Evidence Session (Sections 1-99)|
8 MARCH 2006
1. CHAIRMAN: Mr McCulloch, could I welcome
you and your team this afternoon to come and put your Bill before
us. Perhaps you would like to introduce your team to us and then
after that tell us what you want to tell us and we will ask you
any questions we feel appropriate and take it from there.
2. MR McCULLOCH: Thank you very much,
sir. May I begin by introducing to you first Mr Brian Fisher who
is Head of Group Legal at HBOS plc. HBOS is the group or parent
company from which the Bill derives its name or its short title.
The group company, HBOS, was formed on the merger of the Bank
of Scotland and Halifax plc in 2001. HBOS is the publicly quoted
company and it is Mr Fisher who has been involved throughout in
the preparation of this Bill from its inception. With Mr Fisher
is my colleague from my own office, Nicholas Evans from Bircham
Dyson Bell, and just to my right, of course, as always, is our
senior parliamentary clerk, Pam Thompson.
3. CHAIRMAN: Thank you.
4. MR McCULLOCH: Sir, technically the
Bill is promoted by two wholly owned subsidiaries of HBOS, that
is the Bank of Scotland, whose formal name is actually the Governor
and Company of the Bank of Scotland, and also by Clerical Medical
Investment Group Limited, and I may call them CMIG for short at
5. This is, in fact, an unusual Bill even by
the standards of Private Bills because although it follows the
usual principle of providing how the general law might apply to
the situation being dealt with by the Bill, in this case - very
unusually, I think - the Bill actually modifies an Act of the
Parliament of Scotland. Not the current Scottish Parliament, I
hasten to emphasise, but the Parliament that existed before the
Treaty and Act of Union. The Parliament of Scotland established
the Bank of Scotland by a 1695 Act entitled An Act of Parliament
for Erecting a Bank in Scotland. This made the Bank of Scotland
Britain's oldest commercial bank. For reasons which I will come
on to, sir, it is now thought desirable to amend that 1695 Act.
It has been changed over the years on previous occasions before
Parliament but, even so, some of its provisions have stood the
test of time by some 310 years.
6. So far as we can tell, should it be of passing
interest, sir, no Act of the pre-Union Parliament of Scotland
has been modified by this Parliament since 1970, over 35 years
ago, which was the Conveyancing and Feudal Reform (Scotland) Act
1970 modifying the Bankruptcy Act of 1696.
7. The main purpose is to reorganise the group
of companies that are the subsidiaries of HBOS. This is sometimes
referred to internally at the bank as the "banking licence
consolidation programme". There are three subsidiary purposes
to this. The first is modernising the regulation and management
of the bank, which is to register it as a public limited company
under the Companies Act 1985 in order to bring it into line with
modern company regulation. Then, secondly, to transfer to the
modernised Bank of Scotland the undertakings of three other HBOS
banking subsidiaries: Halifax plc, Capital Bank and HBOS Treasury
Services. In the case of Halifax and the Bank of Scotland this
will give full legal effect to the merger of the Bank of Scotland
and Halifax that took place in 2001. Thirdly, and lastly, to transfer
to CMIG what is sometimes called the "legacy property"
still held in the statutory body the Clerical, Medical and General
Life Assurance Society. I will come back to that later, if I may,
8. The structure of the Bill follows this pattern:
firstly dealing with the modernisation of the Bank of Scotland;
secondly dealing with the bank transfers of the undertakings;
and finally dealing with the Clerical Medical situation.
9. So far as modernising the Bank of Scotland
is concerned, the bank is an unusual company. It is a statutory
company. As I said, it was constituted in 1695 by a pre-Union
Act of the Scottish Parliament and regulated under a series of
private Acts dating from 1695 through to 1970. These various Acts
are set out in the preamble to the Bill.
10. The key Act now is the Bank of Scotland
Act 1920 which sets out the bank's business and objects and its
regulations, matters which would normally be found in a company's
memorandum and articles of association. Some of these provisions
are now in need of updating and this requires a Bill.
11. We believe all these changes are uncontentious.
It is really a matter of good corporate governance to update the
bank's objects in this way.
12. In order to provide for a smooth transition
to this plc status and to accommodate the merged undertakings
of the Bank of Scotland and Halifax it is also necessary to amend
and repeal the existing Acts regulating the Bank of Scotland,
and the Bill provides for this.
