Submission from Santander UK (S045)
1. Santander UK plc ("Santander UK") welcomes the opportunity to present evidence to the Parliamentary Commission on Banking Standards.
2. Santander UK is mainly a retail and commercial bank: some 90 percent of profits after tax are derived from retail and commercial banking activities. Santander UK is a wholly owned subsidiary of Banco Santander S.A. ("Santander"). Santander UK is self-sufficient in capital, funding and liquidity and operates autonomously from its Spanish parent company.
3. Santander has invested more than £16bn into the UK economy through the acquisitions of troubled financial institutions including Abbey National (c. £9bn, 2005), Alliance & Leicester (£2.3bn, 2008), and Bradford & Bingley (£612m) and a recent capital injection of £4.5bn (2010) to further develop its business in the UK.
4. This makes Santander one of the largest inward investors in the UK economy. These investments are proof of Santander’s ongoing commitment to building a strong and stable retail and commercial banking sector in the UK, to retaining and creating jobs in the UK, and to supporting businesses and families in the UK to grow and prosper.
5. Santander UK is embedded in communities throughout the UK with some 25 million customers, 24,500 employees, 1,350 branches, and 1.6m UK-based shareholders.
6. Santander UK is dedicated to earning and keeping the trust of its customers. Trust is the cornerstone of the Santander business model and the foundation of its corporate values. Santander UK is working to build a full-service, diversified retail bank around the needs and interests of its customers. Santander UK is also making a significant contribution to economic growth by focusing on growing its lending to small and medium-sized enterprises in the UK, which it did by 18 percent in the last year.
7. Santander UK has maintained the strengths of its building society heritage in savings and mortgage products and is growing its presence in the current account market and SME banking. By doing so, Santander UK is bringing significant competition to the UK high street as the first serious challenger to the incumbent ‘Big Four’.
8. Santander UK's balance sheet is one of the most UK-focused with an exposure of less than 0.5 percent of assets to eurozone periphery countries. More than 99 percent of customer assets are UK-related and 85 percent of its customer loans are prime residential mortgages to UK customers, with the balance being to UK businesses.
9. Unlike most global banks and many UK banks, neither the Santander Group nor Santander UK have ever needed state assistance. In contrast to many competitors, Santander’s prudential strength during and after the global financial crisis has allowed it to grow its retail and commercial banking businesses throughout the world.
10. As a UK-based retail and commercial bank, Santander UK will confine its evidence to commentary on issues relating to retail and commercial banking activities in the UK market only.
Question 1: To what extent are professional standards in UK banking absent or defective?
11. High professional standards are essential to the proper functioning of the retail and commercial banking sector.
12. Over time, professional standards evolve to reflect new products, new risks and the changing expectations of consumers and society at large. With the benefit of hindsight, Santander UK would recognise that the evolution of professional standards in some parts of the retail and commercial banking sector may not have always kept pace with the rapid evolution of banking products and risks. At the same time, we would encourage the Commission to recognise that UK consumers have been generally well served by product and process innovation by banks and a significant widening of choice and access to banking products.
13. In recent years, professional standards have been called in to question in the wake of:
· Prudential failures, e.g. the collapse of retail banks and former building societies in the UK. The incidence of prudential failure has varied across the retail and commercial banking sector. A number of retail and commercial banks, including Santander UK, avoided prudential failure altogether during the recent financial crisis.
· Conduct failures, e.g. product mis-selling or "Treating Customers Fairly" (TCF) issues. The incidence and type of conduct failure have varied across the sector. Some instances have been to a greater or lesser extent common to most major UK retail and commercial banks, for example the mis-selling of Payment Protection Insurance (PPI), but other instances have been confined to individual institutions.
14. For this reason, Santander UK would encourage the Commission wherever possible to differentiate between institutions within the retail and commercial banking sector in order to reflect the diversity in incidence and type of prudential and conduct failures.
Question 1a: How does this compare to (a) other leading markets?
15. The financial crisis was an international crisis. Prudential and conduct failures have occurred in retail and commercial banks in a number of countries around the world. Instances of prudential and conduct failure do not seem to have been correlated with a particular regulatory or supervisory model.
Question 2: What have been the consequences of the above for (a) consumers, both retail and wholesale, and (b) the economy as a whole?
