Banking StandardsWritten evidence from Ian Taplin

Submitted by Ian Taplin, ex Lloyds Bank Wealth and Private Bank (2005–2010) and Founding Member of Whistle blowers UK(WBUK).

This submission relates to the call for evidence and testimony—specifically to 4b and 5.

Part 1 will cover 4b “arrangements for whistle blowers”. (Part 2 will cover 5; which will submitted shortly.)

Precis.

“Arrangements for Whistle Blowers, and why more bank employees do not whistle blow within UK Banks?”

Preface

1. The PPI mis-selling episode has so far cost UK banks (and the other providers)—£12 billion and the claims volumes are not abating. Yet there is no public record of any banking employee raising concerns or whistleblowing on this activity. It is public record that the FSA warned the Industry of the regulators’ concerns about mis-selling in 2005; and yet the Banks only ceased their selling activities in 2010.

2. The Libor rate rigging, we are informed—was practised by the major UK Banks for many years and again there is no public record of disclosures made by whistle blowers in the public domain.

On 27 July 2012, the Financial Times published an article by a former trader which stated that Libor manipulation had been common since at least 1991.

3. The questionable selling of interest rate swaps to small and medium sized businesses was only made public by the efforts and actions of the alleged victims; and not by any whistle blowing actions made in public by employees of the UK High Street Banks. It is estimated that between 40,000 and 60,000 businesses are affected.

4. Carol Sergeant, Chair of Public Concern at Work(PCAW), a Whistle Blowing Charity gave evidence to the Parliamentary Commission on Banking Standards, on 17 December 2012 and stated:

“One of the reasons we (PCAW) are looking specifically at financial services is that that’s an area in which they’re probably hasn’t been sufficient whistleblowing.”

With reference to the Public Interest Disclosure Act 1998, Ms Sergeant also states:

“It is time for review—both of the legislation and how it is working.”

“People have not been listened to. We need to find a way of not only encouraging people to speak out and making sure they are listened to.”

Introduction

1. I have been working in Financial Services since 1992 and have experience of working in small, medium, and large regulated firms. I was registered with the Financial Services Authority (FSA) as an investment adviser and as an approved person. Previously I was in the book publishing business and also served in the British Army—as a Platoon Commander in the Light Infantry now the Rifles Regiment.

2. I worked at Lloyds TSB from 2005 to 2010 in the Private Bank and Wealth divisions as a regulated adviser providing advice to retail customers. In 2007, I started raising concerns, internally, about alleged misconduct and regulatory breaches. In 2009 and in 2010 I submitted 2 Formal Complaints relating to concerns of misconduct and regulatory breaches. In August 2010, I was dismissed for gross misconduct for, essentially, whistle blowing.

(a)I did not seek to pursue PIDA Claims through an Employment Tribunal; as in my case such a process does not I propose serve the public interest and does not protect the LTSB customers; whom I allege have been victims of a new mis-selling episode—which the FSA are currently investigating.

(b)As a result, I am claiming I am not subject to any non-disclosure agreements nor the confidentiality clauses in my employment contract with Lloyds Bank.

(c)In 2011 and 2012, the FSA received two Formal Submissions of complaints concerning Lloyds Bank allegedly breaching regulatory law and Principles (Note 1). I have presented in person, two Formal Submissions to FSA Panels totalling over 5 hours of face to face discussions. My Formal Complaints have been acknowledged as legitimate and serious by the FSA.

3. I am also a founding member of Whistleblowers UK, (WBUK), which launched in 2012 as a self-help mutual organisation, run by Whistle Blowers as volunteers—for the protection and welfare of Whistle Blowers. The launch of WBUK has been widely reported in the mainstream media.

http://www.whistleblowersuk.org/

(a)This Parliamentary Commission has published several submissions offered up by members of WBUK in December 2012.To date ,WBUK Banking members have yet to receive requests to provide oral evidence to assist the Commission.

I, and other Banking Members of WBUK are grateful to the Commission for the opportunity for us to share our experiences; and to hopefully further assist the Commission by providing insights into the difficulties faced by Banking Whistle Blowers in the UK.

(b)We welcome the Commission’s recognition the role Whistle Blowers have to play as explained by Lord Lawson-Chairing the Sub Committee e-panel on regulatory approach—on 17 December 2012;

With regard to Whistle blowing “is there anything else that can be done to enhance the risk management function within banks? I don’t think it should be the main bulwark, but it (whistle blowing) could be a useful additional one.”