13. Sir, as well as the items covered by Schedule
1 to the Bill, which are the equivalent of the objects in a plc
company, there is a substantial body of regulations and it was
felt desirable to leave those out of the Bill but a copy of them
has been deposited with Parliament so that if any Member wishes
to see the very full picture it has been made available.
14. Turning to the bank transfer if I may,
sir. Under the present system, HBOS has four banking undertakings
and each has a separate licence leading to what is now regarded
as unnecessary duplication and cost: four boards, four sets of
accounts, the administration of four banking licences and so on.
The creation of a single entity, Bank of Scotland plc, would simplify
15. The legal position, however, is that although
the Bank of Scotland and Halifax came into common ownership in
2001, legally they remain separate entities. The need for legislation
arises in this situation because a bank may not, as a matter of
law, transfer a customer's money to another bank without the customer's
consent. Clearly in the case of a bank with thousands and thousands
of customers, to obtain the consent of each and every one of them
is just regarded as wholly impractical, so whilst the two banking
businesses may pass into common ownership through the merger of
the share ownership, the actual businesses themselves cannot legally
fuse and operate as one undertaking without special authorisation,
and in this case by this Bill.
16. The HBOS name will be unaffected by this
and the bank's retail activities will continue to be carried out
under the Bank of Scotland or Halifax as the case may be, it is
just that these will now operate under a single legal undertaking
operating under a single banking licence.
17. There is a view, sir, that nowadays banking
undertakings can be merged under the Financial Services and Markets
Act 2000. Certainly there is provision for this in the Act and
banks have looked very carefully at the scope of those provisions
to see whether their particular situations come within it. However,
in this particular case, sir, the transfers are directly linked
to the modernisation of the bank's constitution and add to this
some doubts there have been about the effectiveness of the Financial
Services and Markets Act to cover every eventuality which can
arise with an undertaking as complex as this it was regarded as
expedient to proceed in one vehicle in this way by a Bill.
18. The bank, therefore, seeks Parliament's
approval which provides not only for the constitutional changes
but also to the merger so that these may proceed on the same timetable
and to avoid the complications and costs of proceeding under separate
procedures which would have their own different timescales.
19. If I may turn to the Clerical Medical situation.
So far as Clerical Medical is concerned, the Society was set up
by Deed of Settlement in 1827. This was replaced by Acts of Parliament
between 1850 and 1974. The Society is presently incorporated under
the Clerical, Medical and General Life Assurance Society Act of
1974. When the Society demutualised in 1996 its long-term business
was transferred to CMIG, one of the two Promoters of this Bill,
by a scheme made under the Insurance Companies Act 1982 which
enables transfers of such a kind.
20. In respect of some residual assets, however,
although the beneficial ownership was transferred to CMIG the
legal asset was left with the Society. This was partly, I think,
sir, because the scheme undertaken was an application of English
court and there were some Scottish assets to deal with. That is
an example of why not everything went across under the terms of
the scheme. These residual assets should now really be transferred
to CMIG - they have to be transferred - before the Society can
be dissolved. HBOS would like the Society to be dissolved, so
it seems convenient to deal with all of this in the Bill at the
same time. By transferring these residual assets so the Society
can finally be dissolved.
21. So far as Clerical Medical is concerned,
therefore, I think it is fair to say that the Bill is a sort of
tidying up exercise which transfers to CMIG, which already carries
out the business of the Society, the property that has never been
transferred by any other means.
22. Regarding the promotion generally, although
this reorganisation is essentially internal to the bank in the
sense that the companies are all subsidiaries of HBOS, the shareholders
have formally consented to the promotion of the Bill in accordance
with Standing Orders, no objection has been raised to the promotion
by anyone, whether customers, employees or third parties, and
in particular there has been no petition against the Bill, no
government department has reported on the Bill expressing any
concerns, and the minister was content with the Bill's statement
of compatibility with the Convention on Human Rights.
23. I expect you would like me to turn briefly
to the provisions of the Bill, sir?
24. CHAIRMAN: Yes, but reasonably briefly.
25. MR McCULLOCH: The main provisions
are included in Parts 2 and 3. Part 2 is the part which updates
the regulation and management of the bank and this will hinge
upon its registration as a plc when that occurs.
26. Clause 3 provides that these provisions
will only come into force upon that event taking place.
27. Clause 4 gives the bank a new name, Bank
of Scotland, rather than the reference to the Governor and puts
the company on the same footing as all other plcs.