16. Historically, consumers have been well served by retail and commercial banks in the UK. The UK’s high levels of owner-occupation, credit card use, mobile and internet banking, and pre-crisis availability of lending for both retail and corporate customers point to a financial services market that offers consumers high levels of choice and value. 93 percent of households in the UK have access to a bank account compared to a benchmark of 91 percent for OECD and non-OECD high-income countries. 
17. Conduct failures have a direct impact on consumers in terms of unsatisfactory TCF outcomes. Some indication of the severity of this impact is evident in the high levels of remediation set aside by the UK retail and commercial banking sector to cover conduct failures such as PPI mis-selling, for which total current provisions amount to approximately £9bn. However, it is important to ensure that remediation levels are assessed in a consistent and unambiguous way in order to avoid encouraging the development of a compensation culture.
18. Conduct failures have also led to a considerable increase in conduct regulation, e.g. the Retail Distribution Review (RDR), an unintended consequence of which may be the removal of basic advice options as well as mass market investment advice as banks consider further reductions in their offerings.
19. It is difficult to separate the impact of prudential failures on consumers and the economy in the UK from the impact of the international financial crisis as a whole, of which the prudential failures mentioned above were partly the product. The years preceding the financial crisis were characterised by macroeconomic imbalances, monetary expansion, an unsustainable credit boom, and asset price inflation. The total debt-to-GDP ratio in the UK rose by 177 percentile points between 2000 and 2008.  As one of the world’s more open economies and most important financial centres, the UK was particularly exposed to the impact of the financial crisis. The result has been economic downturn and significant deleveraging, not just by banks, but by consumers, businesses and the Government.
20. Deleveraging by the retail and commercial banking sector has been exacerbated by a significant increase in prudential regulation in response to prudential failures. This has constrained the capacity of banks to lend, which may have led to instances in which sound businesses have been unable to access the credit they need to realise growth and investment plans.
Question 3: What have been the consequences of any problems identified in question 1 for public trust and in, and expectations of, the banking sector?
21. The financial crisis has resulted in a significant loss of public trust in the retail and commercial banking sector. According to one recent survey, the public has an unfavourable opinion of the sector by a margin of 27 percent.
22. Conduct failings have compounded this loss of public trust. A recent Which? Report showed the extent to which trust in banks has deteriorated over recent years: 71 percent of respondents believed that general banking culture had not improved since the financial crisis. Santander UK recognises that it may take many years to regain this trust.
23. The loss of public trust is something we regret and it is a clear call-to-action for the retail and commercial banking sector. Retail and commercial banking is a public responsibility as well as a business. The services that banks provide are an integral part of every personal and corporate lifecycle. This sets retail and commercial banking apart, and makes bankers the "custodians of institutions of great public interest." 
24. Santander UK believes that customer-oriented models of retail banking can help the sector to regain the public’s confidence. The survey cited above also showed that members of the public still have a positive opinion of their own retail bank by a margin of 38 percent. This suggests that, by focusing on serving the needs and interests of their customers, individual banks can begin to rebuild trust in the sector as a whole.
Question 4: What caused any problems in banking standards identified in question 1?
25. As a retail and commercial bank focused exclusively on the UK, Santander UK proposes to confine its answer to consideration of the general themes and weaknesses that it believes to be most applicable to the UK retail and commercial banking sector.
26. With regard to the generic causes of prudential and conduct failures, Santander UK would echo the conclusions of the Turner Review in suggesting that the combination of a failure of supervision and a failure of corporate governance was the main the cause of prudential and conduct failure in the UK retail and commercial banking sector in the run up to and during the financial crisis. As the Turner Review stated: "improvements in the effectiveness of internal risk management and firm governance are also essential… There were many cases where internal risk management was ineffective and where boards failed adequately to identify and constrain excessive risk taking." 
27. Santander UK has consistently supported recommendations to address weaknesses in corporate governance, specifically with respect to the prudential risk function and to Board oversight. Santander UK would echo the recommendations of the Walker Review that in future the risk functions within retail and commercial banks should be independent of executive management and have the authority within the corporate structure to challenge strategy or day-to-day decision-making. Non-Executive Directors should also be empowered to provide greater levels of oversight and challenge to executives who may be pursuing aggressive growth strategies.
28. With regard to some of the more specific causes of prudential and conduct failure, Santander UK would suggest that recent instances have indicated that certain additional areas of corporate governance could have been strengthened; that incentives and objectives could have been better balanced between targets and positive customer outcomes; and that front-line training and qualifications could have been improved.
