-risk approach to growth.
125. The Commission was very disappointed
by the attempts of those who led HBOS into the abyss to acknowledge,
even now, either the nature of the problems that eventually consumed
the bank or the extent to which they flowed from their own decisions
rather than unforeseeable events. No bank is likely to be immune
from the effects of an economic downturn, but the scale of HBOS's
credit losses was markedly worse than that of any of its major
peers. In these circumstances, the apologies of those at the top
of HBOS for the loss imposed upon the taxpayers and others ring
hollow; an apology is due for the incompetent and reckless Board
strategy; merely apologising for having failed to plan for an
unforeseeable event is not much of an apology.
126. Many of the principal causes
of the HBOS failure and the weaknesses in its business model were
known to financial markets. Public disclosures by the Group showed
the pace of asset growth, key distinctive features of the Corporate
Division's assets (including the exposures to commercial real
estate, leveraged finance and equity and joint ventures), the
pace of the International Division's growth and its concentration
in commercial real estate, and the overall Group reliance on wholesale
funding. Nevertheless, the financial markets as a whole, including
shareholders, debt-holders, analysts and rating agencies, also
failed to discipline the company's growth until it was too late.
When they did, the Group had become a serious threat to financial
The price of failure
127. At its creation in 2001, HBOS had
an initial market capitalisation of £30 billion.
At its peak in 2007, the market capitalisation had grown to over
£40 billion, when its tangible book value was £18 billion.
The HBOS annual compound total shareholder return was 6.9 per
cent over the period of nearly six years from its formation to
the end of June 2007, when the equity market was also near its
peak. As we have already noted, 96 per cent of that value has
disappeared. Those who retained their shareholdings have therefore
paid a large monetary price for failure. These shareholders include
Lord Stevenson, who told us that he invested a great deal of his
own money in HBOS shares.
128. Sir James Crosby did not fare so
As with other directors, as part of the long term incentives element
of his remuneration package, he received shares in HBOS. After
leaving the bank in July 2006, Sir James chose to sell two thirds
of his holdings.
He told us that his motive for selling his shares was "balancing
my portfolio of assets".
Because Sir James disposed of so many of his shares before financial
markets crashed, he would have fared considerably better than
those who continued to hold all their shares in HBOS until the
bank failed. This raised the issue of whether the period for
vesting deferred shares is long enough. Sir James Crosby was
knighted, was appointed to the FSA Board and then became its Deputy
Chairman, before resigning in 2009.
129. One person has paid a more direct
monetary price. Peter Cummings, who was Head of the Corporate
Division which was the largest single source of impairments on
the HBOS balance sheet in the three years from 2008, was fined
£500,000 by the FSA. The FSA's Final Notice to Peter Cummings
of 12 September 2012 states that the fine was imposed on the grounds
that Peter Cummings failed to exercise due skill, care and diligence
in managing the business of the firm for which he was responsible
(a breach of FSA Principle 6) and was knowingly concerned in a
contravention by the Bank of Scotland of Principle 3 (a firm must
take reasonable care to organise and control its affairs responsibly
and effectively; with adequate risk management systems).
The enforcement action against Peter Cummings cost the FSA approximately
£5.4mn (just over 12 per cent of the FSA's total annual enforcement
budget for 2012/13).
We have seen that the management of the Corporate Division contained
significant weaknesses, which help to explain the scale of the
losses. Peter Cummings had significant autonomy in the running
of the Division, but he was not operating in complete isolation.
Peter Cummings told us that he was under pressure from the top
of the bank to increase profit targets year on year
because, as he told us, "there was a point where the retail
bank was not performing and not delivering on the expectation,
and I was asked to step in".
Whilst accepting that the targets were not imposed on him, Peter
Cummings said that, "I certainly made it clear to my superiors
at that point that I was not all that happy about it".