28. Clause 5 contains various savings provisions,
ensuring that neither the registrations of plc nor the change
of name in any way affects the bank's current rights, liabilities
and obligations. In particular, it ensures that the bank's historic
right to issue banknotes is safeguarded.
29. Clause 6 updates the bank's business and
objects, providing new provisions that are set out in the Schedule,
as I mentioned earlier. Again, to put the bank on the same footing
as any other plc it may now alter its new business and objects
without having to come back to Parliament each time to do so.
The clause will provide that the business and objects set out
in Schedule 1 will be the statement of objects that would normally
be the company's memorandum. Strictly, it will not have a memorandum
because it will still remain a statutory company under the 1695
Act, but it is achieving an equivalent position to a modern plc.
30. Clause 7 provides that the current regulations
for the bank's administration are to be replaced by a set of new
regulations. These have been approved by the board. They are modelled
on the HBOS regulations. These will now be changeable in the usual
way as they would be for any other company wishing to change its
own articles. As I explained earlier, sir, we have not included
those in the Bill itself because they run to very many pages and
essentially it would have been a heavy printing exercise with
probably little benefit.
31. Clause 8 makes the consequential amendments
and repeals of the old Bank of Scotland Acts which are not longer
needed. Part 3 allows for the mergers to take place.
32. Clause 9 allows the Bank of Scotland to
appoint days for the transfers of Halifax, Capital Bank and HBOS
Treasury Services to take place. Sub-section 2 also provides that
this will not occur before registration of the bank as a plc takes
33. Clause 10 provides for the undertaking
of each transfer company to vest in Bank of Scotland on the day
appointed for that company. I think the remaining provisions of
Part 3 are intended to supplement this with a range of very well
developed boilerplate type provisions, which essentially are to
achieve a position of neutrality for third parties that might
otherwise be affected, possibly inadvertently in some way, by
the fact of a transfer of one undertaking to another. As you will
realise, sir, from previous Bills of this kind provided for mergers
there has been a well-honed way of doing this over the years,
and all of these provisions, I think it is fair to say, are very
34. Jumping to clause 18. This provides for
the transfer of companies to be dissolved when the undertakings
have been fully vested in the Bank of Scotland.
35. Clause 22 ensures that the mergers do not
affect the Bank of Scotland's right to issue banknotes.
36. Clause 23 gives equivalent powers to transfer
the remaining assets of the Society to CMIG and then for the Society
to be dissolved.
37. As I said, sir, the Bill follows precedent
very closely, but we do propose a few amendments to the Bill as
deposited. These have arisen in consultation with Speaker's Counsel
and also Counsel to the Lord Chairman in the other House. These
have been marked up on your copy of the Filled-up Bill, which
I believe you have had circulated to you. I think it is fair to
say that they are all amendments of a pretty technical or drafting
nature and, to some extent, formatting. There are some typographical
changes and so forth. Sir, I think the amendments that you see
marked on the copy of the Bill are part of the quality control
process since the Bill was introduced.
38. I think you will have been made aware,
Sir, that if we may we would like to make some last minute changes
to clause 16. This arose very recently when we became aware that
a provision in the Income and Corporation Taxes Act 1988, which
uses the expression "retirement benefit scheme", which
we use in clause 16 of the Bill, is being changed by the Finance
Act of 2004 with effect from 6 April of this year. That expression
is to be replaced by the expression "pension scheme".
39. We have looked at this quite carefully
and we believe that so far as it applies to the bank it is a terminological
change purely as a consequence of this change of a public Act.
It seems appropriate, if we may be allowed to do so, sir, to deal
with that now whilst we are about to appear before you for this
unopposed Bill Committee Stage and make those changes which are
consequential upon the changes of the 1988 Act by the 2004 Act.
Sir, those changes are shown in a Paper Apart which I hope has
been circulated to you.
40. CHAIRMAN: Just.
41. MR McCULLOCH: We alighted
upon this point very recently as part of the ongoing due diligence
when one is looking at a Bill. There they are before you, confined,
however, fortunately, to clause 16, to this terminological change.
42. Sir, unless you wish me to go deeper, I
think that is probably all that you may require.
43. CHAIRMAN: I think that is very comprehensive
as far as the Bill itself is concerned. We understand the need
for amendments which are annotated in the Bill itself. I think
the Committee might well want a little more explanation either
from Mr Fisher - it has been Mr Fisher's baby from the beginning
of this Bill - or yourself as to why we were confronted with these
last minute amendments since the Finance Act to which it relates
was passed in 2004. We would have thought that somebody would
have seen this situation on the horizon.