Features of the UK market structure
29. Over recent decades, the UK retail banking market has developed a number of features including a tendency to use cross-subsidies, high upfront discounts and complex charging structures. These features have been noted in a number of reports in recent years including the Government’s UK Mortgage Market: taking a long-term view (2004), with respect to the mortgage market, and the Treasury Select Committee’s report Competition and choice in retail banking (2011), with respect to personal current accounts. These tendencies have provided a context, and in some cases they may have acted as catalysts, for certain kinds of conduct failure. For example, high upfront discounts and the proliferation of products with complex charging structures may have contributed to unsatisfactory TCF outcomes.
Weaknesses in other areas of corporate governance
30. We would suggest that recent conduct failures may in some cases have revealed a need to strengthen corporate governance and board effectiveness with regard to the risk function, audit and compliance controls, product approval processes, and professional cultures.
i). Risk management
31. In some cases, the definitions used of risk may have needed broadening in order to encompass the full range of conduct risks to which banks were subject. This might have avoided potential situations in which risk functions failed to identify or avert the full range of potential conduct failures. For example, the FSA noted in its report Banks’ management of high money-laundering risk situations (2011) that "at more than a quarter of banks visited, the risks they sought to mitigate were of limited relevance to anti-money laundering." 
ii). Control functions
32. Control functions like Compliance and Internal Audit may have required more resources in retail banks where conduct failures occurred. FSA enforcement and redress actions have identified instances in which Compliance and Internal Audit functions lacked the resources or authority to consider fully or report on risks, or in which Boards and executive committees failed to act on reports provided to them. For example, the FSA identified "a failure to respond to compliance concerns" in its Final Notice issued to the Norwich & Peterborough Building Society. 
iii). Product Approval Processes
33. Product mis-selling and other TCF issues may have arisen as a result of, among other things, defective product approval processes. In some instances, new products may have been subject to insufficient levels of scrutiny or the approval process itself may have failed to take a sufficiently end-to-end view by not taking the sales process or the customer into consideration by testing customer outcomes. An example of this was highlighted in the FSA’s Final Notice over the sales process used in the distribution of Structured Capital At Risk Products. 
iv). Professional culture
34. In some cases, professional cultures may have needed strengthening. Senior management may not have articulated or communicated the appropriate corporate values with sufficient clarity and a firm’s strategy may have needed to be more closely aligned with the interests of its customers. The FSA has in recent Final Notices drawn attention to these types of issues with regard to professional culture. 
Balancing incentives and objectives with positive consumer outcomes
35. Incentive structures in some instances could have been linked to a more diverse set of objectives. For example, rewards might have been aligned with sales targets alone rather than a balanced set of performance indicators such as customer satisfaction, customer retention, service quality and risk. In some instances, this may have incentivised the sale of unsuitable products to customers.
36. In addition, one feature of the UK retail and commercial banking sector has been a high degree of focus on product lines. In order to achieve compliance on a product-by-product basis, retail banks have been required to employ staff specialising in single product lines. In some cases, this high degree of role specialisation may have created the incentive for specialised staff to sell specific product types to customers without sufficient regard to their overall needs.
Training and qualifications
37. We would accept that changes in the level of training and qualifications among employees in the retail and commercial banking sector may in part have contributed to instances of conduct failure.
38. Over recent decades, banking roles have become increasingly commoditised as a result of specialisation in individual product lines. This trend has been reflected in the growing specialisation of the types of qualification available from specialist providers. Over time, this may have resulted in fewer bank staff having the kinds of all-round banking knowledge that would enable them to serve customers’ needs in a comprehensive way.
39. Furthermore, product specialisation has led to the development of an asymmetry between the level of qualifications required of regulated-product sales staff and the level expected of general sales staff. The result of this has been in some cases to change the overall types of responsibility held by branch managers and other front-line staff. In turn, this may have contributed to the demise of a traditional retail banking model in the UK based around generalist branch managers familiar with their customers’ overall financial situations. These trends may have played a part in driving instances of product mis-selling and other unsatisfactory TCF outcomes.
Question 5: what can and should be done to address any weaknesses identified? To what extent are such weaknesses subject to remedial corporate, regulatory or legislative action, domestically or internationally?
40. Since the onset of the financial crisis, significant efforts have been made by governments, regulators and banks, domestically and internationally, to identify and address weaknesses in the sector. Many of these efforts have resulted in substantial reforms that have already been or are in the process of being implemented.