Andrew Love MP states:

“We need Whistle Blowers to be effective if we are to find what is actually going on in some financial institutions.”

A. Public Interest Disclosure Act (PIDA)

Introduction; “the legislation is considered by banks and the regulator as voluntary and as an example of light touch regulation—easily ignored”

1. This legislation was enacted by Parliament to better protect whistle blowers from detrimental treatment by employees. Being a Private Members Bill (introduced by Richard Shepherd MP)—it was only passed into the Statute Book as a voluntary and not a compulsory duty upon employers. This was apparently because of the concerns of the extra costs which may be incurred due to the administrative burdens of compulsory compliance.

2. There exists other UK legislation which also can cover some aspects of whistle blowing—in Employment Law and in the UK Bribery Act 2010. In the Financial Services sector-there are further obligations under the “approved persons” regime of the Financial Services Authority (FSA).

3. There are, however, no statutory requirements in PIDA, for organisations to have a whistleblowing policy in place. However the government would expect public funded agencies to have such a policy in place; and such agencies are apparently assessed in their whistleblowing procedures -as part of their external audit.

4. Under the Combined Code of Corporate Governance, UK listed companies are obliged to have whistleblowing arrangements and are asked to explain if they do not have such arrangements in place.

5. Whilst it appears that FSA regulated firms have statutory obligations to ensure they have robust whistleblowing procedures in place, the FSA guidelines for the UK High Street Banks on whistleblowing appear to offer only encouragement.

(a)Under the FSA guidelines SYSC 18.2.2;

(1)Firms are encouraged to consider adopting appropriate procedures which will encourage workers with concerns.

(2)For larger firms appropriate internal procedures may include; and

(3)an assurance that where “protected disclosures have been made…”

6. So PIDA appears to be more voluntary and that even within a regulated sector the FSA seemingly only encourages rather than ensuring strict adherence .This is thus considered an example of light touch regulation.

7. There is no public record of any warnings or sanctions imposed by the FSA, upon UK Banks, for failing to have adequate Whistle Blowing processes in place.

B. Bank Structures and Processes

Introduction; “BANK STRUCTURES AND PROCESSES exist which actually discourage whistle blowers”

1. Staff Manuals

(a)LTSB staff manuals detailed the procedures for making a Grievance complaint but there were no mention of whistleblowing or any guidance provided on the subject .Nor did the Staff Manual provide any reference to LTSB’s obligations as a regulated firm.

(b)The LTSB definition of a grievance is:

“A grievance is defined as a concern or complaint, actual or perceived, by an employee concerning misuse of company policies, procedures, processes or failures to honour contractual entitlements.”

(c)In my own experience, it was seven months before LTSB alerted me to their Whistle Blowing procedures despite my Grievances being primarily concerned with alleged regulatory breaches.

(d)Public Concern at Work (UK Whistle Blowing Charity) and BSI (British Standards Institution) state:

“Whistleblowing is where an employee has a concern about danger or illegality that has a public interest aspect to it; usually because it affects others (eg customers, shareholders, or the public). A grievance or private complaint, is by contrast, a dispute about the employee’s own employment position and has no additional public interest dimension. Unless the organisation’s arrangements make this distinction, it cannot assume or expect that its employees will understand the difference and act accordingly.” (Note 2)

(e)LTSB “bundled up” grievances and whistle blowing complaints. This “bundling up” of employment related grievances with regulatory based complaints within a Grievance Process can have serious ramifications for whistle blowers (WB). WBUK Banking Members consider this practice as seemingly deliberate.

For example:

(1)The WB concerns(which are regulatory based)—could be dealt with by the HR Department who have no proper remit to deal with regulatory based complaints as they have no qualifications as regulated personnel in the “approved persons” regime.

It is Compliance personnel with the required approval and qualifications that should deal with regulatory based complaints.

(2)HR departments can also appoint Line managers such as Sales Directors to conduct the Grievance meeting and subsequent investigation; even though it is the Compliance Staff that should supervise regulatory based complaints and any subsequent hearing and investigations.

So the WB regulatory based complaint is dealt with by Sales and HR staff; and the direct contact with the appropriate Compliance Staff may be denied to the employee whistle blowing even though the Complaint is their responsibility.