44. MR McCULLOCH: May I try and
deal with that because I think it would be fair if I were to take
45. CHAIRMAN: Is it your responsibility?
46. MR MCCULLOCH: I think it
is fair to say it is.
47. CHAIRMAN: Then by all means take
48. MR MCCULLOCH: Unfortunately,
when one public Act is amended by another it does not ring a bell.
We were not aware of this particular change because, if we can
be allowed some measure of tolerance in this whole process, there
was nothing to alert us that this particular definition in the
1988 Act was being changed. In fact, we were exercising due diligence
in a rather different direction when we alighted upon it. There
are some new TUPE regulations, TUPE being the Transfer of Undertakings
regulations, which protect the interests of employees in certain
situations. We thought, "Let us just check that there is
nothing lurking there in the TUPE regulations which could have
some bearing on our Bill". We did not think it would, sir,
because all the employees we are concerned with here, whether
working for the Bank of Scotland or working for the Halifax, are
employed by HBOS Group, the parent company. Nevertheless, we thought,
"Let us just check and see what happens". It was in
checking those regulations that we spotted this change to the
proposed terminology in the 1988 Act which we were aware that
we had used in clause 16. It was something of a side wind, to
be honest, that we even alighted upon this just very, very recently.
49. CHAIRMAN: What would have been the
effect if you had not alighted upon it?
50. MR McCULLOCH: I think in
substance no effect. It might have been picked up later in the
process, of course, it could have been picked up anywhere, but
the underlying substantive issue is unchanged by this. Unless
Counsel thinks otherwise - he is perhaps better equipped to deal
with this question than I am - I think because the underlying
substantive issue is not being changed here, it is just a change
of the terminology. Ultimately, I suppose we could have had a
situation where Parliament would have passed an Act with an out
of date reference in it.
51. CHAIRMAN: I will ask Members of
the Committee to come in if they wish to. We were not concerned
so much about the substance of it, but the fact that it had not
been picked up. As a Committee, we like to have notice of what
we are trying to do. We like to be precise, as I am sure you do
too, and we would have liked a little more notice of what was
52. MR McCULLOCH: I am very conscious
of that. Of course, we are entirely at your disposal, sir, as
to whether you choose to deal with it now or whether we should
leave this to another stage in the Bill. Obviously, from the Promoter's
point of view, we would prefer to deal with it now having identified
it, given that it does not, in our view, raise a difficult or
53. CHAIRMAN: Thank you. Mr McCulloch,
does that basically deal with what you want to tell us or do you
want either of your colleagues to say anything more at this stage?
54. MR McCULLOCH: Sir, I think
we would be very happy to leave it to any further questions you
55. MR BAILEY: I have no objection in
principle either to the issue which has just been raised or the
Bill. It is really just a matter of curiosity. I understand the
concept of a statutory company and the fact that should there
be subsequent alterations to it then there have to be statutory
amendments to it. Obviously I understand the concept of a plc,
but what I do not understand is the position that we seem to be
moving to where we have a statutory company which is a plc. Presumably
in the future we would not have to have alterations made by Parliament
to any changes which would take place in the structure of the
Bill or whatever. Why do we not just ask for a repeal in the law
and go forward as a normal plc with a memorandum and articles?
56. MR McCULLOCH: May I give
an initial answer and if Mr Fisher wishes to add anything, he
may do so. The key issue in this situation is to ensure continuity
of the legal entity one way or another. There are certain benefits
that flow from that continuity, but essentially it is intended
to achieve a situation of neutrality for any third party which
may be affected adversely by a change of legal entity. In certain
contractual relationships in the financial services sector that
can trigger certain events which would be disadvantageous to a
third party. It is considered of paramount importance to retain
the continuity of the legal entity.
57. The bank never seriously contemplated just
repealing the 1695 Act in its entirety and starting up a fresh
company, it was felt that the prudent course was to retain its
original identity. One of the benefits for the bank is to retain
its right to issue banknotes, which is considered very important.