130. Evidence from Peter Cummings reflected
his dismay at the process to which he was subject by the FSA Enforcement
Division, as well as the apparent arbitrariness of the means by
which the level of his fine was eventually arrived at. On the
way in which he been singled out for censure, Peter Cummings told
It is unfair, and it also seems
a bit sinister. We are not the only failed bank. There are at
least four or five of them, and I find it curious that I was singled
out. So someone, somewhere decided that that was the appropriate
action to be taken, and it is the best part of four years later,
and this is the first time that I have been asked that question.
I think it is sinister and curious.
131. In relation to the Enforcement
process, Peter Cummings found the approach to fining an individual
to be oppressive, noting that he had no institutional framework
to fall back on; no ability to call witnesses; and no ability
to analyse documents.
Peter Cummings said that "anything I explained to them, or
any representations I made to them, frankly they were not interested".
132. On the way in which the fine was
imposed, Peter Cummings told us:
I found it, if I am being blunt,
quite inept and very disappointing. In terms of the way the process
was explained to me, that I would have the ability to put my side,
and I believe that I did in the various representations, but very
little was referred to therein. They issued what my one legal
team concluded was an unlawful notice, reducing the original fine
from £1 million to £800,000, and we issued them with
a notice to say that it was unlawful because they had not explained
how the fine was constructed. Within 24 hours
the investigative team got back involved and then a phone call
to my solicitors and one meeting and approximately two phone calls
later the fine was reduced from £800,000 to £500,000
if I do not take the matter to the judicial [tribunal]
133. On the question of whether the
FSA had considered taking enforcement action against anyone else
from HBOS, they informed us that the enforcement investigation
had been conducted in the context of the large impairment losses
in the HBOS Corporate book and that "the evidence gathered
in the investigation demonstrated clearly that the most culpable
senior manager for the Corporate Division's failings was Peter
Cummings". The FSA told us that it had considered the prospects
of successfully establishing personal culpability against other
individuals to be very low.
134. The analysis that we have undertaken
of the circumstances of the downfall of HBOS leave no doubt that
that downfall cannot be laid solely at the feet of Peter Cummings.
While his personal responsibility for some staggering losses should
properly be recognised, significant and indeed disastrous losses
were also incurred by other divisions, whose heads have not been
held personally accountable in the same way. Losses were incurred
across several divisions. The losses were caused by a flawed strategy,
inappropriate culture and inadequate controls. These are matters
for which successive Chief Executives and particularly the Chairman
and the Board as a whole bear responsibility.
135. We asked Sir James Crosby whether
he considered himself a fit and proper person to run a financial
company. He replied that he had no plans to apply to be considered
as such, and doubted whether he would be approved if he applied.
Andy Hornby appeared sufficiently chastened by his experience
at HBOS as to imply that he will also not be seeking further employment
in the banking sector. Lord Stevenson viewed the question as to
whether he was a fit and proper person to run a financial institution
as "rather academic" given his age and that he had no
intention of working in financial services.
Notwithstanding these points, Lord Stevenson remained in a non-executive
position entailing his presence on the FSA approved persons register
until 2012, and in fact only formally relinquished his position
a matter of days before giving evidence to the Commission.
In the view of this Commission, it is right and proper that
the primary responsibility for the downfall of HBOS should rest
with Sir James Crosby, architect of the strategy that set the
course for disaster, with Andy Hornby, who proved unable or unwilling
to change course, and Lord Stevenson, who presided over the bank's
board from its birth to its death. Lord Stevenson, in particular,
has shown himself incapable of facing the realities of what placed
the bank in jeopardy from that time until now. Apart from allowing
their Approved Persons status at HBOS to lapse as their posts
were wound up, the FSA appears to have taken no steps to establish
whether they are fit and proper persons to hold Approved Persons
status elsewhere in the UK financial sector. In cases of this
importance the Commission believes that simply allowing Approved
Persons status to lapse is insufficient. The Commission therefore
considers that the FSA should examine, as part of its forthcoming
review of the failure of HBOS, whether these three individuals
should be barred from undertaking any role in the financial sector.
136. The Commission considers it
a matter for profound regret that the regulatory structures at
the time of the last crisis and its aftermath have shown themselves
incapable of producing fitting sanctions for those most responsible
in a manner which might serve as a suitable deterrent for the
next crisis. We will consider the changes in regulatory powers
or approach that will be needed to rectify this in our final Report.