2. The Line Management Dual Duties

(a)The Management at LTSB Wealth doubled up on sales and compliance duties. So the sales consultants were supervised by a manager who had responsibilities for sales targets as well as the compliance requirements laid down by the FSA, the regulator.

This structure of dual responsibility (of sales and compliance duties) extended up to the Managing Director of LTSB Wealth.

There is an obvious conflict of interest inherent in such a structure as the incentives to achieve substantial monetary bonuses by reaching sales targets could well outweigh the absence of similar financial incentives to achieve compliance targets of “treating customers fairly”.

Therefore there is a disincentive for management to listen to whistle blowers. Such a system acts as deterrence for the line management to assist the whistle blower and to protect them—even under “due duty of care” obligations lay down by Employment Law guidelines.

3. Incentives

(a)The LTSB Incentives system during 2005–10 ensured that if a regulated sales consultant achieved a sale—then a complicated and extensive matrix of staff would benefit from such a sale. The cross-selling opportunities of the LTSB Bancassurance model would only operate profitably if the referral system was working for maximising the sales prospects.

Therefore, when I received a referral from a junior sales consultant who was based in a LTSB Branch, I was aware that many more LTSB staff depended on me to make a sale—for their own targets and performances were dependent upon me to achieve the sale.

Most of the LTSB staff that was depending upon me to make the sale were non–regulated branch staff—and who often had no expertise to assess the suitability of a sale to a customer. So, if for any reason I decided that there was no scope to provide further advice to the customer and therefore I do not make a sale—I would be criticised by the non-regulated management that I had failed to make a sale.

I calculated there were eight LTSB staff members who were depending on me to make the sale on LTSB branch referrals and whom would be awarded points as a direct result of a sale being achieved. A large capital sale of an investment of say £500,000 would make a substantial difference to the monthly targets of these dependent LTSB branch staff.

(b)The Bancassurance Model is designed to exploit the vast customer base in retail banking. LTSB is first and foremost a retail bank and main source of profits is derived from the non-regulated activities of lending. The smaller regulated sales operations were totally dependent upon the retail bank ensuring a constant flow of customer referrals.

The pressure is on the regulated sales consultants to make the sale to achieve his own targets and help the non-regulated retail staff achieve their own targets; and thus to be regarded more highly by the non-regulated powerful retail bank.

(c)The nature of the interdependency of such a sales system and the wide distribution of awards from sales does not lend itself to an employee wanting to blow the whistle as the employee would be considered disloyal and would often feel disloyal themselves. Often these work colleagues have known each other for many years and have pursued their careers within the Bank together.

This pressure, not to whistle blow, is immense.

4. The Issue of Leadership

(a)This interdependency of sales of the Bancassurance Model reaches into the highest levels of the corporation; and the Executive Directors responsible for their respective Divisions were able to reap substantial rewards from the Bancassurance operation.

(b)If the commercial considerations of the Bank were seemingly threatened by a troublesome whistle-blower, experience has shown us, that Senior Level Executives will ignore the whistle blower and their own regulatory responsibilities- in order to accumulate more wealth.

Even if such Senior Level Directors receive direct correspondence from a Whistle Blower (sent by registered mail) whom is appealing for assistance and leadership -because of obstruction or intimidation -the whistle blower will be ignored even though the Director has statutory obligations as a “approved person”.

This is known as “wilful blindness”-and is a common phenomenon the whistle blower has to deal with.

(c)Concerning PPI mis-selling, the FSA warned the Banks about the inappropriate selling of this contract in 2005 when the regulator assumed responsibilities for supervising insurance contracts. Despite the introduction of regulatory supervision and repeated FSA warnings, the UK High Street Banks persisted on selling the PPI contract through to 2010. This was in defiance of the FSA whom were evidently considered to be light weight regulators.

(d)The various Banking leaderships were thus openly ignoring the regulators. Substantial financial rewards were paid out to Executive Board Directors partly made up of the high margins generated by the selling of the PPI scheme; a clear example of senior level misconduct and self-enrichment.

(e)This Senior Level self-enrichment through open and public defiance of the regulators has undermined the workforces’ own confidence in the integrity of the Bank they committed to work for—since school or University; and upon which they have become totally dependent to reach their own personal and career goals.