41. Examples of reform at the legislative level in the UK include the Banking Reform Bill and the Financial Services Bill. At the European level, there are 61 separate measures regarding financial services in the legislative pipeline. In addition, UK regulators are in the process of implementing a number of reforms regarding corporate governance including the recommendations made in the Walker review and the Financial Reporting Council’s (FRC) review of the UK Corporate Governance Code.
42. These examples of recent legislative and regulatory reform at domestic and international levels will go a long a way to addressing the themes and weaknesses identified above. Many of these reforms have yet to be implemented and will, in any case, take time to settle.
43. In the view of Santander UK, the priority for the retail and commercial banking sector should be to ensure that current reforms are properly implemented. Furthermore, we would suggest that any remaining weaknesses can be addressed at the corporate level.
44. For this reason, we have in our answer below given examples of the steps that Santander UK has been taking to address potential weaknesses in its own corporate governance, incentives structures, and training regimes. We would suggest that these examples are evidence that the retail and commercial banking sector as a whole can address any remaining weaknesses of its own accord without the need for further regulatory and legislative action.
Santander UK’s approach to potential weaknesses
Features of the UK market structure
45. In the view of Santander UK, the UK retail and commercial banking sector can and should of its own accord look to offer simple, transparent products that reward customer loyalty for the lifetime of the product. Furthermore, the UK retail and commercial banking sector can and should of its own accord take further steps to organise its business around customers rather than products.
46. Santander UK supported the recommendations of the Independent Commission on Banking (ICB) to improve competition in the retail banking market, specifically measures to increase transparency and improve the switching process. We supported the transparency initiatives announced by the OFT in 2009, and we implemented annual summaries to show the costs and benefits of current accounts to the customer and changes to monthly statements. We are working with the Government to deliver a new switching service by 2013. The service will be free for the customer and will guarantee that the switch will be in place within seven working days of opening the new account.
i). Simple, transparent products
47. Santander UK has acknowledged the need to move towards the provision of simple, transparent products. For this reason, for example, Santander UK has ceased to offer packaged accounts with opaque or complex charging structures.
48. Key milestones in our move to offer simple, transparent products were the launch of our 1|2|3 credit card in September 2011 and the launch of our 1|2|3 current account in March 2012. Our 1|2|3 products are transparent, simple to understand, and offer genuine benefits to our customers through cash-back and market-leading interest rates on the current account. In the first half of 2012, over 800,000 1|2|3 credit cards and current accounts were opened, 150,000 of which switched from other banks. 93 percent of customers report being satisfied with the account and 80 percent would recommend the product if asked. Moneywise.co.uk has called the 1|2|3 product the "market-leading current account". In the view of Santander UK, these results demonstrate that banks can and should of their own accord seek to address the features of the market structure identified in paragraph 29.
ii). Customer centricity
49. Santander UK has taken a number of steps to organise its business around customers rather than products. We have undertaken a programme of customer segmentation, which has allowed us to gain a deeper understanding of the needs of individual customers and ensure that we offer the right products to the right customers. For example, Santander UK’s latest offering to affluent customers – called Select – provides a personalised service to every customer via their own relationship manager, enabling them to solve their service problems via a single point of contact. In addition, we are implementing an integrated multi-channel experience – including telephone, Internet and branches – that enables all customers to access our products and services via the channel most convenient to them.
50. Santander UK would suggest that regulators also look to promote greater customer-centricity in the UK retail and commercial banking sector. We would not suggest that this is an area in which formal regulatory action is appropriate, but we would nonetheless welcome any steps on the part of regulators to facilitate greater customer centricity in banks.
iii). Customer service
51. Santander UK recognises that customer service is an area in which it needs to improve significantly. As a result, Santander UK has made improving customer service a top priority and taken a number of steps to address the issue including returning its call centres to the UK. These actions have resulted in a 29 percent reduction over the last six months in the gap between overall customer satisfaction with Santander UK and with peers, according to the Financial Research Survey (FRS). However, Santander UK still has a long way to go to reach its goal being one of the best UK banks for customer service. To address its issues with customer service, Santander UK will need in the short term to improve complaints handling and service quality and in the long term successfully implement the kinds of customer-centric structural reforms referred to in paragraph 49 above.
i). Risk management
52. The Santander Group’s emphasis on prudent risk management has provided the model for Santander UK’s own risk management framework. The Santander Group model is characterised by the independence of the risk function from the business side of the bank; the involvement of the Board and senior management on a collective basis in decision-making; the diversification of risk across geographies, products and customers; and the high levels of expertise and the significant resources dedicated to the risk function. A particular hallmark of the Santander Group model is the Chief Risk Officer’s (CRO) membership of the Board.