58. MR FISHER: We are very keen that
the bank, which was incorporated in 1695, can be seen as a continuing
entity and the issue of banknotes is a key consideration for us
59. MR WALTER: I have three questions
but one of them probably hangs on what you have just said. You
are moving from a statutory company into a plc and one of the
reasons why you want to retain the current status is with regard
to the issue of banknotes. There are many people in this country
who get very exercised by the way in which banknotes are presented
in terms of what they represent because they represent the currency
of the country. Clause 22 says that you can continue to issue
banknotes, and nothing in this Bill affects that, but clause 4
says that you can change your name without coming back to Parliament.
Under that provision could we see that Bank of Scotland banknotes
might in future be called something else, maybe Halifax banknotes
or the Bank of McDonald's banknotes or some other name? I am rather
concerned that the provisions under clause 4 that you can change
your name without reference to Parliament would mean that the
shape and colour and name on the banknotes could also be changed
without reference to Parliament.
60. MR McCULLOCH: I suspect, sir, that
the bank's notes have changed in various ways over the years reflecting
certain changes to the bank itself or in design terms, for example.
61. MR FISHER: Certainly there is no
intention of changing the name of the company further that I am
aware of. This will simply put us on the same footing as the other
Scottish clearing banks that issue banknotes and are themselves
plcs and therefore able to change their name with appropriate
shareholder consent, as far as I am aware.
62. MR WALTER: So what you are saying
is that you would be in the same situation as the Royal Bank of
Scotland and Clydesdale Bank and they could change their name
if they so wished so the name appearing on the banknotes could
be something totally alien to either Scotland or the United Kingdom?
63. MR FISHER: As far as I am aware.
I am afraid I am not able to speak authoritatively for those other
banks but I am aware that they are plcs and, therefore, under
the general law would be able to change their name with shareholder
consent and the consent of the Companies Registrar. I am not aware
of any other restrictions on them in terms of changing their name.
64. MR WALTER: I am throwing out an
idea that you might subsequently be taken over by the Union Bank
of Switzerland or somebody so we could have the Union Bank of
Switzerland banknotes issued in Scotland. Would that be beyond
the realms of possibility? I am not suggesting that they are about
to make a bid for them.
65. MR FISHER: The Union bank would
not be able to do so, only the entity that was incorporated in
1695 would be able to issue banknotes.
66. MR WALTER: But you could change
67. MR FISHER: It could change its name,
68. MR McCULLOCH: Although there has
been a merger of Halifax and the Bank of Scotland, sir, and it
is proposed to complete that legally by this Bill, that does not
enlarge the bank's power to in itself issue banknotes either.
It is not as if it can now issue double the notes it used to or
anything like that.
69. SIR ROBERT SMITH: Can you clarify
the power to issue banknotes. In the legislation from which that
flows, are there any restrictions on the design or the information
that can be on those notes?
70. MR McCULLOCH: I do not think there
is. I am rapidly reaching for a note I prepared quite a long time
ago which gives the statutory derivation of these powers because
it goes back to the Bank Charter Act 1844, the Bank Notes (Scotland)
Act 1845, the Stamp Act 1854 and the Currency and Banknotes Act
1928. I have not been back through those provisions but I doubt
whether I would find controls of that kind.
71. SIR ROBERT SMITH: Can I just clarify
that whilst this protects your legal right to issue notes it does
not protect you from anything the Treasury might decide to do
in terms of the costs or regulations they put on you in terms
of issuing notes.
72. MR FISHER: That is correct, it is
entirely neutral. It is ensuring that we are in the same position
tomorrow that we are today.
73. SIR ROBERT SMITH: I think you reassured
us in your evidence but there is nothing here that alters the
treatment of the customers, is there?
74. MR McCULLOCH: No. All the customer
relationships, the terms of their particular accounts, for example,
are all expressly preserved by these boilerplate provisions in
the Bill. Whether it is interest rates applicable to a loan account
or anything of that kind, it is all safeguarded and left neutral.
75. MR WALTER: I have a point on that.
Some years ago your firm represented the HSBC Investment Bank
Bill which came before this Committee and at that time we raised
the question of the consent of the depositors. You implied in
your opening statement that it was impractical to seek the consent
of the depositors. Have the depositors been informed so that they
might petition against this Bill if they did object?
76. MR McCULLOCH: It is part of the
requirements of Standing Orders that any Bill is advertised in
various ways. Public notice is given so that anybody who is made
aware of the Bill and has, as is said in this House, a locus
standi to object could petition and no-one has done.