(f)Thus the rank and file employee, whom having no leadership example in the ethics of how to properly treat customers and how to be a partner in a good business model—becomes hardened to the rights or wrongs of abusing the trust of the customer .The employee can become cynical as to standards the leadership claim to be upholding in the Bank’s own published “Code of Conduct”.

So in this vacuum of any quality leadership and example—there is no public record of a Bank employee whistle blowing on the PPI mis-selling scandal, the LIBOR rate rigging, and the sale of Interest Rate Swaps.

5. No Formal Training

(a)The FSA Principles and Guidelines use key words or phrases such as fairness, transparency, or acting in the clients “best interest” and “treating customers fairly.” (Note 3)

These Regulatory Principles and Guidelines have had little meaning to staff when they have been so heavily targeted to sell an Insurance Contract such as the PPI product.

So given the Financial Services and Markets Act 2000 relies upon basic principles of how to conduct business—being adhered to; then it follows that regulated staff should be trained on how the FSA Principles apply to actual behaviours when dealing with customers.

(b)Regulated Staff are well trained on the risks of money laundering activities and banking fraud through the retail networks—yet many would hard pressed to answer how the FSA Principles apply to their everyday activities.

(c)Nor is there any formal training on the Whistle Blowing Legislation and how PIDA is embedded in FSA Guidelines.

(d)I would also suggest few regulated staff would realise that the FSA guidelines expect a bank to ensure a direct discreet channel to Compliance Staff is available which can bypass the usual line management structures.

C. Bank Behaviours

Introduction; “BANK BEHAVIOURS towards whistle blowers can include intimidation, obstruction, and deliberate confusing actions”

1. Based upon the research available and indeed the experiences described in the media in the UK and indeed by members of Whistle blowers UK there is seemingly a pattern of behaviour which is displayed by Large Corporates when dealing with whistle blowers.

2. The US based Government Accountability Project (GAP)—the US Whistle Blowing Charity—has published the “Corporate Whistle Blowers Survival Guide”; written by GAP Legal Director Tom Devine and former GAP Investigator Tarek Maassarani.

http://www.whistleblower.org/action-center/know-your-rights-campaign/banking-industry/corporate-whistleblowers-survival-guide

The guide describes the “Malek Manual”, which according to GAP may be used as an HR Manual on how Corporations should treat whistle blowers.

For example:

(a)Ignore the whistle blower and then isolate them by ensuring the whistle blower goes on sick leave limiting the potential collateral damage.

(b)Ensure his workmates are informed the whistle blower is on sick leave dealing with his health problems and instructing them not to contact the whistle blower.

(c)Refusing to deal with the Whistle blowers complaints until cleared fit for work by his doctor; whilst simultaneously taking steps to make the whistle blower redundant.

(d)Promising investigations but refusing to commit to informing the whistle blower the results of the investigations.

(e)Multiple investigations are promised as the whistle blower escalates his complaint through the corporate hierarchy.

In my own case there were five new investigations into my two regulatory based complaints.

(f)Confuse the whistle blower by:

(1)Not disclosing the wider management structure and the direct lines of reporting.

(2)Not disclosing the identities of key legal and compliance staff with whom the whistle blower should have access to.

(3)Being selective in answering queries and ignoring substantial elements of a regulatory based complaint which has the effect of delaying matters and building up volumes of correspondence; which can wear down the employee whom is suffering from stress.

(4)Claims by Senior Executives they have not been given certain key evidence and therefore cannot comment.

(5)Compliance Staff refusing to discuss issues such as WB intimidation –as intimidation is an employment matter and therefore not a compliance concern.

(6)HR refusals to accept whistle blower complaints against Senior Directors have any validity; and failing to explain why Senior Directors are protected from employee complaints.

(g)Using subtle and not so subtle intimidation and obstruction:

(1)In correspondence with the WB -constantly referring to the WB as being on sick leave and therefore being unwell might affect the validity and legitimacy of his concerns.

(2)Using threats of disciplinary action if WB refuses to follow the HR processes if the WB lawfully complains that access to Compliance Staff is being blocked by HR and his own line management.

(h)Senior Executive Board Level Directors standard policy of refusal to reply to registered mail sent by the Whistle Blowers trying to bypass obstruction.

(i)Making oral offers of a settlement then denying any offer has been made when asked to put such offers in writing.