152 HBOS, 2002 Annual Report and Accounts: "Even
in tough markets, this is the strategy that delivers",
p 7 Back
Ibid., pp 70, 129 Back
HBOS, 2001 Annual Report and Accounts: The New Force and
HBOS, 2008 Annual Report and Accounts Back
HBOS, 2007 Annual Report and Accounts: Delivering our Strategy
..., p 60 Back
HBOS Plc, Secret 20/20 Vision Group Business Plan 2003-2007,
p 61 Back
B Ev w 348 Back
B Ev w 402 Back
B Ev w 319 Back
The Group's wholesale funding included covered bonds, securitisations
and senior debt. It also raised funds in different currencies.
However, as the table above illustrates, US dollar funding proved
to be relatively volatile over the crisis and the HBOS balances
from this source approximately halved in 2008, as shown in HBOS,
2008 Annual Report and Accounts, p 27. Back
BQq 54, 345, 437, 472, 529 Back
HBOS, 2008 Annual Report and Accounts, p 27 Back
BQq 539 - 540 Back
BQq 355, 496 Back
B Ev w 326 Back
B Ev w 330, 333 - 334 Back
B Ev w 322 Back
B Ev w 326 Back
B Ev w 422 Back
B Ev w 325 - 326 Back
BQ 440 Back
B Ev w 530 Back
B Ev w 427 Back
BQ 472 Back
B Ev w 534; emphasis in original Ev w Back
BQ 440 Back
BQ 472 Back
HBOS, 2007 Annual Report and Accounts: Delivering our strategy
..., p 97; and HBOS, 2008 Annual Report and Accounts, p
BQ 533 Back
HBOS, 2008 Annual Report and Accounts, p 26 Back
BQ 570 Back
Treasury Committee, Seventh Report of Session 2008-09, Banking
Crisis: dealing with the failure of the UK banks, HC 416,
para 120 Back
National Audit Office, HM Treasury Resource Accounts 2011-12:
The Comptroller and Auditor General's Report to the House of Commons,
July 2012, p 10 Back
HBOS, 2008 Annual Report and Accounts, p 140; HBOS, 2009
Annual Report and Accounts, p 70; HBOS, 2010 Annual Report
and Accounts, p 68 Back
Lloyds Banking Group, 2011 Annual Report and Accounts,
pp 290, 303 Back
Treasury Committee, Seventh Report of Session 2008-09, Banking
Crisis: dealing with the failure of the UK banks, HC 416 Back
House of Commons Library, The Lloyds-TSB and HBOS Merger: Competition
issues, December 2008, p 7 Back
Qq 1288, 1464 Back
BQ 923 Back
Q 1276 Back
Q 1285 Back
Q 1288 Back
Q 1443 Back
Q 1585 Back
Q 1592 Back
Q 1636 Back
BQ 1069, 1071 Back
BQ 735 Back
Qq 1289, 1438, 1587 Back
Qq 1303, 1444, 1562 Back
BQq 1069, 1071 Back
HBOS, 2001 Annual Report and Accounts: The New Force Back
HBOS, 2007 Annual Report and Accounts: Delivering our strategy...,
pp 154-55, 207 Back
Q 1531 Back
Q 1234 Back
Q 1234 Back
Q 1235 Back
Peter Cummings, FSA Final Notice, 12 September 2012, pp 1 - 2 Back
Memorandum from the Financial Services Authority, 29 January 2013 Back
BQ 1225 Back
BQ 1228 Back
BQ 1235 Back
BQ 1218 Back
BQ 1372 Back
Note by witness:"I now recall that this was more than 24
hours, although the investigative team responded very quickly." Back
BQ 1371 Back
Memorandum from the Financial Services Authority, 18 January 2013 Back
Qq 1428-1430 Back
Q 1705 Back
Companies House Electronically Filed Document TM01, Resignation
Details for Lord Henry Dennis Stevenson, 04/12/2012 Back