53. Santander UK has taken steps to develop a fully-empowered, independent and holistic risk function by separating the Santander UK Board’s Audit and Risk Committee and by enabling the CRO to focus on strategic risk oversight rather than day-to-day risk management. In addition, we have created the position of Chief Risk Management Officer, who focuses on financial risks, and created a risk oversight unit to assist the CRO in advising the CEO and respective committees. Santander UK’s risk framework looks at financial and non-financial risks holistically to help minimise TCF issues and potential breakdown of controls.
54. That said, we would like to emphasise that a truly prudent bank is never complacent. Like every bank, Santander UK depends on the trust of its customers. Everything we do in terms of corporate governance is dedicated to ensuring that we avoid complacency and maintain the highest standards of prudent risk management.
ii). Control functions
55. Santander UK’s Internal Audit function working in conjunction with Compliance supports the Board Risk Committee by providing independent and objective opinions on the effectiveness and integrity of risk management arrangements. It does this via a systematic programme of risk-based audits of the controls established and operated by operational management and support functions and also those exercised by the risk oversight function. The Internal Audit function has the authority it needs to play an integral role in the business review process and to hold business divisions to account. Our effective control functions allow us to detect products that fall outside of our risk framework and respond proactively. One example of such early intervention resulted in an insurance product being withdrawn from sale shortly after launch due to advice quality metrics not being met. The product was only re-launched after an in-depth review and staff retraining to ensure that suitable and effective advice around this product could be delivered.
iii). Product approval processes
56. Santander UK has designed its product approval process to ensure that the potential defects identified in paragraph 33 are mitigated by establishing a Product Approval and Oversight Committee (PAOC), which is chaired by the Chief Financial Officer (CFO) and comprises senior representatives from all key functions in the organisation. The purpose of assembling such a diverse group is both to gain a holistic perspective on new products and to create an environment in which sufficient challenge exists. This ensures that PAOC’s duties in terms of product approval and continuous oversight are properly discharged with particular focus on guaranteeing that any new product or service sold achieves the right customer outcomes. PAOC considers the full spectrum of risks.
iv). Professional culture
57. In the view of Santander UK, the most important ingredient in fostering a strong professional culture is appropriate leadership from the top of the organisation combined with a clear corporate strategy. We believe that senior management should lead by example and regularly and consistently communicate key corporate values and the way in which these values relate to corporate strategy.
58. Santander UK’s senior leadership has consistently highlighted the importance of honesty and integrity at the product-design phase, giving customers appropriate advice, and putting the interests of customers before the interests of the bank. Communications are built around a clear aspiration: to make Santander UK the best bank for its people, its customers and its shareholders. The drive to transform Santander UK in to the customer-focused organisation referred to in paragraphs 49 has involved developing and communicating a new set of corporate values as well as leading the implementation of a number of operational initiatives
59. In the view of Santander UK, we have to consistently review the balance of incentives between targets and positive consumer outcomes such as customer satisfaction, customer retention and risk.
60. At Santander UK, we maintain our incentive schemes for branch staff in accordance with this aim. In order to be eligible for the branch incentive scheme, staff members must meet a minimum set of standards across a range of metrics including customer satisfaction, operational risk, advice quality and complaints handling. Once an individual qualifies, the scheme then rewards them according to their performance in terms of new business generation, customer retention, customer satisfaction, operational risk, advice quality and complaints handling. All schemes are geared to ensure reward is only issued when a balanced performance is achieved across all elements of the scheme.
61. Furthermore, Santander UK does not set minimum performance requirements for specific product areas. This approach ensures that Santander UK’s branch teams and advisors are able to meet business growth targets with the products that are most appropriate to the needs of each individual customer.
62. Santander UK would argue that regulators should continue to permit the retail and commercial banking sector to innovate with performance-related incentives. It is our view that the principle of performance-related incentives remains sound, and banks, like other industries, need the freedom to motivate, evaluate and manage the performance of their staff.
Training and qualifications
63. In the view of Santander UK, we have to continuously improve the training of front-line staff and support the development of professional standards certification regimes that embed ethical awareness, and establish mechanisms for monitoring and enforcing these standards.