(j)Dismissing the whistle blower for gross misconduct forcing the whistle blower into an Employment Tribunal—or the court system which invariably is stacked against the whistle blower.

D. Employment Tribunals

Introduction; “The EMPLOYMENT TRIBUNAL system does not serve the whistle blower making PIDA claims.” Public Concern at Work 2011. (Note 4)

1. If a whistle blower decides to pursue claims for wrongful dismissal there are concerns that the current ET system does not serve whistle blowers making PIDA claims.

(a)The removal of legal aid often forces the whistle blower to use lawyers on a “no win no fee basis”. The conditionality of using legal advice in this way can mean the retained lawyer has more interest in advising a settlement than encouraging the whistle blower to insist on a formal hearing in the public interest.

(b)Therefore there is pressure to settle and agree to a non-disclosure agreement which does not serve the public interest element in the whistle blowing action. PCAW report that over 75% of PIDA Claims are settled before an ET Hearing—which means we have no information as to what caused the whistle blower to act.

(c)Therefore the public interest element to the whistle blowers action are lost and the problems which seem to been identified within a corporation are buried-to the detriment of the public interest.

Cathy James CEO of Public Concern at Work wrote in 2012:

“There is an increasing urgent need for greater transparency in claims brought (through the ET system) under the Public Interest Disclosure Act.”

“Public interest information is likely to be buried in settlements.” (Note 5)

2. PCAW and WBUK are campaigning for greater transparency in Employment Tribunals as there is scant information available. The ET system is underfunded and scattered across the UK with no central mechanisms to capture key data.

PCAW and WBUK are calling for a central online database with details of ET judgements to ascertain the public interest elements which may affect the public welfare.

3. Regulators such as the FSA/FCA should be expected to liaise with the ET to ensure information on judgements which concern regulated activities and public interest matters—are shared with them. The FSA/FCA thus have a key role in capturing ET information.

E. The Financial Services Authority (FSA)

Introduction; “whistle blowers have little confidence in the FSA and confidence in the new PRA/FCA has already been undermined”

1. The FSA is being replaced with two new regulators—the Prudential Regulatory Authority and the Financial Conduct Authority. The FSA is being replaced because of the regulator’s failures to properly regulate and supervise the banking sector.

There are many reasons for this failure but light touch regulation must be considered a major factor; and the FSA’s own behaviour towards whistle blowers seems to suggest that the light touch regulation effect has also determined how whistle blowers have been dealt with.

WBUK Banking members can relate that when complaints are submitted to the FSA-they never receive any further correspondence other than a brief curt acknowledgment.

2. On the subject of WB being offered settlements and agree to non-disclosure agreements -the FSA wrote in 2011:

“The FSA is well aware that regulated firms will often offer to compromise claims to former employees rather than contest a claim through the tribunal system or the courts. There seems to us to be nothing inherently wrong in this. Indeed, the courts themselves actively encourage the early settlement of claims. We are also aware that, as part of a settlement, firms will usually include a confidentiality obligation in an agreement with the former employee. We also see nothing inherently wrong in this.” (Note 6)

There is no public record of the FSA requesting the reasons behind WB blowing the whistle whom then reach settlements with employers—despite the FSA writing in 2011:

“The (regulated) firms understand that the confidentiality obligation does not prevent the FSA from being able to obtain information from the former employee, where they have information which is relevant to the carrying out of our regulatory functions.” (Note 6).

We question how can the FSA seek to retrieve such public interest information when they have no willingness or indeed formal processes to obtain such information?

3. S43J of PIDA expressly states that any clause that seeks to gag an individual from making a protected disclosure is void and unenforceable but there is no public record of the FSA enforcing this principle to obtain information from regulated firms to protect the public interest.

4. WBUK are aware that should a former employer seek to disclose sensitive information in the public domain and break any non-disclosure agreement he could only do so—and avoid the corporate backlash—with an overwhelming public and media interest at that time—as in the case of Paul Moore and HBOS. There are few examples of whistle blowers breaking such non-disclosure agreements in the banking sector.

5. When a whistle blower contacts the FSA and submits his concerns the FSA will advise the Whistle blower:

“For legal and policy reasons, we will not be able to let you know the outcome of our inquiries or to give you progress reports. Should you have any further information at a later date we would like to direct you to our dedicated whistleblowing team within the FSA who can assist you.” (Note 7)

(a)Unless the FSA moves to enforcement action against the regulated firm, the WB complaint disappears into a black hole.