77. MR WALTER: At the time of the HSBC
Investment Bank Bill we decided that we would not consider the
Bill until the depositors had been informed and, in fact, I am
sure one of your colleagues might have informed you that some
nine months elapsed before the Bill came back before this Committee
when the depositors had been informed of the change in the status
of the bank in that case. It was not entirely the same as what
we are considering here but it was not dissimilar to that situation.
I just question why you thought it not prudent to inform the depositors
of what you were proposing to do.
78. MR McCULLOCH: Sir, I have not gone
so far as to say that. It may be, and I may need to turn to Mr
Fisher here, that at various times in various ways customers of
the bank have been made aware as customers rather than just as
members of the public that these changes were being proposed.
If I could just clarify this: by "depositors" I am assuming
you mean any person who holds an account?
79. MR WALTER: Yes.
80. MR McCULLOCH: Whatever they may
or may not have been informed in the past, I would expect there
to be some future programme of information for customers during
the development of this scheme of the reduction in bank licences.
81. MR FISHER: That is correct. We intend
to be communicating with our customers during the period, if we
are successful in obtaining the enactment of the Bill, and prior
to on a day appointed by us for bringing it into effect exactly
what is intended to happen on the appointed date.
82. MR McCULLOCH: I am looking in my
notes to see just how many customers there are and I cannot put
my finger on the figure. To some extent this goes to the reason
why we seek a Bill because of the difficulty of communicating
with tens of thousands of customers on a very large scale, the
consent of each and every one of whom would be required.
83. MR WALTER: Negative assent was sufficient
in the previous case.
84. MR McCULLOCH: I think that is the
view Parliament has taken on all Bills of this kind in that it
steps into the shoes of the interests of the customers in approving
a Bill of this kind.
85. SIR ROBERT SMITH: It does seem odd
that if you communicate with customers quite regularly with a
lot of literature there was not a thought to alert customers that
they had the opportunity to go to wherever these requirements
are, over and above the requirements to say to customers, "If
you are interested in what is happening to your bank, this is
the legislation, this is the procedure by which you can make yourself
aware of it". Not requiring their consent but at least alerting
them to its existence so if they wished to object it would be
easier for them to know this was going to happen.
86. MR McCULLOCH: I understand that
view, sir. The bank have made no secret of it, if I can put it
that way round. They have complied with the Standing Orders to
make the provisions of this Bill made known to everyone. It would
be fair to suggest that there is a proportionality point to be
taken into consideration here when there is such a large number
of customers available. Yes, the bank does obviously communicate
with its customers in other ways at other times but it is a substantial
87. CHAIRMAN: Thank you, Mr McCulloch.
88. MR WALTER: I have one other point
which relates to the Clerical, Medical and General Life Assurance
Society winding up. You said that part of the provision of this
Bill is to wind up the Society. Does the Society have any outstanding
endowment misselling claims against it and, if so, what would
be the implications of winding it up?
89. MR McCULLOCH: I think the whole
undertaking of the Society has been transferred to CMIG and it
is purely the residual assets we are talking about here.
90. MR FISHER: That is correct. The
whole of the business is conducted by CMIG.
91. MR McCULLOCH: If anybody wished
to bring a claim for anything they would not be denied the opportunity
to do so by virtue of this transfer.
92. CHAIRMAN: Thank you. If my colleagues
are happy with the explanation for the late arrival of the amendment
and have no objections to that amendment and are also happy with
everything else you have told us, Mr McCulloch, I do not think
you need to withdraw whilst we consider this. We are happy for
the Bill to pass. Perhaps you would like to prove the preamble?
MR BRIAN WHITE FISHER, Sworn
Examined by MR McCULLOCH
93. MR McCULLOCH:
Thank you, sir. This will be proved by Mr Fisher. Are you
Brian White Fisher?
(Mr Fisher) I am.
94. Are you the Head of Group Legal Services
of HBOS plc?
(Mr Fisher) I am.
95. Have you been involved in the preparation
and promotion of the Bill on behalf of the HBOS Group, the subsidiaries
concerned and in particular the Governor and Company of the Bank
of Scotland and Clerical Medical Investment Group Limited?
(Mr Fisher) I have.
96. Have you read the preamble to the Bill?
(Mr Fisher) I have.
97. Is it true?
(Mr Fisher) It
98. MR McCULLOCH: Thank you.
The witness withdrew
Thank you again, Mr McCulloch. We are happy for the Bill to
go on its way and we hope everything to do with it will have a
smooth passage. Thank you very much.