64. The long-term goal of Santander UK is to align staff training and qualifications with the Santander Group model that supports highly-qualified, generalist staff in front-line roles that carry significant authority and responsibility. We recognise that the UK employment market is different to other markets in which the Santander Group operates with a relatively high staff turnover, particularly in key areas such as the South East. However, Santander UK continues to invest significant resources in staff training and will continue to look to raise the qualifications of front-line staff.
65. Santander UK is a founder member of the Chartered Banker Professional Standards Board (CB: PSB), a joint initiative under the auspices of the oldest banking institute in the world to develop a series of professional standards to support the ethical awareness, customer focus and competence of those working in the banking industry. Santander UK is currently working to implement the CB: PSB’s draft framework throughout the organisation. We believe that the Chartered Institute of Bankers in Scotland (CIOBS) and the IFS are suitable organisations to work with on the introduction of such industry-wide qualification regimes. We would support moves to extend the reach of these organisations and put their work on a more formal footing.
Question 6: Are the changes already proposed by (a) the Government, (b) regulators and (c) the industry sufficient? Respondents may wish to refer to the Financial Services Bill and the Government's proposals for the Banking Reform Bill. They may also wish to refer to proposals by the Bank of England and the Financial Services Authority on how the Financial Policy Committee, Prudential Regulation Authority and Financial Conduct Authority will operate in practice.
66. The changes already proposed by the government, regulators and the industry are substantial. In the UK, the Financial Services Bill will transform the regulatory framework for financial services, and the Government’s proposals for the Banking Reform Bill will lead to the most significant reform of the banking sector in decades.
67. The Walker Review has resulted in major changes to the FRC Corporate Governance Code and the FSA’s Approved Person Regime and the Kay Review is likely to result in further reforms to corporate governance for financial institutions in the UK.
68. As explained above, at a European Union level, 61 separate pieces of EU legislation regarding financial services are currently going, or about to go, through the legislative process. A further five dossiers are planned for 2013 and there is an ongoing inquiry into the EU-wide structural reform of banking being led by the Liikanen Group.
69. These legislative and regulatory initiatives at domestic and international levels are in addition to the very significant and numerous internal changes that all banks in the retail and commercial sector have undertaken in the wake of the financial crisis.
70. Santander UK has supported all proposed legislative and regulatory initiatives that will help to create a stronger and more stable financial system. These numerous initiatives may help to restore public trust in the banking sector and may help to prevent the repetition of some of the major prudential failures and conduct failures seen in recent years.
71. In the view of Santander UK, the current challenge is to ensure that the many changes already proposed are implemented in such a way that they meet three tests: improve the strength and stability of the financial system; improve outcomes for consumers; and enable banks to play their full part in supporting economic growth. Despite current perceptions, we do not believe that it would be fair to suggest that the retail and commercial banking sector is still engaged in pre-financial-crisis ‘business as usual’. On the contrary, we would submit that the sector is undergoing the biggest bout of re-regulation and self-imposed corporate reform in decades. In the executive summary of its final report, the ICB stated that "together with other reforms in train, [the ICB’s reform package] would put the UK banking system of 2019 on an altogether different basis from that of 2007." 
72. For these reasons, Santander UK would urge the Commission to assess the impact of the many legislative and regulatory changes already proposed or in the process of being implemented before proposing further reforms. Reforms should look to protect the customer but also recognise the need for a profitable retail and commercial banking sector and avoid undermining the ability of banks to attract investor capital and innovate on behalf of customers. It is a prudential necessity for banks to be profitable: banks must generate capital and maintain high levels of liquidity to satisfy regulators and to reassure depositors that their money is safe and maintain trust in the banking system as a whole.
 The World Bank, Financial and Private Sector Development (June 2011)
 McKinsey Global Institute, Debt and Deleveraging: uneven progress on the path to growth , (January 2012), p. 5
 Lord Turner, ‘Banking at the cross-roads: where do we go from here?’ Speech at Bloomberg , (FSA, 24 July 2012)
 Financial Services Authority, The Turner Review: a regulatory response to the global banking crisis (FSA, 2009), p. 92
 Financial Services Authority, Banks’ management of high money-laundering risk situations , (FSA, 2011), p. 4
 Financial Services Authority, Final Notice, Norwich & Peterborough Building Society (15 April 2011)
 Financial Services Authority, Final Notice, Lloyds TSB Bank Plc (24 September 2004)
 See for example: Financial Services Authority, Final Notice, Bank of Scotland Plc (9 March 2012)
 Independent Commission on Banking, Final Report Recommendations , (2011), p. 18