(b)WBUK members can supply evidence that having presented robust evidence of regulatory misconduct to the FSA they are then ignored and subsequent efforts to re-engage with the FSA are disregarded.

6. There is thus a contradiction inherent in such regulatory methodology in dealing with approved persons whom are whistleblowing. The FSA insists that approved persons should adhere to the FSA Principles and report any concerns of regulatory breaches; yet the FSA refuse to disclose any details of their investigations.

How can a regulated person therefore fulfil his own statutory responsibilities to ensure the customer’s interests are being protected when the FSA refuse to share any information with the regulated individual whom is whistle blowing?

7. Whistle Blowers have no confidence in the FSA and the wider public’s confidence has been undermined in the regulator’s failure to supervise the Banking Sector.

(a)Recent statements by Andrew Bailey, the new head of the Prudential Regulatory Authority whereby he publicly stated that UK High Street Banks are too big to prosecute; and such statements have already begun to undermine the fragile confidence in the new regulator—set up precisely correct the failures of the FSA—which it is replacing.

“Mr Bailey told The Daily Telegraph that some banks had grown too large to prosecute. ‘It would be a very destabilising issue. It’s another version of too important to fail,’ he said”. (14 December 2012)

http://www.telegraph.co.uk/finance/newsbysector/banksandfinance/9743839/Banks-are-too-big-to-prosecute-says-FSAs-Andrew-Bailey.html.

8. We know of many examples of UK High Street Banks sacking employees for whistle blowing yet the FSA has failed to properly assist WB, even when their WB actions taken are to precisely fulfil their own regulatory duties as “approved persons”.

BBC Newsnight reported on 11 September 2012:

“Newsnight can reveal that not a single UK-based bank has ever been punished for firing a whistle blower within its ranks—even though these individuals are protected in law since the Public Interest Disclosure Act 1998 came into force.

When Newsnight approached the FSA for a response it said it would not comment on individual cases, but acknowledged that no bank had ever been sanctioned in such circumstances.”

http://www.bbc.co.uk/news/business-19545849

F. Whistle Blowing is Self-Harmimg

Introduction; “whistle blowers have their careers ruined, their financial security destroyed, and see their families suffer”

1. Well known UK Banking Whistle Blower Paul Moore, ex HBOS, is unable to find similar work—from which he was fired—for internally whistle blowing .He was a Senior Group Risk Officer at HBOS and was fired for properly reporting that the HBOS sales culture was an emerging risk to the business. Paul Moore’s reported income in 2012 was £15,000.

2. Martin Woods, ex Wachovia Bank Money Laundering Officer, was forced to leave the London branch when he reported Wachovia processing Mexican drug cartel money; crimes for which Wachovia paid $160 million in fines. In 2012, when applying for a similar position at Coutts Bank (whereby he disclosed his experience at Wachovia)—he was offered a position by Coutts Bank—but Coutts then withdrew the job offer having second thoughts. Martin, an ex-Metropolitan Police Officer-has at last secured work for which he is trained.

3. There are many other examples of WBUK Banking members whose careers have been severely affected or destroyed, their financial security ruined and their family life put under immense strains—for voicing their concerns through their whistle blowing actions—acting as they were, in good faith in the public interest and for the public’s welfare.

4. WBUK believe it is time to recognise that properly protecting legitimate whistle blowers, whom act in good faith is vital, within a democracy, and genuine whistle blowing is as effective as regulation.

Notes and References

1. FSA Principles.
http://fsahandbook.info/FSA/html/handbook/PRIN/2/1

2. PAS 1998–2008; Whistleblowing arrangements—Code of Practice.
Published by the British Standards Institute with Public Concern at Work 2008.

3. FSA Guidelines “Treating customers fairly”.
http://www.fsa.gov.uk/doing/regulated/tcf

4. “Whistle Blowing; beyond the law .The Biennial review.”—published by Public Concern at Work; Oct 2011. (Page 10)

5. As in Note 4; Cathy James CEO PCAW; (Page 3).

6. Statement written in a letter to the author sent by FSA Lloyds Bank Relationship Manager; June 2011.

7. Statement written in an e-mail sent to the author by FSA Lloyds Bank Conduct Manager Oct 2012.

11 January 2013